DDO Reporting
The Design and Distribution Obligations (DDO) regime introduces targeted and principles-based design and distribution obligations in relation to financial products. The obligations require issuers and distributors to ensure products are targeted at the right people (ie the target market).
On 5 October 2021, the Design and Distribution Obligations (DDO) will come into effect for all issuers and distributors of financial products that are covered by DDO.
A Target Market Determination is a document which describes a group of retail clients (the target market) for whom a product is likely to be appropriate or consistent with their likely objectives, financial situation and needs, plus any conditions around how the product can be distributed.
It also describes the events or circumstances where we may need to review the Target Market Determination for a financial product.
Why are TMDs required?
We’re required to have Target Market Determinations under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.
This is to make sure we’re keeping investors at the centre of our approach to the design and distribution of our financial products.
Target Market Determinations
Ellerston Australian Absolute Return Fund TMD
Ellerston Global Equity Managers Fund TMD
Ellerston Australian Emerging Leaders Fund TMD
Ellerston Australian Micro Cap Fund TMD
Ellerston Australian Share Fund TMD
Ellerston Equity Income KIS Fund TMD
Ellerston Asia Growth Fund (Hedge Fund) TMD
Ellerston Global Mid Small Cap Fund TMD
Ellerston India Fund TMD
Ellerston JAADE Private Assets Fund TMD
Super Obvious Everest Fund TMD
Complaints Reporting
DDO requires external distributors of our products to report to us the volume of complaints they have received about our products covered by our TMDs, on a regular basis.
A complaint is an expression of dissatisfaction made to us by an account holder (or someone legitimately representing their interests), related to our products or services where a response or resolution is explicitly or implicitly expected or legally required.
Distributors should refer to ASIC’s guidance on complaints (Regulatory Guide 271) for further information.
Every quarter, distributors will need to report to us the number of complaints they received about our products that they distribute, even if this is zero.
These reports need to be received within 10 business days of the end of each reporting period, which end on:
- 31 March;
- 30 June;
- 30 September and
- 31 December
Complaints reporting under DDO is separate from any other complaints we may receive.
If you would like to report a complaint please email us at ddoreporting@ellerstoncapital.com.
Significant Dealings
A significant dealing report is intended to capture material or significant distribution of a product outside of its TMD.
Whether or not a dealing is significant will depend on a variety of circumstances, including the scale of distribution outside the target market and the risk of harm to those consumers from such distribution.
Each distributor will need to make an individual assessment in the circumstances of each case to determine when a dealing (or dealings) outside of a TMD is significant and needs to be reported.
A distributor must report any significant dealings to us within 10 business days of them becoming aware of the dealing.
Distributors will need to provide us with the following details for any significant dealing that is identified:
- the TMD the significant dealing relates to;
- the date or the date range which the dealing occurred;
- a description of the dealing;
- an explanation of why the dealing is considered significant;
- an explanation of why the dealing is considered to be inconsistent with the TMD;
- how the dealing was identified (eg, through monitoring, complaints etc); and
- what steps have been or will be taken in relation to the significant dealing.
If you would like to report a significant dealing please email us at ddoreporting@ellerstoncapital.com.
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