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TMD and DDO for financial advisers

New legislation to ensure that financial institutions that issue or distribute financial products have a consumer-centric focus.

From 5 October 2021 under the government’s Design and Distribution Obligations (DDO), product issuers (Sunsuper) and distributors (financial advisers) are required to develop and maintain effective product governance strategies across the lifecycle of financial products to help ensure that customers obtain financial products that align with their likely objectives, financial situation and needs. The purpose of the legislation is to ensure that financial institutions that issue and/or distribute financial products have a consumer-centric focus. We acknowledge that many of our financial advisers already distribute Sunsuper products with this approach.
As a financial adviser, if you are a distributor of Sunsuper products, your main responsibilities will include:  

  • Understand who the target market is
    The Target Market Determinations (TMDs) describe the class of consumers our products are designed for. You’re required to take reasonable steps that will, or are reasonably likely to, result in the distribution of Sunsuper’s products consistent with our TMDs. Our TMDs are available here.

  • Notify Sunsuper of significant dealings
    If you become aware of a significant dealing in a Sunsuper product that is inconsistent with its TMD, you’re required to notify us in writing within 10 business days of becoming aware. Information on reporting significant dealings can be found in Adviser Online.

  • Keep records
    You’re required to maintain records and information relating to the distribution of financial products. For example, the number of complaints and any other information specified in the TMD for up to 7 years.

  • Report information to the Product Issuer (Sunsuper)
    Sunsuper will require you to provide information about complaints you receive relating to our products within a quarterly reporting period. Information on reporting complaints can be found in Adviser Online.


Please note: If you don’t fulfil these requirements, as outlined in Part 7.8A of the Corporations Act, you may be liable for significant civil and criminal penalties or enforcement action from ASIC. Please refer to the legislation for further information.


Need more information?

For further information regarding DDO, click on the links to the resources below:


We’re here to help

If you'd like any further information, please feel free to contact us. We would be happy to hold a training session for you and your office, simply request your appointment here.

For any administration support, please contact the Adviser Enquiry Line on 13 11 84 (press 4 then 2) or send us an email.