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Target Market Determinations

On 5 October 2021, the Design and Distribution Obligations (DDO) came into effect for all issuers and distributors of financial products that are covered by the DDO regulations.

DDO requires issuers and distributors of financial products to have a customer-centric approach to the design and distribution of their products, with the aim of helping customers to obtain financial products that are appropriate for their objectives, financial situation and needs.

The obligations apply to a broad range of financial products including (but not limited to) investor directed portfolio services and superannuation products.

Current TMDs

Accumulation TMD |

Pension TMD |

Member questionnaire

Please complete the questionnaire below to answer four questions regarding your investment objectives.

This questionnaire is only applicable to members that have received a letter from Freedom of Choice.

TMD member questionnaire


What is a TMD?

A TMD is a document that details the target market for a financial product and matters relevant to the product’s distribution and review. As a product issuer it’s our responsibility to create a TMD for each of our products covered by DDO that:

  • Describes the Target Market: Outlines the likely objectives, financial situation and needs of customers the product has been designed for.
  • Establishes Distribution Conditions: Details the conditions or restrictions on the sale of the product.
  • Establishes Reporting Requirements: Sets out the relevant information that must be provided to us by distributors at our required frequency. At a minimum, a distributor must regularly report the number of complaints it receives about the issuer’s product to the issuer, as well as report any significant dealings in the product that are inconsistent with the TMD.

TMDs do not replace Product Disclosure Statements (PDSs) nor do they lessen the importance of PDSs in the financial product decision-making process. TMDs set out who the financial product may be suitable for and how it can be distributed. It is important to note that the TMD is not a summary of the product features, nor does it outline the terms of the product. The PDS should always be referred to for the terms, conditions and features of the product before deciding whether the product is suitable for the consumer.

How do we distribute our TMDs?

Current TMDs for our products are available on this page of our website.

What are the key obligations for a product issuer?

Our key responsibilities for product issuers are to:

  • Create and maintain the TMD for all our products that are covered by DDO.
  • Take reasonable steps to ensure our products are distributed in line with those TMDs.
  • Review the TMDs to ensure they remain appropriate.
What are the key obligations for a product distributor?

The key obligations for product distributors are to:

  • Ensure there is a TMD in place for all products that they distribute which are covered by DDO.
  • Understand and follow the distribution conditions and reporting requirements set by the product issuer in the relevant TMD,
  • Take reasonable steps to ensure the product is distributed in line with the TMD.
  • Keep records of distribution information.
If you are a distributor of our product(s), what’s expected of you?

You are expected to understand the requirements we establish in the TMDs for our products. This means you need to:

  • Understand the target market defined in a TMD and take reasonable steps to ensure the product is distributed in accordance with the TMD.
  • Understand and adhere to any distribution conditions established in the TMD.
  • Provide information as specified in the TMD, at the required frequency and in the required form.
  • Keep accurate records of the reasonable steps taken and any information provided to us.
  • Report to us where you believe a significant dealing in the product which is inconsistent with the product’s TMD has occurred.
  • To report information to the issuer as required by the TMD.

We expect all distributors of AMG Super products to comply with these requirements.

How are distributor complaints and significant dealings managed?
We have created reporting templates to assist you in meeting your DDO reporting obligations. You can use these templates to report any significant dealings outside of the TMD and for product complaints.

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