Design and Distribution Obligations

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.

We’re currently working through our obligations as an issuer and distributor, as well as how we’re going to work with the distributors of our products to meet these new requirements.

As we work through these new requirements, we’ll update the information on this page so stay tuned for more detail on our proposed approach.

What are the Design and Distribution Obligations?

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 number of financial products including (but not limited to) home loans, credit cards, car loans, wrap platforms, managed funds and bank accounts.

What is a Target Market Determination (TMD)?

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.

Target Market Determinations

From 5 October 2021, you’ll find TMDs for all of our lending, deposit and wealth products here.

Product Link

Macquarie Home Loans (including Offset Transaction Account)

Coming soon

Macquarie Credit Cards

Coming soon

Macquarie Consumer Loan (Asset Finance)

Coming soon

Macquarie Property Versatile

Coming soon

Macquarie Fully Drawn Advance

Coming soon

Macquarie Smart Business Loan

Coming soon

Macquarie Strata Improvement Loans

Coming soon

Macquarie Revolving Line of Credit

Coming soon

Macquarie CommOne

Coming soon

Product Link

Macquarie Transaction and Savings Accounts

Coming soon

Macquarie Business Banking Accounts

Coming soon

Macquarie Cash Management Accounts

Coming soon

Macquarie Term Deposit

Coming soon

Macquarie Express Guarantee

Coming soon

Product Link

Macquarie Wrap Super

Coming soon

Macquarie Wrap Pension

Coming soon

Macquarie Investor Directed Portfolio Service (IDPS) 

Coming soon

Macquarie Separately Managed Accounts

Coming soon

Reporting requirements

What’s a complaint?

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.

What does a distributor need to do?

Every six months, distributors will need to report to us the number of complaints they received about our products that they distribute, even where 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; and
  • 30 September

To ensure we continue to meet the highest standards for the products we issue, any complaints about our products should still be raised via our online complaints form as soon as they occur. Complaints reporting under DDO is separate from any other complaints we may receive.

How do distributors report complaints data to us under DDO?

We’re currently working on a portal to allow distributors of our products to report DDO complaints data to us.

We’ll be updating this page with instructions for providing this information to us before the first reporting period (ending on 31 March 2022).

What is a significant dealing?

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 reporting to Macquarie.

What does a distributor need to do?

A distributor must report any significant dealings to us within 10 business days of them becoming aware of the dealing.

How do distributors report a significant dealing to us?

Before 5 October, we’ll update this page with specific instructions on how to provide us with reports of significant dealings.

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.

Frequently asked questions

DDO applies to issuers and distributors of financial products that are sold to retail clients. The term ‘retail client’ is defined in the Corporations Act and can include individuals and small businesses (although for lending products, DDO only applies to retail clients where the loan is for personal or investment purposes – not business purposes).

Our key responsibilities as a product issuer are:

  • to create and maintain the TMD for all our products that are covered by DDO
  • to take reasonable steps to ensure our products are distributed in line with those TMDs.

The key obligations for product distributors are:

  • to ensure there’s a TMD in place for all of the products that they distribute that are covered by DDO
  • to understand and follow the distribution conditions and reporting requirements set by the product issuer in the relevant TMD, eg they must collect and keep the information specified in the TMD, including complaint numbers (even where no complaints are received)
  • to take reasonable steps to ensure the product is distributed in line with the TMD
  • to keep records of distribution information
  • to report information to the issuer as required by the TMD.

Distribution conditions are conditions or restrictions on the sale of a product, put in place by the issuer, to ensure that the product is sold to customers in line with the TMD. Product distributors will need to adhere to the distribution conditions established in the TMD.

You’re 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.