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. The TMD:

  • Describes the Target Market: sets out the type of customer the product has been designed for having regard to the likely objectives, financial situation and needs of those customers.
  • 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

Product Link

Macquarie Home Loans (including Offset Transaction Account)

View TMD

Macquarie Credit Cards

View TMD

Macquarie Consumer Loan (Asset Finance)

View TMD

Macquarie Property Versatile

View TMD

Macquarie Fully Drawn Advance

View TMD

Macquarie Smart Business Loan

View TMD

Macquarie Strata Improvement Loans

View TMD

Macquarie Revolving Line of Credit

View TMD

Macquarie CommOne

View TMD

Product Link

Macquarie Transaction and Savings Accounts

View TMD

Macquarie Business Banking Accounts

View TMD

Macquarie Cash Management Accounts

View TMD

Macquarie Term Deposit

View TMD

Macquarie Express Guarantee

View TMD

Product Link

Macquarie Wrap Super

View TMD

Macquarie Wrap Pension

View TMD

Macquarie Investor Directed Portfolio Service (IDPS) 

View TMD

Macquarie Separately Managed Accounts

View TMD

Reporting requirements

What’s a complaint?

DDO requires external distributors of our products to report to us the complaints they have received about our products (covered by our TMDs).

A complaint is an expression of dissatisfaction made by an account holder (or someone legitimately representing their interests) related to our products, 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?

We expect distributors of our products to report complaints to us as soon as they occur, using our online complaints form.

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 TMD and the risk of harm to those consumers from such distribution.

Each distributor will need to make their own assessment as to whether a particular dealing (or dealings) outside of a TMD is significant and needs to be reported to Macquarie.

What does a distributor need to do?

A distributor must report any significant dealings to us as soon as possible, but at latest within 10 business days of becoming aware of the dealing.

Significant dealings must be reported to Macquarie via email:  ddosignificantdealings@macquarie.com and should contain the following details:

  • The TMD the significant dealing relates to;
  • The date on which or the date range over 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 keep and report on the information specified in the TMD)
  • 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.

Note: In certain circumstances involving Personal Advice, the distributor reasonable steps obligations do not apply.

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.

Note: In certain circumstances involving Personal Advice, the distributor reasonable steps obligations do not apply.