ASIC has recently taken action against a financial product issuer, citing shortcomings in their Target Market Determinations (TMDs). The regulator found the TMDs failed to adequately align risk, investor timeframes, and distribution conditions — effectively exposing retail clients to unsuitable products.
This intervention is a clear signal: under the Design & Distribution Obligations (DDO) regime, TMDs are not “set and forget.” ASIC expects issuers to:
- Regularly review and update TMDs to reflect product changes, market conditions, and customer outcomes.
- Enforce robust distribution controls so products don’t land in the wrong hands.
- Act on complaints and data that suggest mis-selling or harm.
For financial services firms, the lesson is simple: governance and staff capability matter as much as paperwork. A well-drafted TMD won’t protect your business if staff don’t understand how to apply it in practice.
That’s why training is critical for product teams, compliance, sales, and adviser networks. Programs like GRC Solutions’ Design & Distribution Obligations course help teams understand the DDO framework, spot red flags, and implement controls confidently.
Trained staff are better equipped to:
- Apply TMDs consistently
- Escalate risks early
- Demonstrate compliance to ASIC
This action shows even established players can be caught short. Regular reviews and staff training are the best defence against regulatory disruption, reputational damage, and loss of investor confidence.