From 5 October 2021, issuers and distributors of financial products that are distributed to retail clients must comply with the Design and Distribution Obligations under the Corporations Act 2001 (DDO Regime).

  • The DDO Regime introduces new obligations on all product issuers (BT/External Funds) and distributors (Advisers) to ensure products are designed for specific targeted class of customers (target market) and are directed towards the target market by specifying distribution conditions and
  • Requires reasonable steps are in place to ensure that customers are offered products that are likely to be consistent with their objectives, financial situation and needs.

On this page we have the latest information on:

  • Our Target Market Determinations (TMDs)
  • How and when you can access our DDO Reporting Tool in readiness for 5 October 2021
  • Instructions for using our DDO Reporting Tool, including a short training video.

The information contained on this web page does not relate to Protection Plans life insurance products.

Overview of DDO

DDO requires issuers and distributors to take a consumer-centric approach - placing consumer outcomes front and centre at the product design, product distribution, and monitoring and review stages of the product life cycle.

ASIC has published Regulatory Guide RG 274 – Product Design and Distribution Obligations outlining their expectations for compliance, and general approach to administering the obligations. The most recent Guide issued is dated December 2020. Please stay ahead of changes by referring to ASIC at www.asic.gov.au

Target Market Determinations

A Target Market Determination (TMD) is a document that describes a class of customers/group of retail clients (the target market) for whom a product is likely to be appropriate or consistent with their likely objective, financial situation, and needs plus conditions and restrictions under which the product can be distributed.

Our progress on Target Market Determinations

Our TMDs will be available online from 27 September 2021 at our website www.bt.com.au/tmd.

All BT issued TMDs will be made available on our public websites, including any TMDs that are made for badged products available through our platforms. TMDs for underlying funds available on our platforms that are issued by an external issuer, will also be available on our platforms via Morningstar.

From 5 October, if a TMD has not been received for underlying funds from external issuers, to meet our distributor obligations under the DDO Regime we will remove the underlying funds from the investment menu. For a list of impacted funds, please refer back to this website from 5 October 2021.

 

Information for Advisers

Reporting obligations and the DDO Reporting Tool

You can use the DDO Reporting Tool to report certain information to us such as a significant dealing or an acquisition outside of target market. Reporting complaints will continue via the current complaints process over the phone, via your relationship manager or the online complaints feedback form.

Any information contained in the tool regarding distributor reporting obligations is a guide only. For detailed information regarding your distributor obligations, ASIC’s expectations for compliance and their general approach to administering the obligations of the DDO Regime, please refer to the ASIC Regulatory Guide RG 274 – Product Design and Distribution Obligations.

In the coming days, we’ll email you instructions so you can register for the DDO Reporting Tool, in readiness for 5 October 2021. Registration is quick and easy – all you’ll need is the registration code we’ll send you via email. Once you receive the email from us, you’ll be able to register straight away, however the DDO Reporting Tool will only be active from 5 October 2021.

If you provide advice across multiple BT, Asgard, Advance and/or Margin Lending products, you may receive more than one invitation to register. Please note you only need to register once to gain access to the DDO Reporting Tool.

By using the DDO Reporting Tool, you will be bound by the DDO Reporting Tool Terms of use. These are located in the footer of the tool under Legal > DDO Reporting Tool Terms of Use. Please ensure you read these carefully.

It is unlikely that the DDO Reporting Tool will enable distributors to report all information that the DDO Regime may require distributors to report to a product issuer. It will not enable distributors to report complaints. Further, the TMDs for different financial products may require different information to be reported to the product issuer, and the DDO Reporting Tool does not take into account the specific reporting requirements in a TMD for any particular product. If the DDO Regime requires distributors to report a particular item of information to a product issuer and the DDO Reporting Tool does not enable distributors to enter and submit that information, distributors must report that information directly to the product issuer. If the DDO Reporting Tool is not available at any time, distributors must report the required information directly to the relevant product issuer by other means.


 

Additional information for Panorama advisers

If you’re a Panorama adviser, you won’t receive a registration email from us, as you’ll be able to access the DDO Reporting Tool from 5 October using your existing Panorama Portal login details. If you do receive an email, it may be because you provide advice for other BT, Asgard, Advance and/or Margin Lending products, in addition to Panorama. There’s no need to register as you can access the Reporting Tool with your existing Panorama login details.

You can find the DDO Reporting Tool on the Panorama Portal by following these steps:

Panorama Portal -> Business -> DDO Reporting Tool

Please note that by using the DDO Reporting Tool you will be bound by the DDO Reporting Tool Terms of use.

Additional information for non-Panorama advisers

If you are a non-Panorama adviser, you can use our DDO Reporting Tool to report any Significant Dealings or Acquisition Outside Target Market. If you are an external adviser and do not have an account with us nor access to our DDO Reporting tool, complete the registration form to obtain access to the DDO Reporting Tool available here.

For more information about the design and distribution obligations (DDO) and your obligations as a distributor, please refer to ASIC Regulatory Guide 274.
 

DDO Reporting Tool training module

Our short online training module, which demonstrates how to use the DDO Reporting Tool and provides an overview of DDO distributor obligations, is available now. The module will step you through how to report significant dealings and acquisitions outside of target market.

Update on Reasonable Steps obligation

We’re updating our trading terms and conditions to meet our Reasonable Steps obligation. These will now include confirming that the investor has received personal advice in respect of the transaction being submitted. These updates are effective from 5 October and will be available when submitting a trade.

Update to Panorama User Agreement

In connection with the introduction of Design & Distribution Obligations, the Panorama User Agreement will be amended to include a new section on page 7 titled “Applications”. You are directed to only submit an application on and from 5 October 2021 for a Panorama product on behalf of a client if:

  1. You have provided the client with personal advice in relation to the relevant product;
  2. The advice is consistent with applying for the relevant product and remains current at the time the application is submitted;
  3. The client is within the target market of the relevant product.

 

Frequently asked questions (FAQ)

Click through to view a range of FAQs covering key topics.

1. Will all BT products require a TMD?

No, but most will. In addition, some products that are issued by third parties, but available for selection through our platform products, will also require a TMD. 

We are also working with third party product issuers to collect TMDs for those products wherever possible, although it is that issuer's responsibility to make their TMDs available free of charge.

2. What specific additional information will BT be requiring distributors to provide?

From 5 October 2021, BT will require distributors to notify us of the following information:

  • Complaints in relation to the product covered by the TMD (including details of the complaints): at least quarterly;
  • Acquisitions outside the target market of the TMD for a product: at least quarterly;
  • Significant dealings that are not consistent with the TMD for a product (including details of the significant inconsistent dealings): as soon as practicable and within 10 business days of becoming aware of the significant inconsistent dealing.

These collection requirements are set out in each product’s TMD under the Distribution Information section.

3. How will distributors report the required information to us?

From 5 October, we are asking distributors to report required information via the following channels:

  • Complaints: via the current complaints process:
    • Over the phone: BT Adviser Relations team on 1800 025 127, BT Panorama Adviser line on 1300 784 207
    • The adviser's relationship manager
    • The secure complaints feedback form
  • Acquisitions outside of target market and significant dealings: via a new DDO Reporting Tool which has been developed to allow external distributors of BT products to report data specified in the TMD for the BT product (excluding complaints).

It is unlikely that the DDO Reporting Tool will enable distributors to report all information that the DDO Regime may require distributors to report to a product issuer. It will not enable distributors to report complaints. Further, the TMDs for different financial products may require different information to be reported to the product issuer, and the DDO Reporting Tool does not take into account the specific reporting requirements in a TMD for any particular product. If the DDO Regime requires distributors to report a particular item of information to a product issuer and the DDO Reporting Tool does not enable distributors to enter and submit that information, distributors must report that information directly to the product issuer. If the DDO Reporting Tool is not available at any time, distributors must report the required information directly to the relevant product issuer by other means.

4. How does the DDO Reporting Tool work?

When reporting via the DDO Reporting Tool, on-screen prompts will be displayed to help distributors enter the required information.

5. How will BT notify distributors of a new TMD or changes to target market?

The most current TMD will be available online for distributors to review. We will take all reasonable steps to notify distributors, via desktop notification, if a new TMD or a change to target market is applicable. 

Contact us

We’re here to help. If you can’t find the answer to your question in the FAQ section above, please contact us.