Chief Commercial Officer
05 October 2021
4 min read
At the end of September, we brought together almost 200 people across the financial services industry at a forum along with Corey McHattan, regulatory lawyer and partner at Ashurst Australia. At the forum, Corey shared a legal perspective on DDO - including some last-minute relief measures - and we discussed how the industry-designed Iress DDO solution can support the new requirements.
Corey did a great job of explaining some of the less clear aspects of the DDO legislation in relation to significant dealings and some of the proposed new DDO relief measures, which we’ve summarised below.
While DDO is a ‘one size fits all’ regime, the considerations are very different for superannuation, versus insurance, versus managed funds, versus FX. The legislation sets a framework, and while ASIC sets some limited guidance for the industry, it’s up to product issuers and product distributors to determine the specifics themselves.
Notifying ASIC of significant dealings
Both product issuers and product distributors have reporting obligations if there are significant dealings in a product that are not consistent with a target market determination (TMD).
‘Significant dealing’ is not defined in the Corporations Act and whether or not a dealing is significant is a matter to be determined in the circumstances of each case.
ASIC expects that the following factors will be relevant for issuers when determining whether a significant dealing has occurred:
Proposed new relief
A number of DDO relief measures have been introduced at the last minute. Some of the proposed refinements include:
How we can help
Whether you're a product issuer, platform provider, licensee or financial adviser - we can help.
Iress’ solution brings together financial product TMD publishing and reporting capabilities across the industry as well as connectivity with distributors. Via the DDO messaging service, issuers and distributors are connected and able to manage their reporting obligations by creating and sharing complaints and significant-dealing reports across a complex network.
Simply by publishing TMDs to the Iress Blockchain, you automatically meet your first regulatory obligation, and at no cost.
Our solution today has become the most broadly adopted infrastructure for DDO and we’ve seen a lot of support from the industry, with over 1,500 TMDs already uploaded to the blockchain and 75 fund managers, four platform providers, and eight insurers onboard, along with superannuation funds, ETF providers and more.
Speak to your Iress account manager for more information or to access the full recording of the recent industry forum. You can also visit our web page for more information.