Design and Distribution Obligations (DDO)


What is DDO?

DDO is intended to help customers obtain appropriate financial products by requiring manufacturers (e.g. lenders) of financial products and distributors (e.g. brokers) to have a customer-centric approach to designing and distributing products. DDO helps ensure that consumers are receiving products that are likely to be consistent with their objectives, financial situation and needs. 

Target market determination (TMD) is a document created by the product manufacturer (e.g. lenders) which describes the type of customer that the product is designed for. 

How does this impact you?

As a broker, to meet DDO you’ll need to:

Understand the TMD

Product distributors have an obligation to take reasonable steps to ensure the customer fits the target market of the product, as specified in the TMD. However, given that mortgage brokers have to meet Best Interests Duty (BID) obligations, the products you recommend will likely be in the client’s best interests even if they fall outside the TMD - if there is another reason why the client selected the particular product, it is to be recorded. 

What this means is, it’s ok to recommend a product to a customer even if they don’t fit the TMD, you’ll just need to record this and the reason(s) why. This can be done in the Lender and Product Selection Rationale in MyCRM by answering the TMD question(s). Note: the answers to these questions will not appear in the Game Plan.

It’s important to note that you don’t need to provide a copy of the TMD to a customer unless they request to see it. TMDs can be located in the Product Finder. 

Record product complaints

You will be required to notify Loan Market of any complaints you may receive in relation to a product by recording it in the Complaints form in MyCRM under Resources > Complaint/Situation. 

If you are unsure about whether a customer fits the TMD or need more information you can contact compliance@loanmarket.com.au