Target market determinations

ASIC has prepared a useful summary for advice licensees and financial advisers. You can find their factsheet on their website.

You’re expected to understand your own obligations as a distributor under DDO. This includes (but is not limited to):

understanding the information set out in the TMDs about our products including how we have defined the target market;

taking reasonable steps to ensure the product is distributed in accordance with the TMD;

understanding and adhering to any distribution conditions established in the TMD;

submitting the required reports, at the required intervals, and in the required format as specified in the DDO, TMD and on this web page;

keeping accurate records of both the reasonable steps you have taken in ensuring the product is distributed according to the TMD and any information you may have provided to us; and

determining your own thresholds for what you as a distributor considers to be a significant dealing in relation to our products. 

The Financial Services Council (FSC) has developed TMD templates for industry use which we have used as the basis for the TMDs for the Russell Investments Funds, ETFs, and Super and Retirement products. We chose to largely follow the FSC templates (with some minor amendments) to assist with maintaining an industry standard and to help distributors comply with DDO.

Product distributors are required to provide the following reports: 

• Complaints  
• Significant dealings

For more information about our reporting requirements, please refer to the product’s TMD.

We strongly encourage you to use the FSC data standards for the information you provide to us to fulfil your DDO reporting responsibilities. We recommend familiarising yourselves with the FSC data standards templates ahead of the first required reporting period.  

Distributors can provide DDO reports to us in two ways: 

1. Online reporting form 

Distributors can use this form to fill in the details of their DDO reports according to the FSC data standards template.

2. Email reports 

We will accept DDO reports via email. We strongly encourage the use of the FSC data standards templates, available at the FSC website under Data Standards.

For Russell Investments Funds and ETFs please send your DDO reports to Funds_DDOReporting@russellinvestments.com
For Super and retirement products please send your DDO reports to Super_DDOReporting@russellinvestments.com
 

Complaints in relation to DDO are expressions of dissatisfaction about a product.  

For DDO complaints reporting, we need complaints information for actual product complaints (i.e. expressions of dissatisfaction). 

The complaints reporting required by the TMDs, relates only to DDO. Our existing internal complaints handling processes continue as they normally would under RG271 (and previously RG 165), where we are required to acknowledge complaints as soon as practicable and resolve them within 30 calendar days for standard complaints and 45 calendar days for superannuation complaints. 

To report a complaint that is not part of your DDO reporting obligations for Russell Investments Funds and ETFs contact: disputeresolution@russellinvestments.com and for super and retirement products contact: iq@russellinvestments.com.au  

Section 994F(6) of the Corporations Act requires distributors to notify the issuer if they become aware of a significant dealing in the product that is not consistent with the TMD. Neither the Corporations Act nor ASIC defines when a dealing is ‘significant’ and distributors have discretion to apply its ordinary meaning. 

A significant dealing for a distributor may be different to the issuer’s determination of a significant dealing and guidance is provided in our TMDs that may be helpful to distributors in determining their own definitions. The FSC has prepared a flowchart to assist distributors in determining significant dealings. 
 

For questions relating to your DDO obligations and our products, please contact your relationship manager or alternatively you can direct your enquiry to the following mailboxes: 
For Russell Investments Funds and ETFs please contact Funds_DDOReporting@russellinvestments.com  
For Super and retirement products please contact  Super_DDOReporting@russellinvestments.com  

For additional information regarding your specific DDO obligations, we suggest that you contact your licensee, compliance consultant, legal adviser or other relevant industry body for more information.