Target Market Determination

Target Market Determination


The Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019(Cth) came into effect on 5 October 2021 (DDO Laws). The new Design and Distribution Obligations (DDO) require issuers to design products that are consistent with the likely objectives, financial situation and needs of the consumers for whom they are intended.

As part of these obligations product issuers are required to develop a Target Market Determination (TMD). Distributors (advisers) are required to distribute the product in accordance with the TMD. ASIC released Regulatory Guide 274 (RG 274) which sets out ASIC’s expectations for compliance, and general approach to administering the DDO Laws.

Midwinter has provided a solution for its users to be able to source TMD data from within AdviceOS.

We have made TMD data available on a number of our modules withing AdviceOS, including:

  1. Fundsbase
  2. Total Portfolio Analysis
  3. Omnium Insurance Comparator 

This will allow licensees, practices and users with the ability to collate and maintain TMD factsheets for every product they recommend (where available), and to manually extract any relevant information from the PDF documents to help determine whether a recommendation meets the TMD or not.


The Fundsbase module within AdviceOS allows a user to access the entire list of superannuation, pension and investment products available.

We have now included the added functionality of being able to access a TMD for any product across all three of these platforms.

To review the TMD for a particular product, you just need to complete the following steps:

  1. Navigate to Modelling > Fundsbase and select the specific environment you are looking for (ie superannuation, pension, investment)
  2. Select the relevant platform
  3. Navigate to the bottom of the screen

Here you will notice a new column has been created titled TMD. If the investment option has an APIR code, the icon below will be visible. Click on this icon and it will check to see if the relevant TMD is available.  If it is, it will open into a new tab of your browser for you to be able to review and download.  If not, a message saying “pdf not available” will be displayed.

You can see below screenshots of how to navigate AdviceOS within the Fundsbase module.

Example TMD

Total Portfolio Analysis

TMDs can also be accessed via the clients Total Portfolio Analysis, where you can review this information for all relevant products that the client currently holds. 

When you navigate to Modelling > Total Portfolio Analysis > Platforms and investments you will be presented with the clients current platforms and any products. If this page is blank of a platform is missing, you can add this via the + Add Platform button.

In order to view the TMD button, you will need to change the current view. Select the View dropdown and choose Mgt. reporting.

Similar to the Fundsbase functionality, if the underlying investment option has an APIR code, the download icon will be visible.  Click on this icon and it will check to see if the relevant TMD is available.  If it is, it will open into a new tab of your browser for you to be able to review and download.  

If not, a message saying “pdf not available” will be displayed:

Insurance Comparison (Omnium)

We have also provided the ability to download TMDs for insurance providers. These are available within the Insurance Comparison (Omnium) module.

Navigate to Modelling > Insurance Comparison (Omnium) > Product settings.

Once you have completed the relevant information for your client, you can search for the products and policies that may be suitable.

On the right of the policies are additional options as shown by the three vertical dots. Click on the policy you wish and the option to open TMD is available.

If you have any further questions, please reach out to Midwinter Support on 1300 882 938 or via email at 

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