Advisory & Consulting

Design and Distribution Obligations

Customer-centric Product Design, Distribution and Marketing to Retail Clients

DDO Obligations - An Step-Change in Financial Services
The DDO regime is not a "thick in the box" process or an incremental internal compliance change program but rather a substantial, end-to-end lifecycle process that may require re-thinking of business models, third-party arrangements and firm culture. Implementing a robust product governance framework and embedded product monitoring capabilities will be crucial
DDO Framework

Implication of the New Regime

The recent Royal Commission into Financial Industry Misconduct has shown current process and controls within financial services as well as a flawed “consumer protection” disclosure framework can lead to product sales which are not in the best interest of customers and result in poor consumer outcomes


Given the government’s increased scrutiny on customer fairness and delivery of improved outcomes to customers, product creators and distributors will be required to establish consumer-centric frameworks that support robust product governance, target market offerings and deliver better value to a class of consumers


A Customer-Centric Framework


DDO Accountability Models

If your financial institution has been through accountability regimes like BEAR or the FAR legislation, you may be able to leverage current accountability methodologies. Nonetheless, if you have not been through any of these regimes, DDO demands a well-defined form of accountability structure in place. Below we provide a sample DDO accountability methodology model that can be adopted by your firm and may assist in breaking down each specific accountability required to deliver on DDO.

The RACI model clearly lays out roles and responsibilities for any activity or group of activities which will be relevant to the DDO implementation.

A RACI chart (RACI matrix) clarifies roles and responsibilities, making sure that nothing falls through the cracks.  RACI charts also prevent confusion by assigning clear ownership for tasks and decisions.A RACI template can easily accommodate larger DDO projects by inserting additional rows and columns. 



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FSC's Data Standard Definition Template for TMD's

Attributes and Elements of a Codified TMD for Specific Products as Defined by the FSC

(Under BSD 3-Clause License)

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Technology and DDO