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Design and Distribution Obligations

Writer's picture: Copia/TTCopia/TT
Aug 17, 20212 min read

Updated: Nov 15, 2021

The Target Market Determination for the TT Global Environmental Impact Fund is available here.


What are the Design and Distribution Obligations (DDO)?

ASIC Regulatory Guide 274 (RG 274) requires Issuers and Distributors of financial products to take steps to ensure that retail clients are offered products that are likely to be consistent with their likely objectives, financial situation and needs. The DDO regime is designed to provide a framework for all retail products (funds) to be more focused on client outcomes throughout the design and distribution process


What is a Target Market Determination (TMD)?

A TMD is a document which describes who a fund is appropriate for (target market), and any conditions around how a fund can be distributed to retail customers. It also describes the events or circumstances where a Responsible Entity, such as Copia Investment Partners may need to review the TMD for a fund.


The Responsible Entity will also ensure reasonable steps are taken to ensure on an ongoing basis that product distribution is consistent with the target market determination of funds.

For more information about RG 274 see here:


Reporting Requirements

Copia is required to take reasonable steps to retail product distribution conduct is consistent with a product’s TMD (s.994E(5)). This means that we need to make the TMDs available to financial planners and platforms and they, in fulfilling their best interests duty to their clients, only recommend products to clients who are deemed suitable for a product based on the TMD.


We would like financial planners and platforms to provide us with a separate, annual (or more frequent), assurance that:

  1. they have access to our current TMDs

  2. they have read and understood the TMDs

  3. in providing financial product advice to clients they have considered their suitability to invest in the products given the TMDs or

  4. have otherwise made the TMDs available to their clients.


Furthermore, financial planners and platforms are required to report complaints and dealings concerning Copia products. These reports should be in the format of the FSC Complaints Reporting Template and DDO Dealings Reporting Template ( https://www.fsc.org.au/resources/target-market-determination-templates). Completed reports are to be sent by email: clientservices@copiapartners.com.au



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DISCLAIMER  |  This information has been prepared by Copia Investment Partners Limited (AFSL 229316 , ABN 22 092 872 056) the issuer, distributor and responsible entity of the TT Global Environmental Impact Fund. This website provides information to help investors and their advisers assess the merits of investing in financial products. We strongly advise investors and their advisers to read information memoranda and product disclosure statements carefully and seek advice from qualified professionals where necessary. The information in this document does not constitute personal advice and does not take into account your personal objectives, financial situation or needs. It is therefore important that if you are considering investing in any financial products and services referred to in this document, you determine whether the relevant investment is suitable for your objectives, financial situation or needs. You should also consider seeking independent advice, particularly on taxation, retirement planning and investment risk tolerance from a suitably qualified professional before making an investment decision. Neither Copia Investment Partners Limited, nor any of our associates, guarantee or underwrite the success of any investments, the achievement of investment objectives, the payment of particular rates of return on investments or the repayment of capital. Copia Investment Partners Limited publishes information on the document that is, to the best of its knowledge, current at the time and Copia is not liable for any direct or indirect losses attributable to omissions from the document, information being out of date, inaccurate, incomplete or deficient in any other way. Investors and their advisers should make their own enquiries before making investment decisions. 

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The TT Global Environmental Impact Fund invests all or substantially all of its assets in TT Environmental Solutions Fund, a sub-fund of TT International Funds plc. TT International Asset Management Ltd (“TT International”) serves as investment manager to the Fund and is authorised and regulated in the United Kingdom by the Financial Conduct Authority. TT International is not affiliated with Copia Investment Partners. TT International does not take any responsibility for the accuracy or completeness of any information contained herein, or the performance of the TT Global Environmental Impact Fund offered by Copia Investment Partners. TT International disclaims any liability for any direct, indirect, consequential or other losses or damages, including loss of profits, incurred by you or by any third party that may arise from any reliance on these materials. TT International is not responsible for, nor involved in, the marketing, distribution or sales of shares or interests in the TT Global Environmental Impact Fund and is not responsible for compliance with any marketing or promotion laws, rules or regulations. No statement in this document is or should be construed as investment, legal, or tax advice given by TT International, nor is any statement an offer to sell, or a solicitation of an offer to buy, any security or other instrument, or an offer to arrange any transaction, or to enter into legal relations with TT International.  Past performance by any other funds or accounts advised by TT International, including the TT Environmental Solutions Fund, is not indicative of any future performance by the TT Global Environmental Impact Fund.

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