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Target Market Determination (TMD)

A TMD is a public document that describes the class of consumers a financial product is designed for, ensuring products are distributed to appropriate customers under design and distribution obligations.

Detailed Explanation

Target Market Determinations (TMDs) are required under the design and distribution obligations (DDO) regime introduced in October 2021. Insurers must prepare a TMD for each insurance product that identifies the target market - describing the class of consumers for whom the product would be consistent with their likely objectives, financial situation, and needs. The TMD must specify distribution conditions (how the product can be sold), review triggers (circumstances requiring reassessment), and reporting requirements for distributors. TMDs help prevent mis-selling by ensuring products reach appropriate consumers. For example, a comprehensive car insurance TMD might specify it's designed for vehicle owners who can afford the premium and want extensive coverage, while excluding those seeking only third-party coverage. Distributors (including brokers, advisers, and comparison websites) must take reasonable steps to ensure products are distributed consistent with the TMD. TMDs are publicly available, typically on insurer websites, allowing consumers to assess product suitability. Breaching DDO obligations can result in significant penalties.

Common Misconceptions

  • A TMD does not prevent anyone from purchasing a product outside the target market - it guides distribution but doesn't prohibit sales
  • Being within a product's target market doesn't guarantee it's the best option for you - you should still compare products and consider personal circumstances
  • TMDs are not personalized assessments - they describe general classes of consumers, not individual suitability

Real-World Examples

  • A funeral insurance TMD specified the product was designed for consumers aged 18-79 seeking coverage under $15,000; ASIC found it was being sold to 90-year-olds and issued penalties

  • An income protection insurance TMD identified employed professionals as the target market, with specific exclusions for high-risk occupations not covered by the policy

  • A comprehensive car insurance TMD was updated after review data showed high cancellation rates among young drivers, indicating the product wasn't meeting that segment's needs

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