There are big changes coming for anyone who creates marketing material for financial products. The Design and Distribution Obligations (DDO) are set to come into effect on 5 October 2021.
The DDO changes are all about ensuring financial products are being targeted at the right people. Under the new legislation, issuers are required to make, review and keep records of target market determinations.
They will also now be required to notify ASIC of any ‘significant dealings’ in a product in relation to a retail client that are inconsistent with these determinations.
According to IntelligenceBank CEO and co-founder Tessa Court (pictured above), the DDO changes serve as a step towards creating a more transparent financial services sector in Australia.
“This is all a hangover from the Royal Commission, with regards to ensuring people are being offered products that they need and can use,” Court told B&T.
While there is a grace period to put system and processes in place, it is best practise for all in-market collateral and materials to be DDO compliant.
“A big challenge for a lot of our financial services clients currently is that they have literally thousands of product disclaimer statements, documents and even product marketing items like factsheets that now require target market determinations,” Court said.
Ensuring this marketing material is compliant with the new regulations is a “Herculean task”, according to Court.
However, IntelligenceBank is now providing its clients with the ability to stay in line with these obligations and ultimately reduce the costs related to compliance.
“We work with a lot of financial services companies and we help them ensure that the DDO obligations are part of the entire process,” Court said.
“It is really important that from the creative briefing perspective – when a piece of creative is even being briefed in – to be able to specify who the target market determination should be.”
“We also help some clients keep a register of all their product content, so they can easily audit and actually see all that content related to each target market. This means they can retroactively tag and store this content in the one place.”
Court noted that support is now also available for financial institutions to create compliant marketing materials moving forwards.
“The other way that we help is with Dynamic Creative Templates within IntelligenceBank,” she said.
“Not only can you create ads on the fly, but we can also automatically populate the target market that needs to go into the communication as well.
“It’s about making it easy on an ongoing basis, so that when people are tailoring content, creative compliance doesn’t slip through the cracks.”
Dashboard reports are used to give full visibility on the status of DDO materials that are in the approvals process or need to be reviewed.
Educating the market
While it is important marketers are educated and informed about these changes, Court said that without the proper systems in place, things can be missed.
“If you think about the average marketing department, you would have anywhere between 10 and 20 per cent turnover of people,” she said.
“So, everybody can be trained on what they need to do, but then if you don’t have the systems in place to automate this process, then it can be forgotten.
“By including DDO as part of the briefing process, part of the creative templating process, and also having a register of product-related content and what the target market determination should be, it ensures that things don’t get missed in the future.
Balancing compliance and creativity
Compliance measures such as the DDO changes bring with it clear concerns for marketers about how these regulations will impact creativity and the overall effectiveness of campaigns.
Court likened this dilemma to a yacht race.
“If you think about a yacht, you want it to go as fast as possible without capsizing,” she said.
“And that’s really what marketers want to do – they want to get to market as quickly as possible, but not fall over from a compliance perspective.”
Having an automated system like IntelligenceBank in place can help marketers achieve speed to market without compromising compliance, Court added.
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