09 Jan HW 5
We are pleased to respond to your request for comment on the Design & Distribution Obligations Draft Legislation. 1. Practical difficulties for Issuers regarding Target Market Determinations for investment products for which there are a wide range of uses and investor types (a) Difficulties in defining a Target Market (by Class of Investor) While we recognise that there may be some investment products suitable for a narrowly defined target market, there are also many investment products that have a very wide target market. Using the example of an investment product which offers exposure to Australian shares, there would be a very large number of reasons why an investor may legitimately acquire such a product, and a large variety of investor types. These may include: (i) investors wanting to hold a long term exposure to Australian shares; (ii) investors wanting to speculate on the short term outcomes of Australian shares; (iii) investors wanting to take exposures that combine well with various other asset...
