Why Morningstar?
Morningstar has been engaged by a number of distributors to provide them with Target Market Determination (TMD) documents and associated data from issuers.
Many platforms, online brokers and financial planning software providers currently use Morningstar data feeds to power their applications and business processes. By extending our data feeds to cover TMD documents and data, we’re making it simple and cost effective for these providers to meet their DDO obligations, while helping to keep compliance costs low for the industry as a whole. This ultimately reduces the cost that investors will bear.
Like other data you provide to Morningstar, we are not charging product issuers for collection & dissemination of the data or documents.
Morningstar as a Distributor
Morningstar ASIC‘s Regulatory Guide 274 is broad reaching particularly in relation to its definition of “retail product distribution conduct” and as a research house providing financial product advice, Morningstar is captured under this definition. So, to meet our requirements under RG 274, we need to ensure that we have the TMDs for those funds that our manager research team rates, which under the law are required to have a TMD. Without the most up-to-date version of the TMD delivered to us, we will not be able to continue delivering research on these funds.
DDO Update
The FSC has made amendments to its suggested DDO document and associated data file. There are several changes that have been implemented which are all outline in the data file. While there is no official transition date Morningstar will be able to collect this data by the end of September 2023. The new file can be found here on the FSC website or below in our Additional Resources section. Since this is not a regulated template, Morningstar will continue to collect version 1 and non FSC data files consistent with how we do today.
What we need from you?
1. TMD Document for each share class you offer.
- This is the primary and most important document for distributor compliance – and they simply must receive this as soon as this document is available and effective. You can provide this in two ways:
Option 2: Send us the data file, with a publicly available hyperlink
2. The Data file, in extractable format for each share class, with differing data requirements within that file depending on the TMD production regime (FSC Issuer*, or not). Morningstar has created a simple real life excel file of the ‘FSC Data Standard’, with associated examples and instructions for delivery.
The data file format:
This data file is expected for each share class. All of your funds can be provided in a single file. The data file template is available under Additional Resources.
Group A: Every share class should fill in all Group A data points. These are all primarily the meta data of the fund document, hyperlinks and custom fields.
Group B: FSC Issuers should fill in all of this data. If you are not an FSC issuer, you should fill in any fields where your TMD overlaps.
A completed file should be sent as the TMD is being issued and delivered to us at fundopacquisition@morningstar.com.
Given the needs of our platform clients, please ensure that you send the latest TMD information through to us as soon as it is ready.
*FSC Issuer is an issuer that is either an FSC member following the FSC TMD development process, or an issuer who has licensed it.
Additional Information
It is vital to ensure delivery of these requirements to Morningstar are documented within your DDO TMD Production and release procedures to ensure distributors continue to be compliant.
TMD document and data file should be sent together.
Morningstar has always believed in making the industry collection standardised and distributed in an efficient and timely manner so please feel free to use the data collection template for broader industry distribution to other vendors.
For any questions on data collection, please reach out to your local data consultant or our support team at Morningstar Australasia Support helpdesk.au@morningstar.com.
Additional Resources
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