Two ideas this week. One: should you give TMDs to consumers as part of your ‘reasonable steps’?
Two: Data standards – should they exist?
Short answers – No and Yes! Read on for more…
TMDs – who are they good for?
Distributors, that’s who. I was a bit perturbed to hear that some businesses are planning to use give TMDs to consumers as a part of ‘reasonable steps’. While TMDs should be written in plain language, they are for distributors, not consumers.
In fact, to make sure I wasn’t getting the wrong end of the stick, I asked ASIC this very question in a meeting, and the answer was clear – TMDs are for issuers to communicate with distributors.
The fact that they are required to be publicly available is neither here not there.
Rant over. Feel free to reply and tell me I’m completely wrong!
Data standards — your input is required!
When I was Head of Product for Coin (a LONG time ago!), we worked with Xplan to come up with data standards for use across the industry. Our combined efforts, while well-intentioned, were not successful.
Cut to 2021. Should we have attempt data standards again? My initial response was ‘you’ve got to be kidding!’ but on further reflection, I did a complete 180 and am now the co-chair of the FSC DDO Information Standards working group.
What changed? Well, I like to refer to DDO as ‘marketplace legislation’. It’s now legislated that information has to pass between issuers and distributors in order to support product governance that will ultimately deliver better outcomes to consumers. Given these requirements, the time is finally right to build data standards for everyone to use. This will make life easier on all sides, and (hopefully) reduce both costs and time to market for new solutions.
So, it’s time for your input/feedback. You can review the word version of the new standards here, and have a look at the github version here (note that the github version is a bit behind the word version, but will be updated shortly). The consultation period for both runs from now until Friday May 8, so please share these with your IT colleagues and get their input/comments. Please email your comments to Chaneg Torres at the FSC.
If there’s a burning DDO question that no-one seems to have a good answer to, or you just need to understand how Wattletree works in more detail, please get in touch. I invite you to shoot through your Q’s using the below form or alternatively you can call me on 0417 970 818. There’s no such thing as a silly question*
*OK, we all know that’s rubbish but you know what I mean!