CFS has 2 types of TMDs and these have different definitions of 'Dealings';
TMD Dealings for Super and Pension products generally occur when acquiring a new interest within a particular product such as FirstChoice Wholesale Personal Super. However, this excludes our 'MySuper' products such as FirstChoice Employer Superannuation & Commonwealth Essential Superannuation. These products are generally acquired via a 'default' employer arrangement as 'MySuper accounts' which aren't impacted by the new DDO legislation. 'TMD Dealings' may still occur for these products where a member switches from their default MySuper investment option(s), to another investment option within these products.
TMD Dealings for these TMDs occur when an interest is acquired within the investment scheme within a non-super account. This applies to both the initial interest, and any subsequent interests which occur as a result of additional deposits, regular investment plans or switches between investment options.
TMD Dealings are 'outside' the TMD if the customer doesn't meet some or all of the 'target market' defined in the TMD. When notifying CFS of dealings outside the TMD there is a list of 5 TMD clauses to choose from. These include: the 'Class of customer', 'Financial situation', 'Needs & objectives', 'Eligibility' or 'Distribution conditions'.
As part of providing personal financial advice you and your client may agree to 'deal' outside the relevant TMD. The provision of Personal Advice exempts you from any DDO conditions restricting this. You will be required to provide an attestation that personal financial advice was applied.