The Australian Securities & Investments Commission (ASIC) has commenced court proceedings against Australian Unity Funds Management Limited, alleging it failed to take reasonable steps to ensure retail investors in the Select Income Fund were within the product’s defined target market under the design and distribution obligations. Australian Unity, as responsible entity of the fund, made three Target Market Determinations between 5 October 2021 and 5 October 2023. ASIC alleges that although prospective “non-advised” investors were asked to complete a questionnaire, responses were not reviewed until August 2023 and were not used to screen investors until 6 October 2023, despite interests being issued throughout the period. The regulator argues that issuing a questionnaire alone does not meet the obligation to actively assess whether investor responses are consistent with the target market before issuing product interests.