Why version-specific PDS references matter
A PDS can change several times in a year. Fees, definitions, features, exclusions, any of these can move between versions. The version the adviser relied on at the date of the advice is the one that defines what the recommendation was based on. If the SOA references “the PDS” without a date, an auditor cannot tell what the adviser actually read.
A PDS reference without an effective date isn't a reference , it's a guess at which version your future self read.
What a clean PDS reference block looks like
A defensible reference block answers four questions in a single row per product:
- Product name, exactly as published
- Issuer name
- Document type (PDS, Additional Information Booklet, TMD)
- Effective date and a stable link to the source document
Some practices add a fifth column for the version identifier the issuer uses internally (issue number, document ID). When the issuer publishes those, capture them, they make later re-checking faster.
How FundFetch helps. The export drops a tab-delimited block that includes product, issuer, document type, effective date, and direct source URL, paste it straight into the SOA appendix or your file-note template.
The file note that sits next to the SOA
- The PDS & TMD versions you accessed, the date and time you accessed them, and a hash or filename of the saved PDF copy.
- A short note recording that the client falls within the TMD target market and why.
- The TMD distribution conditions and how each was satisfied (e.g. the client met the minimum balance, the eligibility questions were answered).
- Any conflict the client raised after the PDS was discussed (for the “know your client” record).
What to do on the annual review
- Pull the current PDS and TMD for every product the client holds.
- Compare effective dates against the SOA reference block.
- For each product whose PDS has updated, read the “Recent changes” section of the new PDS (most issuers include one) and note whether the change is material to the client.
- If a TMD has changed and the client's circumstances no longer match the new target market, that's a review trigger on your side, not just the issuer's.