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Why QuietGrowth does not have its own Product Disclosure Statement (PDS)?

QuietGrowth enters into a contract with the client to provide a Managed Discretionary Account (MDA) service to the client. QuietGrowth has prepared a Financial Services Guide (FSG) pertaining to this MDA service, as per regulations. The FSG is required to contain information about fees and costs in relation to the MDA service, as if the FSG were a Product Disclosure Statement (PDS) for such a managed investment product. So, in short, QuietGrowth does not have to prepare a Product Disclosure Statement (PDS).