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

QuietGrowth enters into a Client Agreement of MDA 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 of the MDA service, as if the FSG were a Product Disclosure Statement (PDS) for such a managed investment product. So, in summary, QuietGrowth does not have to prepare a PDS, because we have prepared the FSG and MDA contract.