Target Market Determination Documentation
Document Hierarchy
What is the target market for our SACC/MACC product?
The target market for out SACC & MACC products are loan applicants who:
- Need amounts of between $500 and $5,000
- Need to pay for infrequent and sometimes unforeseeable expenses or purchases that cannot be met from their regular or usual disposable income
want quick access to the funds - Want the loan application and approval process to be easy, online, and seamless are not interested in obtaining long term loans
- Need the loan for personal and non-business purposes
- Can afford the repayments for the loan without hardship
- Want loan contract documents to be clear and easy to understand
- Want easy access to customer services to discuss payments, hardship and terms of the contract if required.
What are the key attributes of our SACC/MACC product?
The key attributes of our SACC product are:
- Loan amounts from $500 to $2000.
- Loan terms of 4 weeks to 12 weeks.
- Fixed credit charges – Establishment fee of 20% of the Amount Financed and Monthly fee of 4% of the Amount Financed.
- Transparent, legible and easily understood contract documents, including a financial table and standard loan terms.
- Ready access to customer services and hardship support.
- Fast on-line application and approval process.
- Loans are for personal and non-business purposes only.
The key attributes of our MACC (Medium Amount Credit Contracts) product are:
- Loan amounts from $2050 to $5000.
- Loan terms of 12 weeks to 26 weeks.
- Fixed credit charges – Establishment fee of $400 and Monthly fee of 4% of the Amount Financed.
- Transparent, legible and easily understood contract documents, including a financial table and standard loan terms.
- Ready access to customer services and hardship support.
- Fast on-line application and approval process.
- Loans are for personal and non-business purposes only.
How do the key attributes of our SACC product meet the needs, objectives and financial situations of our target market?
The key attributes of our SACC product meet the needs, objectives and financial situations of consumers in its target market because:
Our SACC product:
- Provides easy access short term finance for consumers for their infrequent and sometimes unforeseeable expenses and purchases.
- Loan amounts are aligned to the amounts requested by the target market consumers in their loan applications
- Loan terms match the consumers’ needs, requirements and objectives and financial situation.
*All our SACC loans are for personal non-business purposes. The application process is online and can be completed quickly. Our contract documents are short, legible and easy to understand. We provide ready access to online and telephone customer service.
Historical data shows that this product has:
- Low Default rates;
- Few hardship applications;
- Few customer complaints; and these are within an acceptable range and indicate that the product is suitable for the target market and is meeting consumer needs, objectives, requirements and financial situations.
What are our distribution channels and conditions for this product?
*All our Distribution channels present the product appropriately to consumers as follows:
Our website which contains:
- No misleading information;
- All relevant disclosures and warnings required by law;
- an easy to follow application process during which the consumer is given informed choices at every stage;
- If a customer has 3 loans within a 6 month period or applies for a loan less than 1 month after completion of their last loan with us, we will not lend to them within the next 3 months unless they affirm in writing:
- that the product is suitable for their situation;
- Is not being used as an informal line of credit; and
- Is being used only for infrequent and unforeseeable expenses and purchases outside the household.
- No loans are provided to any customer for the purpose of paying regular, ongoing ordinary household expenses such as utilities.
- We do not make any unsolicited offers of credit.
- All our products are distributed in compliance with our responsible lending obligations.
What are the trigger review events for us to review this Target Market Determination?
- We will review this TMD if the following occurs in relation to this product:
- The number of defaults which become bad debts in a 3 month period exceeds 5% of the Amounts Financed in our loan book by value.
- The number of complaints from approved SACC loan customers in a 3 month period increases by 10% over the previous quarter.
- The number of hardship applications lodged by customers in a 3 month period increases by 10% over the previous quarter.
- The average number of loans per customer per year exceeds 6.
- Our Responsible Managers will collect, assess and review all the above data every month. We will also respond to external sources such as:
- AFCA;
- ASIC;
- Community based consumer organisations;
and seriously consider their observations, complaints and comments.
- If any of the above Trigger Events occur, we review this TMD as if it was a Periodic Review described below.
When will we periodically review this Target Market Determination?
- We will conduct annual periodic reviews, whether or not a trigger event has occurred in the previous year. Our Responsible Managers will conduct the reviews of this TMD.
- The responsible manager will conduct the reviews of this TMD.
- The Responsible Managers will report to our board of directors within two weeks of conducting a review following occurrence of any trigger events. Such a review will detail:
- What factors may have caused these trigger events to occur, including external factors not related to the design and distribution of our product;
- Appropriate recommendation/s in respect of which of the follow actions we should take:
- No change if all of our DDOs as published above are being met;
- Redesign of the product (needs a redesign);
- Implementation of a new distribution condition/s (if required);
or - Withdrawal of the product from distribution (must cease to be offered).