Target Market Determination
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Consumer Credit Loans
This Target Market Determination (TMD) has been prepared in accordance with the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 (Cth) and associated Regulations. TMDs are designed to assist issuers to ensure that the financial products they issue are likely to be consistent with the likely objective, financial situation and needs of the consumers for whom they are intended (the target market) and to assist distributors to ensure that financial products are distributed to the target market.
This TMD is general in nature and should not be construed as financial advice. Consumers should obtain independent advice prior to acquiring the product to ensure that it is appropriate for their objectives, financial situation and needs.
Product
Consumer Credit Loans (between $300 and $5000).
Product Issuer
This product is issued by Simple Finance Group Pty Ltd, Australian Credit Licence No. 509422
Date of TMD
20 October 2023
Target Market Determination
| Description of target market, including likely objectives, financial situations and needs | This product has been assessed as meeting the likely objectives, financial situation and needs of consumers who:
· Meet the company’s eligibility criteria (including but not limited to): · Are over the age of 18 years of age · Are an Australian citizen or permanent resident · Are currently employed and receive a weekly income greater than $450. · Have the ability to repay the loan over a term no greater than 12 months if the loan is between $300 and $2000 and no greater than 24 months if the loan is between $2001 and $5000.. · Can complete the application form online.
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| Description of product including key attributes | This product’s key attributes include the following:
· Loan Advance between to $300 and $5000 subject to lending criteria · Loan repayments are up to a term no greater than 12 months if the loan is between $300 and $2000 and no greater than 24 months if the loan is between $2001 and $5000. · Fees and charges including (a) Establishment Fees, (b) Monthly fees; and (c) Late fees · Product features: · Online application process · Customer portal · Customer support including phone, email and chat capabilities · Electronic contract distribution and signature capability
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| Class of customers for whom this product is not suitable | This product may not be suitable for consumers who:
· Do not meet our eligibility criteria; or · Do not have the ability to repay the loan in full in accordance with their repayment schedule · Are not gainfully employed or do not believe that they will be employed at any time during the loan term.
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| Explanation of why the product is likely to be consistent with the likely objectives, financial situation and needs of consumer in the target market | · The product allows consumers to borrow monies for a term up to 12 months if the loan is between $300 and $2000 and up to 24 months if the loan is between $2001 and $5000..
for the purpose of covering expenses or making purchases. |
Distribution Conditions
This product can be distributed through the distributors set out below. All distribution channels require an application for the loan to be submitted to Simple Finance via its website or the Simple Finance sales team.
- Direct – Simple Finance’s website and sales team
Simple Finance staff are required to undertake training prior to assisting applicants with loans and must follow all documents procedures. Simple Finance will ask screening questions as part of the application to ensure that a prospective borrower is within the target market set out above.
Simple Finance considers this is an appropriate distribution channel because the nature of the target market and the requirement of all sales staff to have the necessary training, skills and knowledge to assess whether the consumer is within the target market.
- Authorised Representatives
Authorised Representatives who are appointed by Simple Finance can distribute this product. Simple Finance will only enter into agreements with authorised representatives who it considers are reputable and who have the necessary education and experience that Simple Finance requires. Simple Finance considers this is an appropriate distribution channel due to their industry knowledge and the nature of the target market.
Review Triggers
| Review Triggers | The following events are review triggers that would reasonably suggest that the TMD is no longer appropriate:
· A significant dealing of the product to consumers outside the target market occurs · A significant number of complaints are received from consumers in relation to the product · There is a material change to the product or the terms and conditions. · There is a material number of: · Hardship applications · Overdue loans · Defaults · There are significant changes to Australian credit laws that affect the product. |
Review Period
| Review Period | Last review date: 20 October 2023
Period reviews: Every 12 months after the initial review and each subsequent review.
Trigger reviews: Review to be completed within 10 business days of the identification of a trigger event. |
Review Trigger Reporting Requirements
Staff and distributors must advise Simple Finance if they become aware of any of the following matters within the corresponding timeframe.
| Type of Information | What is reported | When it is reported |
| Product complaints | Information relating to complaints received about the product or the distribution of the product, including:
· Number of complaints · Name and contact details of the complainant · Substance of the complaint. |
As soon as practicable and in any event within 10 business days of receipt of the complaint |
| Feedback | Any feedback received about the product or the Distribution Conditions for the product | Every 3 months |
| Significant dealings | Date or date range of any significant dealing of the product outside the Target Market | As soon as practicable and in any event within 10 business days after becoming aware of the significant dealing |