Target Market Determination
Issuer: CarWarranty.com Pty Ltd Trading As Money Direct Finance
Issuer ABN: 25 131 087 842
Issuer Australian Credit Licence: 396613
Product: Secured Personal Loan (“the Product”)
Date TMD approved: 05 October 2021
TMD Version: [2]
TMD Status: Current
Purpose of this Document
The purpose of this Target Market Determination (“TMD”) is to comply with the Design and Distribution Obligations incorporated under Chapter 7 of the Corporations Act 2001 (“the Act”) by the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.
The TMD aims to provide consumers and distributors with information about the class of consumers that comprises the target market for the Product, taking into account their objectives, financial situation and needs. It also specifies any Product distribution conditions and restrictions and deals with reviews of the TMD as well as distributor arrangements.
Legal Disclaimer
This document is not a credit disclosure document and does not include all relevant terms and conditions associated with this Product. It does not take into account any person’s individual objectives, financial situation or needs. Individuals interested in making use of this product should carefully read the Issuer’s Credit Guide and any other disclosure documents before making a decision whether to use this Product.
Description of Target Market
This section is required under section 994B(5)(b) of the Act.
Target Market Summary
This Product is likely to be appropriate for a consumer who is seeking an amount of credit from $5000 to $100,000 repayable at a fixed rate to purchase a motor vehicle, watercraft, or other approved personal property for the primary purpose of personal use.
The target market has been established by assessing the Product (including its key attributes) and the consumer objectives, financial situation and needs for which the Product is likely to be appropriate. The class of consumers who fall within the target market for the Product is described below, based on the objectives, financial situation and needs of the consumer and the key attributes of the Product.
Description of Consumer Objectives, Financial situation and Needs
This Product has been designed to suit a wide target market of consumers who require access to funds for the purchase of a vehicle for predominantly personal use and is suitable for persons who:
· Require an amount of credit from 5,000 to $100,000 over a period between 2-7 years for a suitable purpose.
· Will have the financial capacity to pay fees, interest and repayments of principal as and when such amounts become due and payable.
· Want flexibility to make additional payments and / or increased payments without penalty.
· Meet our credit assessment and other eligibility criteria.
Excluded Classes of Consumers
This Product is unsuitable for persons:
· Who do not qualify under the responsible lending requirements imposed by the National Consumer Credit Protection Act 2009 (“National Credit Act”), will be unable to comply with their financial obligations under the Product terms, or could only comply with substantial hardship.
· For whom the Product will not meet their requirements or needs.
· For consumers who are knocked out on application based on a determination the consumer has not met the eligibility requirements for the product.
Description of Product and Key Attributes
The key attributes of this Product are:
• 2 - 7 year term
• $5,000 - $50,000 credit
• Fixed Interest Rate
• Monthly Account Fees
• Application Fees
• Risk Fees
• The credit is secured against the item purchased
Product and Target Market Consistency
The Product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market based on the following:
· The assessment that the Product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market.
· An analysis of the attributes and characteristics of the product and establishing that they are consistent with the likely requirements of consumers in the target market.
Distribution Conditions and Restrictions
This section is required under s994B(5)(c).
Distribution Methods
This product is distributed through the following channels:
· Directly to consumers online
· Through approved referral / Introducer partners
· Credit Representatives
Distribution Conditions
When Distributed by a third party:
· Applications must be submitted by an appropriately accredited introducer.
When Distributed by Money Direct Finance:
· Only appropriately authorised Money Direct Finance staff my distribute this product.
Factors Considered
In assessing the appropriateness of the distribution methods, conditions and restrictions, the Issuer has taken into account the following factors:
· The comparatively wide target market for the Product.
· The Issuer’s ability to restrict distribution by providing sufficient lending guidelines and
eligibility requirements.
· The Issuer’s ability to manage the distribution channels.
· The capability of existing distribution methods to reach the intended target market, based on
past outcomes.
Reviewing the TMD
The Issuer will review this TMD as follows:
Review Triggers
This part is required under section 994B(5)(d) of the Act.
If events or circumstances occur that would reasonably suggest that the TMD is no longer appropriate, the Issuer will review the TMD. This may include:
· An event or circumstance that would materially change a factor taken into account in making the target market determination for the Product.
· A material change to the design or distribution of the Product.
· A significant dealing in the Product that is not consistent with the product’s TMD.
· The nature and extent of any feedback received from distributors or users of the product .
Mandatory Review Periods
This part is required under section 994B(5)(e) and (f) of the Act.
Initial Review: This TMD will be reviewed within 12 months of the TMD approved date.
Periodic Reviews: This TMD will be reviewed at least every 2 years from the initial review date.
Distributors: Reporting & Required Information
This part is required under s994B(5)(g) & (h).
Complaints
Distributors are required to report and detail in writing all complaints in relation to the Product covered by this TMD to the Issuer every 12 months.
Significant Dealings
Distributors are required to report any significant dealing in the Product that is not consistent with this TMD, within 10 business days.
Appropriateness of the TMD
This section is required under s994B(5)(c) and s994B(8)(a) &(b).
The Issuer has reviewed the Product and its key attributes by considering its purpose, past outcomes and likely future outcomes, and has reasonably concluded that the Product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market as described above, when offered to the consumer in accordance with the distribution conditions listed above. The comparatively wide target market of the Issuer has been a factor in assessing why the distribution conditions and restrictions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed.