Target market Determination

What is a target market determination?

This is a document that describes the type of customer for which the product is designed (target market), and conditions and circumstances for how the product can be distributed and when it needs to be reviewed.

Why do we need to have target market determinations?

Casheroo Investments Pty Ltd (Casheroo) is required to have Target Market Determinations under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019. This Act sets out the obligations to ensure a customer-centric approach to designing, marketing and distributing financial products to the target market.

SECTION 1 – SMALL AMOUNT CREDIT CONTRACTS (SACCs) TARGET MARKET DETERMINATION

1 About this document

This target market determination (TMD) seeks to offer consumers, distributors and staff with an understanding of the class of consumers for which this credit product has been designed, having regard to the objectives, financial situation and needs of the target Market.

The TMD will also describe how the product is distributed, when this document will be reviewed and what information is required to be provided to help maintain the accuracy of this document.

The product is issued by Casheroo. More information about this product is contained on Casheroo’s website: www.casheroofinance.com.au.

Consumers should consider whether the product is appropriate for them before making any decision about whether to apply for or enter into the product.

This document is not a product disclosure statement and is not to be treated as a full summary of the product’s terms and conditions. It has been prepared without taking into account any person’s particular objectives, financial situation or needs and is not intended to provide financial advice. Consumers should consider the product’s full terms and conditions when making a decision about this product.

2 Who this product is designed for

Casheroo’s SACCs has been designed for customers who:

• require a loan for an amount between $400 and $2,000 (or where the initial request is for a higher amount, are willing to accept a loan between those amounts) for an eligible purpose pursuant to our credit policy;
• are seeking a loan that is repayable over a fixed term of between two (2) to four (4) months, with the scheduled term to be agreed in the credit contract;
• do not want a revolving or continuing line of credit or a long-term credit contract that is repayable over a number of years; are currently working and residing in Australia;
• are currently working and residing in Australia;
• require the loan proceeds to be promptly disbursed to their nominated bank account;
• are willing to apply online and provide Casheroo with access to their bank transaction and credit history in order to help us assess their loan application.

3 Who this product is not suitable for

This product is not suitable for customers who:

• who is not of legal capacity;
• require a loan for an amount less than $400 or more than $2,000;
• are seeking an ongoing credit limit that may be drawn down as required from time to time;
• are unlikely to meet their payment obligations under the loan either at all or only with substantial hardship;
• are unemployed or receive more than 50% of their income from government benefits;
• require a longer term loan that can be repaid over more than four (4) months;
• wish to allocate more than 10% of their net income towards repayments for SACCs;
• are unable to access the internet;
• are under 18 years of age.

4 Distribution conditions

An application for Casheroo’s SACCs can only be made via the Casheroo’s website, with support provided by Casheroo’s employees where required. Casheroo’s employees can only provide assistance in relation to an application for a Casheroo’s SACCs if they have received adequate training. They must also follow Casheroo’s applicable policies and Processes.

The online application assessment process includes a number of questions that help to determine if the applicant is within the target market for this product. The information provided by the applicant during the application process will be used to determine if the customer falls within the target market, whether we will offer to provide a loan to the customer and, if so, for what range in amount and loan term. The customer should always answer these questions accurately and check with Casheroo if they are not sure what a question means.

Additionally, the product may be promoted to the target market via comparison websites. These third-party websites provide information about the product on their website and provide consumers with an opportunity to make an application through an electronic link. Any such applications must be completed and processed via our online application process, which contains the questions set out above used to determine if the applicant is within the target market for this product, whether we will offer to provide a loan to the customer and, if so, for what range in amount and loan term.

These conditions make it likely that Casheroo’s SACCs will only be offered to customers within the target market for this product because:

• any comparison websites are vetted and authorised by Casheroo;
• Casheroo’s employees have knowledge of the product terms and conditions and the product TMD;
• Casheroo’s processes are designed to identify instances where a customer falls outside the target market;
• Casheroo has the sole determination of whether a customer acquiring a product meets the eligibility criteria, assessed according to the customer’s requirements and objectives.

5 Reviewing this document

Casheroo collects information and prepares reports regarding loan volumes, average loan amounts, default rates, complaints and any occasions, where this product has been provided contrary to the TMD on an at least annual basis to help improve our products and services.

We will review this TMD if:

• there is a material change to the design or distribution of the product, including the terms and conditions applicable to the product or other related documentation, or on there being a relevant amendment to the National Consumer Credit Protection Act or any associated law which has the effect of altering the rules relating to the provision of SACCs;
• we amend or introduce other ways in which this product can be provided or distributed;
• the number of funded complaints received from customers as a percentage of total funded loans is greater than 5% in any given calendar quarter;
• in respect of the total funded loans in any given calendar quarter, the total number of hardship applications received from those funded customers exceeds 5%;
• the total outstanding balance of payments more than 14 days overdue as a percentage of total amount originated is greater than 8% in any given calendar quarter;
• there is an external event, such as adverse media coverage or regulatory attention;
• the business performance and value provided by the product indicates that the TMD is no longer appropriate, having regard to appropriate data such as customer demand for the product, loan volumes, application approval rates, customer default or loss rates and the nature and number of customer complaints;
• we identify that there has been a significant dealing in the product that is not consistent with the TMD, by detecting that more than 5% of the consumers receiving our product in any given calendar quarter are not within our target market based on specific complaint information; and
• if any external source such as ASIC, AFCA, or community-based consumer organisations communicate to us that they have identified a systemic issue, or if the number of complaints referred to AFCA or by community-based organisations is greater than 15 in any given calendar quarter.

Our review shall occur within 10 business days, when any of the above events occurring.

In any event, a review of this TMD will be completed no later than 6 months from the publication date of this TMD and subsequently at 12 months interval.

6 Distribution Information Reporting Requirements

In the event that distributors (other than Casheroo) engage in retail product distribution, the following information must be provided to Casheroo by distributors who engage in that retail production distribution in relation to this product:

SECTION 2 – MEDIUM AMOUNT CREDIT CONTRACTS (MACCs) TARGET MARKET DETERMINATIOn

7 About this document

This TMD seeks to offer consumers, distributors and staff with an understanding of the class of consumers for which this credit product has been designed, having regard to the objectives, financial situation and needs of the target market.

The TMD will also describe how the product is distributed, when this document will be reviewed and what information is required to be provided to help maintain the accuracy of this document.

The product is issued by Casheroo. More information about this product is contained on Casheroo’s website: www.casheroofinance.com.au.

Consumers should consider whether the product is appropriate for them before making any decision about whether to apply for or enter into the product.

This document is not a product disclosure statement and is not to be treated as a full summary of the product’s terms and conditions. It has been prepared without taking into account any person’s particular objectives, financial situation or needs and is not intended to provide financial advice. Consumers should consider the product’s full terms and conditions when making a decision about this product.

8 Who this product is designed for

Casheroo’s MACCs has been designed for customers who:

• require a loan for an amount between $2,001 and $5,000 (or where the initial request is for a higher amount, are willing to accept a loan between those amounts) for an eligible purpose pursuant to our credit policy;
• are seeking a loan that is repayable over a fixed term of between 16 days and 2 years, with the scheduled term to be agreed in the credit contract;
• do not want a revolving or continuing line of credit or a long-term credit contract that is repayable over 23 months;
• are currently working and residing in Australia;
• require the loan proceeds to be promptly disbursed to their nominated bank account;
• are willing to apply online and provide Casheroo with access to their bank transaction and credit history in order to help us assess their loan application.

9 Who this product is not suitable for

This product is not suitable for customers who:

• are not of legal capacity;
• require a loan for an amount less than $2,001 or more than $5,000;
• are seeking an ongoing credit limit that may be drawn down as required from time to time;
• are unlikely to be able to meet their payment obligations under the loan either at all or only with substantial hardship;
• are unemployed or receive more than 50% of their income from government benefits;
• require a longer-term loan that can be repaid over more than 23 months;
• are unable to access the internet;
• are under 18 years of age

10 Distribution conditions

An application for Casheroo’s MACCs can only be made via the Casheroo’s website, with support provided by Casheroo’s employees where required. Casheroo’s employees can only provide assistance in relation to an application for a Casheroo’s MACCs if they have received adequate training. They must also follow Casheroo’s applicable policies and processes.

The online application assessment process includes a number of questions that help to determine if the applicant is within the target market for this product. The information provided by the applicant during the application process will be used to determine if the customer falls within the target market, whether we will offer to provide a loan to the customer and, if so, for what range in amount and loan term. The customer should always answer these questions accurately and check with Casheroo if they are not sure what a question means.

Additionally, the product may be promoted to the target market via comparison websites. These third-party websites provide information about the product on their website and provide consumers with an opportunity to make an application through an electronic link.

Any such applications must be completed and processed via our online application process, which contains the questions set out above used to determine if the applicant is within the target market for this product, whether we will offer to provide a loan to the customer and, if so, for what range in amount and loan term.

These conditions make it likely that Casheroo’s MACCs will only be offered to customers within the target market for this product because:

• any comparison websites are vetted and authorised by Cashero
• Casheroo’s employees have knowledge of the product terms and conditions and the product TMD;
• Casheroo’s processes are designed to identify instances where a customer falls outside the target market;
• Casheroo has the sole determination of whether a customer acquiring a product meets the eligibility criteria, assessed according to the customer’s requirements and objectives.

11 Reviewing this document

Casheroo collects information and prepares reports regarding loan volumes, average loan amounts, default rates, complaints and any occasions, where this product has been provided contrary to the TMD on an at least annual basis to help improve our products and services.

We will review this TMD if:

• there is a material change to the design or distribution of the product, including the terms and conditions applicable to the product or other related documentation, or on there being a relevant amendment to the National Consumer Credit Protection Act or any associated law which has the effect of altering the rules relating to the provision of MACCs;
• we amend or introduce other ways in which this product can be provided or distributed;
• the number of funded complaints received from customers as a percentage of total funded loans is greater than 5% in any given calendar quarter;
• in respect of the total funded loans in any given calendar quarter, the total number of hardship applications received from those funded customers exceeds 5%;
• the total outstanding balance of payments more than 14 days overdue as a percentage of total amount originated is greater than 8% in any given calendar quarter;
• there is an external event, such as adverse media coverage or regulatory attention;
• the business performance and value provided by the product indicates that the TMD is no longer appropriate, having regard to appropriate data such as customer demand for the product, loan volumes, application approval rates, customer default or loss rates and the nature and number of customer complaints;
• we identify that there has been a significant dealing in the product that is not consistent with the TMD, by detecting that more than 5% of the consumers receiving our product in any given calendar quarter are not within our target market based on specific complaint information; and
• if any external source such as ASIC, AFCA, or community-based consumer organisations communicate to us that they have identified a systemic issue, or if the number of complaints referred to AFCA or by community based organisations is greater than 15 in any given calendar quarter.

Our review shall occur within 10 business days, when any of the above events occurring.

In any event, a review of this TMD will be completed no later than 6 months from the publication date of this TMD and subsequently at 12 months interval.

12 Distribution Information Reporting Requirements

In the event that distributors (other than Casheroo) engage in retail product distribution, the following information must be provided to Casheroo by distributors who engage in that retail production distribution in relation to this product:

Further enquiries

Should you have any questions about our credit products or this TMD, please contact us on (02) 7232 3128 or by email: info@casheroofinance.com.au.