Target Market Determination MACCS
Target Market Determination
Prepared by Mifin Pty Ltd ABN 14 132 429 595 Australian Credit Licence Number 389029
This Target Market Determination (TMD) applies to Medium Amount Credit Contracts
Customers wishing to apply should refer to our Credit Guide and Terms and Conditions located on our website.
Effective Date: 26 January 2023
The products and associated product attributes to which this TMD relates are:
- Medium Term Loans $2001 to $5000 repayable over 6 to 24 months (Medium Amount Credit Contract) as defined in the National Consumer Credit Protection Act.
- loan amounts ranging from $2,100 to $5,000.
- loan terms ranging from 6 months to 24 months.
- a maximum annual interest rate of 48%.
- fees (establishment fee, missed payment fee).
- a fixed interest rate for the term of the loan.
- a repayment frequency of weekly, fortnightly or monthly.
- transparent, legible and easily understood contract, including financial table and loan terms.
- loans can be secured by a vehicle or unsecured.
- ready access to customer services and hardship policy
The target market to which this TMD relates are consumers who:
- Are looking for a regulated loan of an amount between $2001 and $5000
- Require a loan term between 6 months to 24 months
- Australian Residents
- Looking for a fixed repayment period
- Can afford to repay the loan
- Want the funds promptly, they cannot afford a drawn out application process
- Over 18 years old
- need credit to pay for infrequent, and sometimes unforeseeable, expenses that cannot be met from their regular, usual disposable income
- are willing to use a vehicle as security
The target market specifically does not include consumers who:
- Are under financial hardship
- Do not qualify under the National Consumer Credit Protection Act(2009).
- Cannot afford to repay the loan
- Are not of legal capacity
- Receive 50% or more of their income from Centrelink or other government benefit if the repayment on all their SACC loans will exceed 20% of their gross income
Intended Use of Product
The product may be used for but not limited to:
- Cover a medium term cash shortfall
- Unexpected bills for example fridge repair
- One off expenses eg. Car registration
- Purchase of white goods
- provide loans to pay for medium sized discretionary purchases
- provide loans to consolidate debts
Review as to whether key attributes meet the target markets needs :
- Loan terms remain fixed and medium term allowing consumers access to finance for unexpected and infrequent expenses
- Loan amounts equate to requirement for loan so consumers less likely to overborrow keeping repayments more affordable without hardship
- Application process is online, transparent, no obligation, and takes a few minutes
- Contracts are short, legible and easy to read
- Easy access to customer service during normal working hours
Historical data over last 12 months indicates that we are meeting our products attributes
- Low default rates
- Low repayment decline rates
- Low hardship application rates
- Low customer complaints
- Distribution channels will all present the product appropriately to consumers in that they:
- do not contain any misleading or deceptive conduct.
- do not consist of any unsolicited offers of credit.
- contain all disclosures required by law.
- are, if distributed through any third party, regularly vetted to ensure the above.
- are, if required by law, the subject of written agreements with us
- Voluntary Distribution Conditions
No loans to customers who:
- do not meet one or more of our requirements
- who are unable or unwilling to repay via direct debit
- do not meet the Government benefit 20% of income repayment rule
- All our products are distributed in compliance with our responsible lending obligations
- Review Period
- TMD will be reviewed within 12 months of previous TMD date
- As required when a trigger event occurs ( see below)
- A new condition is required
- If we decide an early review is necessary
- Review Triggers
A review will be triggered if:
- A significant change to terms and conditions of a product is made
- ASIC or AFCA inform us of any irregularities in the TMD
- There is a 20% increase in complaints to AFCA over a 3 month period
- Default percentage increases by 20% over a 3 month period
- Hardship applications increase by 20% over a 3 month period
When a review is required this will be done by the responsible manager who will report to the board within 2 weeks of a trigger event or annual review indicating whether
- a trigger event occurred
- action is required to ensure compliance with our Design and Distribution Obligation
- a product review or redesign is necessary
- a product must cease to be offered