Target Market Determination SACCS

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 Small 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

Product

The products and associated product attributes to which this TMD relates are:

  1. Small loans from $200 to $2000, repayable over 4 weeks to 26 weeks (Small Amount Credit Contract) as defined in the National Consumer Credit Protection Act(2009).

Key attributes of our products:

  • Fixed Term loan – 4 weeks to 26 weeks
  • Fixed Fee – 20% establishment fee and 4% fixed monthly fee
  • Regular fixed repayment amounts repayable weekly, fortnightly or monthly
  • A personal loan only
  • No security required
  • Access to Hardship policy and customer service
  • Easy to understand and transparent contract
  • Straight forward and concise application process

Target Market

The target market to which this TMD relates are consumers who:

  • Are looking for a regulated loan of an amount between $200 and $2000
  • Require a loan term between 2 weeks to 26 weeks
  • 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

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
  • Have repayments on all SACC loans in excess of 10% of net income.

Intended Use of Product

The product may be used for but not limited to:

  • Cover a short term cash shortfall
  • Unexpected bills for example fridge repair
  • One off expenses eg. Car registration
  • Purchase of white goods

Assessment

Review as to whether key attributes meet the target markets needs :

  • Loan terms remain fixed and short 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
  • Consumers who do not have substantial assets to secure loans can still access small, short term finance
  • 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

Product suitability

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

  1. 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
  1. 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
  1. All our products are distributed in compliance with our responsible lending obligations

Review

  1. 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
  1. 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