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Target Market Determination

Skypay Pty Ltd · ABN 52 691 707 696

STRAWBERRY LOANS PTY LTD REPRESENTED BY SKYPAY PTY LTD (AUTHORISED CREDIT REPRESENTATIVE.)

AUSTRALIAN CREDIT LICENCE 519253

AUTHORISED CREDIT REPRESENTATIVES NUMBER 578886

TARGET MARKET DETERMINATION (TMD)

Medium Amount Credit Contracts – Personal Loans

Prepared and published in acknowledgement of the requirements imposed on “issuer” companies involved in the provision of credit under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.

The product is a Medium Amount Credit Contract (as defined in Section 204 and prescribed in Sections 32A and 32B of the National Credit Code) – a consumer loan product regulated by the National Consumer Credit Protection Act 2009.

Key attributes of the product:

Who are the target consumer/s, target market?

Consumers who:

Consumers or classes of consumers that are excluded from the target market

Consumers who are:

Target consumers’ likely objectives, financial situation and needs

The consumer’s likely objectives, financial situation and needs include:

Consumer’s likely objectives

Consumers likely financial situation

Consumer’s likely needs

Seeking a loan of between $2,001 and $5,000 (plus establishment fee of $400 if applicable) to pay for education fees and other education related expenses. Other reasons for a loan may include car repairs, travel expenses, once off product purchase, holidays, weddings, renovations etc. Customer would be wanting to spread repayments over a relatively short term.

Why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market?

The product is a simple credit product, which is the foundation for the likely effect of the company’s distribution conditions.

Product features, such as loan amounts, fixed interest rates, short to medium loan terms, equal repayments and choice of payment frequency are likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market. Additionally, the service provided by Strawberry Loans, including easy online application, quick response and turnaround times, is also likely to meet the likely objectives, financial situation and needs of consumers in the target market.

The products have been the subject of robust testing under the Commonwealth credit regulatory regime, are fundamental to the Australian market place in that they do not have any unique features that would be unfamiliar to the consumers in the target markets.

Distribution method?

Skypay Pty Ltd as the Authorised Credit Representative, via internet and telephone contact with applicant consumers.

The distribution communications methodologies adopted, or that could be adopted, include websites, emails, Australia Post, social media and traditional advertising media such as print, radio and television from time to time.

In accordance with the National Consumer Credit Protection Act 2009, Strawberry Loans, has the final decision on loan approval and supervises both in-house product distribution and credit representatives’ efforts, with close attention to the Design and Distribution Obligations.

What conditions or restrictions are placed on distribution?

Conditions and/or restrictions include:

As with the outcome of reviews, the conditions or restrictions imposed are an attempt to eliminate, or at least minimise, the actual or potential degree of harm.

Why do those conditions mean the product is not likely to be distributed to consumers outside the target market?

These conditions are clearly communicated to all company representatives and distributors and are incorporated in employment and engagement agreements. They form part of the major terms and conditions of those agreements.

Strawberry Loans has regular reviews of company credit policy, procedures and processes.

What triggers make it (the product or TMD) no longer appropriate?

These include, but may not be limited to, the following events and circumstances:

How often we want to review the TMD

The first review will be scheduled to regular reviews will be every 12 months.

Where issues of concern in regard to inconsistency between the TMD and the credit product and/or target market arise, between these regular scheduled reviews, the companies’ policy is to undertake a review and action the review’s findings within 10 business days of the adverse information being brought to the attention of the company’s TMD Manager, and with implementation of all recommendations.

Where deemed appropriate and material, complaints, if any, will be brought to ASIC’s attention by way of a “Significant Dealing Notification”, within 10 days of any relevant review being completed.

What would trigger a review before the standard review?

How often do we want distributors to report complaints information to us?

Reporting from in-house representatives and third party distributors is scheduled monthly, but where numbers or type of complaint indicate a material significance, reporting will occur as soon as that significance emerges and is noted.

In-house management and staff who are not representatives will also be encouraged to report at any time, where deemed relevant.

In addition, the companies will welcome reports from other non-representatives and non-distributors at any time.

In what format and with what detail do we want them to report to us?

By email to the Responsible Manager in that Manager’s role as TMD Manager.

Details to be reported include:

Do we want them to report anything else to us?

Yes. In circumstances where there is no material level of complaint, or type of complaint, in their professional judgement a trend may be emerging, or the evolution of a more serious or material complaint could occur without attention to the causal issue at the time of the report.

What will we determine to be a significant dealing, i.e. where the product goes to consumers outside the target market or some other significant issue?

The companies will determine that there has been a significant dealing in the following circumstances (unless these are due to loan application fraud):