Target Market Determination
Pay Later Loan
This document is the Target Market Determination (TMD) for the Real Flow Finance PayLater Loan. It is issued by Real Flow Finance (Product Designer) on behalf of the Issuer of the product.
A Target Market Determination (TMD) is a written document that:
- describes the class of customers that
- make up the target market for the Real Flow Finance PayLater Loan (Target Market);
- specifies any conditions and restrictions on the distribution of the product (Distribution Conditions); and
- sets out the events or circumstances where we are required to review the TMD (Review Triggers).
We are required to have a TMD by law. This TMD is not a recommendation to acquire a Real Flow Finance PayLater Loan nor does it replace our terms and conditions or other disclosure documents that we or one of our third party distributors (Distributors) may provide to you.
|Product Type||Bridging Loan|
|Issued By (Real Flow Finance, we, us, our)||Real Flow Finance Pty Ltd ACN 164 355 051 Credit Representative 525257 (on behalf on the ‘Issuer’, Venus Capital Pty Ltd ACN 169 312 510 Australian Credit Licensee 441879)|
|Date TMD approved||5 October 2021|
|Initial Review Period||One year after the date of this TMD|
|Subsequent Review Periods||Every third anniversary of the date of this TMD|
Target Market Description
|Product description and key attributes||
The Real Flow Finance PayLater Loan is a bridging loan designed for borrowers who wish to finance the marketing and advertising costs associated with the sale of a residential property, to pay for repairs or minor renovations or to pay for the expenses related to the styling of a residential property in preparation for sale.
Borrowers must be able to repay the Real Flow Finance PayLater Loan in full from the proceeds from the sale of the property
The key attributes of the Real Flow Finance PayLater Loan are:
· Loan Term – the PayLater Loan must be repaid on the earlier of:
o 180 days after the loan settlement date;
o The sale of the property; or
o The withdrawal of the property from active marketing
· Minimum Loan Amount – $1,000.00
· Maximum Loan Amount – $35,000.00 subject to the amount of equity in the Existing Property;
· Interest Rate –fixed for the term of the loan.
· Repayments – interest is capitalised over the Loan Term (therefore, repayments are not required during the Loan Term);
· Early Repayments – at any time without penalty;
· Security – caveat over the property being sold.
· Maximum Loan to Value Ratio (LVR) – 95%
Fees and charges also apply.
|Customers for whom the product is likely to be suitable (Target Market)||
Real Flow Finance considers that the Real Flow Finance PayLater Loan will suit borrowers who want a loan to finance the upfront costs associated with preparing and marketing a property for sale, but who want the flexibility of interest capitalisation so that they are not required to make repayments during the expected period of the marketing campaign.
Customers within the Target Market must be able to repay the PayLater Loan in full out of the proceeds of sale of the property.
Customers within the Target Market will:
· be 18 years or over; and
· be an Australian citizen or resident;
· expect to be able to sell the property reasonably quickly, and in any case within 180 days;
· can meet Real Flow Finance’s credit criteria;
· want to capitalise the interest for the term of the loan; and
· be willing to grant Real Flow Finance a caveat over the property.
The Real Flow Finance PayLater Loan is not appropriate for customers who:
· are under 18 years old;
· do not meet Real Flow Finance’s credit criteria;
· expect the sale (and settlement of the sale) of the property to take longer than 180 days
· would be unable to repay the loan in full upon the sale of the property; or
· have defined goals and objectives that are not met by this product.
Real Flow Finance considers 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 because:
- applicants will only be approved for the purposes set out above; and
- applications will only be approved if the customer meets Real Flow Finance’s credit assessment criteria.
|Conditions and restrictions on distribution of the product||
The Real Flow Finance PayLater Loan is subject to the following distribution conditions and restrictions:
The Real Flow Finance PayLater Loan may only be distributed:
· via an on-line application;
· by the customer calling Real Flow Finance directly;
· through a broker acting under an Australian Credit Licence; or
· as a result of a referral from one of our Referrers, acting in accordance with the ‘Referrer exemptions’ in Regulation 25(2) or 25(5) of the NCCP Regulations.
Real Flow Finance considers that its Distribution Conditions are appropriate and likely to result in the product being distributed to the Target Market for the following reasons.
- Legal relationship – Real Flow Finance has:
- a direct employment relationship with our staff taking calls or otherwise assisting customers who are interested in a Real Flow Finance PayLater Loan; and
- a written agreement with our third party Distributors.
- Supervision – Real Flow Finance
- closely monitors the performance of its staff; and
- undertakes periodic reviews in relation to the activities of our third party Distributors.
- Training –
- Staff and licensed third party brokers:
- are appropriately trained to discuss the features of the product with customers; and
- understand that applications will not be approved unless they satisfy Real Flow Finance’s credit assessment criteria; and
- Referrers are provided with clear instructions regarding the limitations on their activities.
|Circumstances which will result in the product being reviewed||
Real Flow Finance will review this TMD in the following circumstances.
· we receive a significant number of complaints in relation to the product
· we identify a material adverse customer experience in relation to product appropriateness
· there is a material change to the product’s key attributes or the manner of distribution
· there is a pattern of ‘significant dealings’ in the product which are inconsistent with the Target Market;
· ASIC orders that the distribution of the product cease, or ASIC or AFCA raise concerns about the design and distribution of the product; and
· any other event or circumstance that Real Flow Finance considers mean that it is appropriate for the TMD to be reviewed.
Review Trigger Reporting Requirements
Our staff and third party Distributors must advise Real Flow Finance if they become aware of any of the following matters within the timeframes specified.
|Product complaint data||
Information relating to complaints received about the product or the distribution of the product, including:
· number of complaints,
· the identifier of the distributor;
· the product name; and
· the exact details of the complaint.
|Immediately, but in any case, no later than next business day after becoming aware of the complaint.|
|Significant dealings||Any significant dealing of the product outside the Target Market||As soon as practicable but no later than 10 business days after becoming aware of the significant dealing.|
|Feedback||Any feedback received about the product or the Distribution Conditions for the product.||As soon as possible, but no later than within 20 business days of the receiving the feedback|
Real Flow Finance will keep records of the reasonable steps they have taken to ensure that this product is sold in a manner consistent with this TMD. Our third party Distributors must also keep records of all customers they refer to us.
Real Flow Finance will also keep complete and accurate records of
- all versions of the TMD for this product; and
- our decisions, and the reasons for those decisions about:
- the determination of the TMD for this product;
- the identification and tracking of review triggers;
- the setting of review periods, and
- all other the matters documented in this TMD.