Target Market Determination

Prepared by MyPayNow Pty Ltd (ACN 635 410 909) (MyPayNow) for the purposes of the Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (Cth)
Effective Date: 3rd March 2025

1. About this document

The purpose of this Target Market Determination (TMD) is to set out:

• the customers at whom the MyPayNow product (the Product) is targeted (the Target Market);
• the distribution channels and conditions for the Product; and
• the circumstances in which this TMD will be reviewed.

This TMD is not intended to provide a full summary of the Product's terms and does contain legal or financial advice. When making a decision about the Product, customers should refer to the applicable terms.

2. Target Market

1. Included class of customers
   
   The Product is designed for customers who:
   
   
   • require short term access to funds to assist in paying expenses and managing their cash flow;
   • want access to funds via a straightforward online process;
   • want access to funds quickly and "on-demand" once approved;
   • are employed;
   • are not experiencing financial hardship and can afford the repayments on the Product without hardship; and
   • are comfortable using online platforms to manage their finances and for customer service support.


2. Eligibility criteria
   
   To be an approved MyPayNow customer, customers must satisfy certain eligibility criteria, including that customers must:
   
   
   • be an Australian resident;
   • be 18 years or older;
   • have a valid form of Australian-issued identification such as a current drivers' licence, passport or Medicare card;
   • be employed;
   • receive net wages of at least $450 per week;
   • receive those wages into an eligible Australian bank account (some digital (app only) banks such as Up Bank are not supported); and
   • satisfy MyPayNow's credit assessment criteria, which is designed to identify factors including income and spending patterns, account history and repayment history, to assess affordability and suitability.


3. Excluded class of customers
   
   The Product is not designed for customers who:
   
   
   • receive income solely from Centrelink;
   • require access to a long-term credit facility;
   • require medium to large amounts of credit (that is, credit exceeding 25% of their nett wage or $2,000);
   • require a product with extended repayment times (for example, beyond two months); or
   • are experiencing financial hardship.

3. Key Product attributes and how they meet the Target Market

The table below outlines the key attributes of the Product and how those attributes are consistent with the objectives, needs and financial situation of the customers in the Target Market

MyPayNow has assessed that, the key attributes of the Product are likely to be consistent with the objectives, needs and financial situation of customers in the Target Market.

4. Distribution conditions and channels

The Product is only distributed online via MyPayNow's mobile and web-based application. No loan application, assessment or contracting and, therefore, distribution of the Product takes place through any third-party.

MyPayNow's online channels provide customers with access to information about the Product in an easy to navigate format, including a detailed and extensive FAQ page which provides straightforward explanations of the key attributes of the Product.

All customers need to satisfy MyPayNow's credit assessment criteria which assesses the suitability and affordability of the Product for the customer, and is designed to identify and exclude customers in the excluded class of customers.

Marketing and advertising for the Product is conducted primarily via partnerships, sponsorships, third party referrers and on social media platforms. MyPayNow also advertises on various platforms including, online, television, billboard and radio.

MyPayNow also undertakes market research to assess the reach and effectiveness of its marketing strategy.

MyPayNow's view is that the conditions outlined above are appropriate and make it likely that the Product will be distributed to customers in the Target Market.

5. Review of the TMD

1. Periodic reviews
   
   MyPayNow will review the TMD periodically to ensure it remains appropriate.
   
   

   Periodic reviews of the TMD	Timing
   Initial Review	No later than 12 months from the Effective Date
   Subsequent ongoing reviews	No later than 12 months from the date of the previous review



2. Review Triggers
   
   MyPayNow will review the TMD earlier if any of the below review triggers occur, or any other event or circumstance occurs that reasonably suggests that this TMD is no longer appropriate. Any such review will be undertaken within 10 business days of becoming aware of the relevant event or circumstance.
   
   

   Customer outcomes	Unexpected trends in customer outcomes which are significantly inconsistent with the intended Product performance, including a significant increase in default rates.
   Complaints	This includes: a significant increase beyond expected levels in complaints or disputes, or a significant change in the nature of complaints or disputes relating to the product; unexpected trends or common themes emerging in customer feedback or complaints.
   Product changes	Material changes to the key attributes of the Product, including: changes to pricing, including to the fixed credit charge or interest rate or the introduction of new fees; material changes to the terms and conditions of advance contracts; the introduction of credit reporting or checking.
   Distribution changes	Material changes to the distribution channels or conditions, including material changes to MyPayNow's credit assessment criteria.
   Legal or regulatory	A change in law or its application, a change in relevant industry code, a court decision, or ASIC or other regulatory guidance or action that materially affects the Product. This may include a change in the law which requires MyPayNow to change or remove a key product attribute or a product intervention order being made by ASIC in respect of the Product.
   Significant dealings	Significant dealings in the Product which are not consistent with the TMD, including significant dealings of the Product to customers who are outside of the Target Market.