Target Market Determination for MyPayNow Advance Contract

This Target Market Determination has been prepared by MyPayNow Pty Ltd ACN 635 410 909 (Us, We, Our) in compliance with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs). It applies to our My Pay Now Advance product.

The Target Market for Our Product

The Target Market our product is consumers who:

  1. need amounts of between $50 and $1,250 to assist in paying expenses and managing their cash flow.
  2. are not interested in long or medium loan terms but want short term credit.
  3. can afford the repayments on the product without hardship.
  4. want contracts which are clear and easy to understand.
  5. want easy access to customer services to discuss payments, hardship and terms of the contract.
  6. want the funds quickly.
  7. want the loan application process to be simple, online, and quick.

The Key attributes of Our Product

The key attributes of our product are:

  1. Loan amounts are up to 25% of customer’s regular wage or salary with a maximum of $1,250.
  2. Terms of up to 31 days.
  3. One Fixed credit charge- 5% of the Amount Financed.
  4. Transparent, legible and easily understood contract documents.
  5. Ready access to customer services.
  6. Fast on-line application and approval process available through a mobile phone App.

The Key attributes of Our Product meet the Target Market

The key attributes of our product meet the needs, objectives and financial situations of consumers in its target market because:

  1. our product:
    1. provides easy access short term credit for consumers for to assist them in paying expenses and managing their cash flow.
    2. loan amounts are closely related to the amounts required by the target market consumers in their loan applications.
    3. short terms match the consumers’ needs, requirements and objectives, and financial situation.
  2. repayments on our product are affordable for the consumer without hardship.
  3. the application process is online by a mobile App and can be completed quickly.
  4. our contract documents are short, legible, and easy to understand.
  5. we provide ready access to online and telephone customer service.
  6. historical data shows that this product has:
    1. low Default rates.
    2. few customer complaints.
    and these are within an acceptable range and indicate that the product is suitable for the target market and is meeting the customer needs, objectives, requirements and financial situations.

Distribution Channels and Conditions

  1. All our Distribution channels present the product appropriately to consumers as follows:
    1. Our website and App contain:
      1. No misleading information
      2. An easy-to-follow application process during which the consumer is given informed choices at every stage.
    2. All third-party referrers are:
      1. vetted before being allowed to present our product.
      2. subject to regular monitoring.
      3. required to enter into referral agreements with us.
    3. We do not make any unsolicited offers of credit.
    4. Our television, billboard and social media advertisements contain no misleading information and are in plain easily understood language.
  2. We have adopted the following Voluntary Distribution Conditions to ensure that our product is distributed appropriately to its target market:
    1. No loans to any customer whose only source of income is Centrelink Benefits only.
    2. Customer earns a minimum of $405/week
    3. Is at least 18 years of age
  3. All our products are distributed in compliance with our voluntary responsible lending policy.

Review Triggers

We will review this TMD if the following occurs in relation to this product:

  1. The number of defaults in a 3-month period increases by 20%.
  2. The number of complaints from approved customers in a 3-month period increases by 20%.

The responsible manager will collect, assess, and review all the above data every month.

We will also respond to external sources such as:

  1. AFCA.
  2. ASIC.
  3. Community based consumer organisations.

If any of the above Trigger Events occur, this will trigger a review as if it were a Periodic Review as below.

Periodic Scheduled Reviews

  1. We will conduct quarterly periodic reviews whether or not a trigger event has occurred in the previous quarter.
  2. The responsible manager will conduct all reviews of this TMD.
  3. The responsible manager will report to our board within two weeks of conducting a review as to:
  4. Whether any trigger events have occurred.
    1. What factors may have caused these trigger events to occur including external factors not related to the design and distribution of our product.
    2. Which of the follow actions we should take:
      1. No change if all of our DDOs as published above are being met.
      2. The product needs a redesign.
      3. A new distribution condition is required; or
      4. The product must cease to be offered.