Target Market Determination (TMD)
Online Loans Pty Ltd

Effective from June 2024

A. Purpose and overview

1. This Target Market Determination (TMD) has been developed to:

assist consumers (as that term is defined in section 5 of the National Consumer Credit Protection Act 2009) within the Target Class (as defined below), obtain suitable financial Products having regard to their ‘likely objectives, financial situation and financial needs’, and
assist distributors distribute the Products in a manner consistent with this TMD.

2. The Products include the provision of credit to retail consumers pursuant to Div 2 of Pt 2 of the Australian Securities Investments Commission Act 2001 (ASIC Act). Online Loans Pty Ltd (the Issuer) is therefore a credit provider and is regulated under the National Consumer Protection Act 2009 (National Credit Act).

3. This TMD specifically covers the following Online Loans Pty Ltd products (Products):

Cash Loans (Small Amount Credit Contract) – loans from $200 to $2,000;
Personal Loans (Medium Amount Credit Contract) – loans from $2,001 to $4,600.

4. This document is not a full summary of the Products’ terms and conditions contained in the customer terms issued by Online Loans Pty Ltd (and any supplementary documents), nor is this TMD intended to provide financial product advice.

TARGET CLASS
Product	Cash Loans (Small Amount Credit Contract)	Personal Loans (Medium Amount Credit Contract)
Likely objectives	This Product is suitable for borrowers with the following likely objectives, financial situation and financial needs: Fixed monthly repayments; Short term loans of no more than 12 months; Loan amounts not exceeding $2,000; Some early repayment flexibility.	This Product is suitable for borrowers with the following likely objectives, financial situation and financial needs: Borrowers looking for loan products with fixed fees, fixed interest and fixed repayments; Short to medium term loans not exceeding 15 months; Loan amounts from $2,001 to $4,600; Some early repayment flexibility.
Likely financial situation and needs	This Product is suitable for a Target Class with the following likely financial situation and needs: Access to smaller loan amounts on a short term basis to meet emergencies or other unexpected liabilities; Borrowers with differing levels of repayment abilities; Borrowers with stable income including on welfare benefits; Borrowers that may not satisfy the lending history requirements of mainstream lenders; Borrowers with differing levels of financial literacy; Borrowers who have the ability to repay the loan amount with fees; Borrowers seeking unsecured lending; Borrowers seeking an online solution for financing options;	This Product is suitable for a Target Class with the following likely financial situation and needs: Borrowers seeking medium amount loans who may not have access to savings to meet the purchase price of goods and services in full; Borrowers with differing levels of repayment abilities; Borrowers with stable income including on welfare benefits; Borrowers who have the ability to repay the loan amount with fees over the shorter to medium term; Borrowers that may not satisfy the lending history requirements of mainstream lenders; Borrowers with developed levels of financial literacy; Borrowers seeking an online solution for financing options; Borrowers seeking a face-to-face solution for financing options; Borrowers seeking finance with security as an option;
Key Product Attributes	This Product contains the following key attributes: Fixed loan terms from 2 months and up to 12 months; Ability for borrowers to elect weekly/fortnightly/monthly repayment terms; Ability for borrowers to make early repayments without penalty; Unsecured loans; Streamlined online loan application process to provide borrowers access to emergency funds conveniently; Ability to transfer loan funds to the borrower’s account (depending on borrower’s bank) quickly subject to responsible lending obligations; Fixed application fee of 20% and monthly fee of 4%; Upfront and transparent fee structure.	This Product contains the following key attributes: Fixed loan terms of 13 months for loans between $2,001 and $2,999; Fixed loan terms of 15 months for loans between $3,000 and $5,000; Fixed charges; Ability for borrowers to elect weekly/fortnightly/monthly repayment terms; Ability for borrowers to make early repayments without penalty; Ability to quickly transfer loan funds to the borrower’s account (depending on borrower’s bank) subject to responsible lending criteria; Fixed application fee of $400 and fixed credit fee structure of 45%; Upfront and transparent fee structure; Ability for borrowers to apply for secured or unsecured loans.
Ineligible/excluded class of consumers	Online Loans Pty Ltd has determined that the Product is not suitable for the following class/type of consumers: Consumers seeking borrow more than $2,000; Consumers under the age of 18; Consumers not receiving a regular stream of income; Consumers who do not meet the minimum take home income or benefits requirements; Consumers who exceed the cost-of-living expenses criteria (whether for single or joint borrowers); Consumers who are currently bankrupt or in a Part IX debt agreement; Consumers who have finance defaults listed after bankruptcy; Consumer under a debt consolidation arrangement; Consumers seeking to refinance existing loans into a new loan; Consumers in hardship.	Online Loans Pty Ltd has determined that the Product is not suitable for the following class/type of consumers: Consumers seeking to borrow less than $2,001; Consumers seeking to borrow more than $4,600; Consumers under the age of 18; Consumers not receiving a regular stream of income; Consumers who do not meet the minimum take home income or benefits requirements; Consumers who exceed the cost-of-living expenses criteria (whether for single or joint borrowers); Consumers who have finance defaults listed after bankruptcy; Consumers with no permanent address; Consumer under a debt consolidation arrangement; Consumers in hardship.

B. Conditions and restrictions on distribution

1. Online Loans Pty Ltd has determined that based on the Products’ key attributes, the Products have a fairly broad target market.

2. The Products are distributed through the following channels:

Online;
Branch Loans Pty Ltd Branches.

3. If Online Loans Pty Ltd or its distributors becomes aware that the distribution conditions outlined in this TMD are no longer adequate such that consumers outside of the Target Class are able to gain access to the Products, that distribution channel shall immediately be reviewed.

C. Events and circumstances likely to suggest this TMD is no longer appropriate for the Target Class

Online Loans Pty Ltd has determined that the following events and circumstances will make the Product no longer appropriate to the Target Class:

Where ineligible consumers or consumers out of the Target Class are overwhelmingly able to gain access to the product;
In circumstances where the distribution of the Product described in this TMD are no longer applicable;
Where Online Loans Pty Ltd overwhelmingly feel the Products are no longer appropriate having regard to the objectives and financial circumstances and needs of the Target Class.

D. Review of TMD

1. The initial review of this TMD shall commence within 12 months of the effective date (Initial Review Date).

2. This TMD shall be reviewed periodically at least every 6 months from the date of the Initial Review Date.

3. Any of the following circumstances shall trigger a review of this TMD:

Where the Product is deemed to no longer be consistent with the likely objectives, financial situation and needs of the Target Group;
Where the distribution conditions of the Product are found to be inadequate and consumers outside of the Target Group are able to acquire the Product;
An external event that would create a material change to the design or distribution of the Product, such as any changes to the legislation;
An occurrence of a Significant Dealing (as set out in section E.3 below);
Where the total percentage of hardship applications is greater than 3% of the total number of loans entered into over a period of 6 months;
Where the number of complaints received from distributors about the product of distribution of the product over 6 months is greater than 3% of the total number of loans entered into in the over a period of 6 months;
Any other reasonable circumstances which Online Loans Pty Ltd reasonably believes will warrant a review of this TMD.

E. Reporting obligations and continuous monitoring of this TMD

1. To ensure that the Product meets the reporting obligations set out under the ASIC Regulations Guide 274, Online Loans Pty Ltd requires its distributors to:

Provide number of requests for hardship applications;
Provide rates of arrears and defaults;
Provide rates of early payout;
Provide the number of complaints;
The substance of any complaints;
Reports from distributors of significant dealings;
Provide any other relevant information which Online Loans Pty Ltd determines is relevant and necessary;
Provide general feedback as to whether the Product continues to be suitable for the specific target market outlined in this TMD.

2. All distributors are required to report to Online Loans Pty Ltd in accordance with the following reporting periods:

6 months for the purposes of the TMD for non-complaint related reporting; and
2 Business Days in respect of a complaint.

3. For the purposes of this TMD, a “Significant Dealing” shall mean any of the following occurrences in relation to consumers outside of the target class acquiring a loan:

The dealing is significant because it constitutes a transaction which has resulted in, or will or is likely to result in, significant detriment to the customer because the distribution of the Product results in more than 5% of customers outside the Target Class being issued the Product.

4. The reporting obligations shall apply to the following distributors:

Online Loans Pty Ltd itself as a distributor;
Branch Loans Pty Ltd Branches.

5. All complaints received by distributors in relation to this Product (including those in written form) will be reviewed immediately upon receipt of the complaint.

6. Online Loans Pty Ltd is required to notify ASIC of any Significant Dealings within 10 business days.