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120 Days Revolving Line of Credit TMD

Target Market Determination

NEXT PERIODIC REVIEW DATE: 15 JUNE 2025

Elevare Pay Easy Pty Ltd A.C.N. 634 728 591 (Elepay) (we, us or our) issues Pay Later products to Australian Property Owners and we are committed to maintaining a consumer-centric approach throughout our product design phase, distribution and sales channels, and monitoring and review process. This Target Market Determination (TMD) is effective from 15 June 2023.  

1.  Purpose of this TMD

This TMD has been prepared by Elepay for its ‘120RLC Product’ in compliance with our Design and Distribution Obligations
under Part 7.8A of the Corporations Act 2001  (DDO).

​

This TMD sets out the class of consumer for which the 120RLC Product has been designed having regard to the objectives,
financial situation and needs of consumers in the product’s target market. It includes the following:

  • product features and class of consumers that fall within the target market;

  • distribution conditions, restrictions and sales practices that are likely to direct distribution of the Products to the target market;

  • information relating to reviews and monitoring of the Products and this TMD, including specifying timing for periodic reviews and review triggers (i.e., the events or circumstances which would trigger a review);

  • how we deal with significant dealings.


This TMD does not offer a comprehensive outline of the 120RLC Product’s terms and conditions, nor is it a substitute for
obtaining independent legal or financial advice. Consumers should read the full terms and conditions before applying for the
120RLC Product.

2.  Background to the 120RLC Product

The 120RLC Product is part of a suite of Pay Later Products Elepay offers to Australian Property Owners who anticipate that a monetization event will occur in the foreseeable future (primarily, the sale of real property but may also include the refinance with a third-party lender).


An “Australian Property Owner” includes:

  • any person or entity who is a registered proprietor to real property held in Australia (Owner);

  • any person or entity who is an appointed representative of an Owner (e.g. appointed attorney or executor of a deceased estate); or

  • any person or entity who has the express consent of the Owner to acquire the 120RLC Product relating to the Owner’s property (for example, Elepay may require the registered proprietor to sign a Deed of Consent).

 

The primary objective of the 120RLC Product is to allow these property owners the opportunity to better manage their cash flow by allowing them to defer any upfront costs relating to their property until the occurrence of the monetization event.

 

To offer the 120RLC Product, we have partnered up with a number of styling companies, pre-listing companies, renovation companies and real estate agents to allow property owners to defer payment of expenses relating to:

  • home renovation and improvement;

  • property styling (to sell) and interior design;

  • other property-related works or expense,

      (Sale Costs)

3.  Class of consumers that comprises the Target Market

Elepay’s 120RLC Product is designed exclusively for consumers who meet our Eligibility Criteria and who wish to defer payment of their upfront Sale Costs associated with Elepay’s approved 120RLC Partners on the basis that there is a foreseeable monetization event (Target Market).

3.1.  CLASS OF CONSUMERS WITHIN THE TARGET MARKET

The 120RLC Product is for the class of consumers who:

  • falls within the definition of Australian Property Owner (see above) and require short-term lending solutions to pay Sale Costs;

  • are seeking finance with flexible payment options, no initial fees and no interest for the term of the loan^, the ability to make early repayments without additional charges, and a maximum amount of funding capped at the amount of the Sale Costs;

  • are receiving product or services and incurring Sale Costs through our 120RLC Partners;

  • meets Elepay’s Eligibility Criteria (set out below);

  • are not currently experiencing financial hardship;

  • are able to make a single lump sum payment for the loan amount (via the funds received from the monetization event) without causing financial hardship.

3.2.  EXCLUDED CLASS OF CONSUMERS

The 120RLC Product is not suitable for consumers who:

  • do not fall within the definition of Australian Property Owner;

  • are not receiving products or services and incurring Sale Costs through our 120RLC Partners;

  • do not otherwise meet Elepay’s Eligibility Criteria;

  • are going through bankruptcy or are experiencing, or are likely to, suffer from financial hardship;

  • are considered vulnerable persons (e.g. suffering from any form of cognitive impairment);

  • require an ongoing line of credit;

  • require a redraw facility;

  • are not comfortable with providing security over their real property.

​​

^ Default interest and other fees apply, see below.

3.3.  ELIGIBILITY CRITERIA 

To be eligible for the 120RLC Product, a consumer must satisfy the following requirements:

  • be an individual aged 18 years or above;

  • fall within the definition of Australian Property Owner (see above);

  • have an anticipated monetization event (for example, proposes to sell their property within the foreseeable future). Elepay may offer the product based on other monetization events (e.g. refinance from a third-party lender) subject to an individual assessment of the consumer’s circumstances;

  • if the monetization event is the sale of the consumer’s property, then meets Elepay’s Property Sale Equity Analysis, which ensures that the consumer has sufficient net equity to repay the loan upon the sale of the consumer’s property without causing financial hardship. The consumer will not be subject to an income serviceability assessment. Elepay will request details regarding the sale of the property (to ensure that there is sufficient net equity and the consumer proposes, or are actively taking steps, to sell their property). This includes, but is not limited to:​

    • details of the proposed sale – e.g. listing date and expected sale price;

    • details of the appointed real estate agent and conveyancer or solicitor;

    • details of any registered co-owner(s);

    • a copy of a recent mortgage statement;

    • a copy of the real estate agent sales appointment form;

    • a copy of the contract of sale (if available);

  • meet Elepay’s standard lending criteria including:

    • ​conducting a credit check on the consumer;

    • conducting an identity verification check on the consumer;

    • conducting an ownership check (e.g. title search of the property);

    • conducting an online property valuation report (for the property);

  • be incurring Sale Costs through our approved 120RLC Partners of a minimum amount of $100.00.

3.4.  OTHER KEY PRODUCT ATTRIBUTES

Other key attributes of the 120RLC Product are:

  • Structure –120RLC Product is structured so that the Consumer enters into a loan for a period of 120 days, under which Elepay disburses funds directly to the 120RLC Partner for payment of the agreed Sale Costs incurred by the consumer (from the Partner);

  • Purpose of loan - the 120RLC Partner must be providing products or services to the Consumer and the loan must be for the payment of the Partner’s Sale Costs (whether partial or in full);

  • Repayment– the consumer is required to repay the loan (in full) on the earlier of: (a) the settlement date (if the property is sold) and (b) the scheduled repayment date (being 120 days from the Elepay Start Date), though early repayment is possible without penalty (see below);

  • Partner’s goods or services – the Partner has an obligation under the Elepay Partner Agreement to supply goods and services to the consumer with reasonable care and skill and in accordance with the supply terms between the Partner and the consumer;

  • Fee Structure – the Fee structure for the 120RLC Product is as follows:

    • No Plan Fee and no Interest for the term of the loan – the Consumer is not required to pay any plan fee or interest for the provision of credit (default interest and other fees apply, see below);

    • No Establishment or Administration fee – the Consumer is not required to pay any establishment or administration fee for the provision of credit;

    • Partner Fee – the Partner is required to pay a partner fee of up to 6.95% of the consumer’s total loan amount. This fee is payable under a separate agreement between Elepay and the Partner;

    • Default/Late fee – the consumer will be liable to pay a late interest of 0.0695% per day compounding daily (of the outstanding amount) and a late fee of 0.25% every 30 days (of the outstanding amount) if the consumer has not repaid an amount owing by the scheduled repayment date. This is subject to any claim the consumer may have for financial assistance.


Note: Any consumer obtaining an Elepay loan associated with Sale Costs incurred from our partner, Fix Sell Pay Pty Ltd A.C.N. 165 833 438 (Fix Sell), will be subject to different default fees and charges, as follows:

A further late payment fee:

1.85% of the loan amount

Default interest:

Calculated at 0.08% (instead of 0.06%) per annum* compounded daily (calculated from the date of default until all balance owing is paid in full)

Late payment fee:

1.85% of the loan amount

Default interest:

0.06% per annum* compounded daily (calculated from the date of default until all balance owing is paid in full)

FIX SELL DEFAULT FEES
Fee
Rate

(A) The following default fees apply if a consumer is in default by a period of less than 28 days:

(B) If a consumer's default subsists for over 28 days, then the following default fees will apply:

* Calculated based off the total outstanding balance as at the relevant date.

​

  • Other fees – other fees may apply such as a missed payment fee ranging from $15.00 to $25.00 (depending on the method of payment nominated) and title registration fee ranging from $350 to $1,100 (depending on whether a registered security is provided with respect to the consumer’s property);

  • Minimum Credit Limit – the minimum amount of funding provided is $100.00;

  • Maximum Credit Limit – subject to an individual credit and lending assessment for a particular consumer, the amount of funding provided is capped at the Sale Costs agreed between the consumer and the 120RLC Partner;

  • Early repayments – Consumers have the ability to make an early repayment of the loan without any additional charge or exit fee;

  • Security – the consumer will be required to provide a charge over the consumer’s real property (which may or may not be registered against title to the property).

4.  Consistency between the Target Market and the 120 RLC Product Key Attributes

Set out below is our assessment of the likely objectives, financial situation and needs of the Target Market, and the key product attributes of the 120RLC Product.

CONSUMER OBJECTIVES, FINANCIAL SITUATION AND NEEDS
120RLC PRODUCT ATTRIBUTES

Require short-term lending solutions to pay Sale Costs

  • Designed to provide consumers with short-term lending to fund the consumer's Sale Costs (once these costs have been agreed between the consumer and our 120RLC Partner).

  • Payment is made directly to the nominated 120RLC Partner for payment of expenses (payable by the consumer to the Partner).

Redraw Facility

  • Redraw facility is not available.

Funds to be used for Sale Costs

  • Funds must be used for upfront Sale Costs associated with our 120RLC Partners.

Repayment and Term

  • Repayment is required on the earlier of: (a) settlement date (if the property is sold) and (b) the scheduled repayment date.

  • The term of the loan is 120 days and the repayment date is 120 days from the Elepay Start Date.

Flexible payment options to accommodate for any unforeseeable change in circumstances

  • If the anticipated monetization event has not occurred (e.g. property owner is unable to sell their property) by the repayment date, Elepay offers flexible and compassionate payment arrangements to the consumer. These may include an extension of time, suspension or reduced repayment terms and/or concessions or waivers of certain fees and charges.

  • The assessment will be conducted by Elepay's Finance Team and subject to the terms of Elepay's internal Financial Hardship Policy.

No fee and no interest for the provision of credit payable by the consumer during the loan term

  • Consumers are not required to pay any fee, interest, establishment fee or administration fee for the provision of credit.

  • Merchant fees are payable by 120RLC Partners and default interest and charges and other fees may be charged to consumers (please refer to the Fee Structure in clause 3 of this TMD).

Ability to make early repayments

  • Consumers have the ability to make an early repayment of the loan without any additional charge or exit fee.

Credit Limit

  • ​Subject to an individual credit and lending assessment for a particular consumer, the amount of funding provided is capped at the Sale Costs agreed between the consumer and the 120RLC Partner.

Full transparency over any registered security

  • ​​Elepay will discuss and obtain the owner's consent prior to registering any security over the consumer's property and approving the consumer's loan application

  • Elepay will disclose any related costs (e.g. estimated registration costs) before attending to the registration of the security.

5.  Distribution Channels and Conditions

5.1.  APPROPRIATENESS STATEMENT 

Elepay considers it is reasonable to conclude that if the 120RLC Product is issued to a consumer in accordance with the distribution conditions in this TMD it would be likely that the consumer is in the Target Market and it would likely be consistent with their likely objectives, financial situation and needs. This determination is based on the assessment above regarding the consistency between the Target Market and the Product’s Key Attributes, which incorporates past outcomes and feedback of the Product’s consumers and Partners. 

5.2.  DISTRIBUTION CHANNELS AND CONDITIONS  

Distribution Channel: A consumer may apply for (or be referred) the 120RLC Product via our authorised 120RLC Partners. 

​

The consumer may only apply by submitting an online loan application via Elepay’s website. We have oversight over how the 120RLC Product is promoted and issued. 

​

We regularly monitor our website to ensure it contain:

  • no misleading information;

  • all relevant disclosures and warnings required by law;

  • an easy to follow process during which the consumer is given informed choices at every stage.

​

The distribution conditions relating to the marketing and promotion of the 120RLC Product are specified in the table below.

Condition

General

  • We do not make any unsolicited offers of credit.

  • The consumer must meet the Eligibility Criteria.

Online Channels (e.g. website)

  • Our online website provides consumers with information including: 

    • comparison rates; 

    • summary of key benefits, rates and fees;

    • payment calculator. 

Authorised Staff

  • Only authorised staff are permitted to assist consumers with this Product. These staff have the necessary training, skills and knowledge to provide specific advice relating to the Product. 

Approved Partners (Referrers):

  • For a Partner to be approved, the Partner must: 

    • be proposing to provide products or services to the consumer; 

    • enter into and comply with the terms of a Partner Agreement; and 

    • satisfy our verification and compliance assessment criteria

Factual information

  • An approved Partner may provide general or factual information relating to the Product (provided that it is consistent with this TMD) (for example, the consumer application process). 

No Financial Product Advice

  • An approved Partner must not provide specific advice (e.g. financial advice) relating to the terms of the loan and must redirect any queries to Elepay. 

DISTRIBUTION CONDITIONS

​This Product is not distributed through third parties. 

6.  Periodic Review and Review Triggers 

To ensure that the 120RLC Product continues to meet the objectives and needs of their Target Market, it is necessary that we regularly review this TMD. This includes consideration of: 

  • 120RLC Product and Target Market; 

  • Eligibility Criteria; and 

  • distribution channels and conditions.

 

In reviewing the above, we collect and analyse data relating to: 

  • our eligibility and application phase; 

  • Partner feedback and our online Partner portal; 

  • disputes between the Partner and consumer relating to the Partner’s services and products;

  • sales information; 

  • consumer information; 

  • payment information (including funds recovered and not recovered);

  • feedback and complaints (from consumer and Partners);   

  • default information and extended repayment terms; 

  • property sale status (including the amount of property withdrawn from sale);

  • market conditions (including the effect of interest rate changes and market sentiment).

 

These reviews will be conducted periodically and in response to review triggers and other events or circumstances that would reasonably suggest this TMD is no longer appropriate.

PERIODIC REVIEW PERIOD

We will conduct our next review on the Next Review Date and periodic reviews at least quarterly from the Next Review Date. 

REVIEW TRIGGERS

In addition to periodic reviews, we will review this TMD in response to a review trigger or other event or circumstance that would reasonably suggest this TMD is no longer appropriate. The occurrence of a review trigger or other such event or circumstance will trigger an immediate review of this TMD and may result in Elepay changing the Target Market, the design or distribution of the product or ceasing to offer this product.


These review triggers are:

  • we receive a substantial number of complaints from consumers or partners about the 120RLC Product (i.e., if complaints about the product from active 120RLC Product consumers or partners increases by 10% or more in a six month period);

  • a substantial number of consumers are:

    • if the monetization event is the sale of the property, withdrawing their property from sale and no longer intends to sell the property (i.e., if over 15% of active 120RLC Product consumers fall within this category);

    • if the monetization event is the sale of the property, unable to sell their property within the loan term period and seek extension of the repayment date (i.e., if over 15% of active 120RLC Product consumers fall within this category);

    • experiencing negative repayment history, including missing a scheduled repayment (i.e., if over 15% of active 120RLC Consumers fall within this category);

    • seeking financial hardship relief (i.e., if over 10% of active 120RLC Product consumers fall into this category);

  • there are material changes to the key attributes of our products which may result in the product no longer being appropriate for our Target Market;

  • there is a material change in our distribution channels such that our distribution conditions requires variation;

  • there are a substantial number of complaints relating to the products or services provided by the Partner (e.g. delay in works completed by the Partner) (i.e., if complaints about our partners from active 120RLC Product consumers increases by 10% or more in a six month period);

  • change in regulatory, legislative or market conditions which may materially affect the product or any matter relating to this TMD;

  • the use of Product Intervention Powers, regulator orders or directions about or relating to the 120RLC Product’s key features, target market or distribution strategy;

  • a significant dealing has occurred (or is likely to occur). A significant dealing occurs when the distribution of our product (including conduct by our distributors) significantly differs from any condition or expectation set out in this TMD;

  • any other matter that may result in this TMD not being appropriate.

7.  Reporting 

We will report to ASIC within ten (10) business days should we have reasons to believe that a significant dealing has occurred either by us or via our distributors. Our distributors are also obliged to inform us of any significant dealing events, and we have arrangements in place to monitor and review our distributors’ compliance with this obligation.

Complaints (as defined in section 994A(1) of the Corporations Act 2001) relating to the product. The distributor should provide all the content of the complaint, having regard to privacy.

As soon as practicable but no later than 10 business days following end of calendar quarter.

Significant dealing outside of target market, under section 994F(6) of the Corporations Act 2001.

As soon as practicable but no later than 10 business days after distributor becomes aware of the significant dealing.

Reporting Requirement
Reporting Period
DISTRIBUTOR REPORTING REQUIREMENTS

We will also monitor other consumer and distributor feedback on a monthly basis.

8.  Records

We will keep records of any complaints, action taken or review of any matters related to this TMD. 


This includes, but is not limited to: 

  • Product design and development matters; 

  • Data collected and analysed for TMD reviews;

  • TMD review meetings; 

  • Consumer feedback; and 

  • Review of distribution channels and conditions. 

9.  Contact 

Should you have any queries regarding this TMD, please contact us at legal@elepay.com.au or 1300 019 417.

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