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Target Market Determination



Elevare Pay Easy Pty Ltd A.C.N. 634 728 591 (Elepay) (we, us or our) issues PayLater 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 as at 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 PayLater 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).


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.


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.

Eligibility Criteria and Other Product Key Attributes


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 suffcient 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 suffcient 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.


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:

120 1.png

* 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.

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5. Distribution Channels and Conditions


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 120RLC Product Key Attributes, which incorporates past outcomes and
feedback of the 120RLC Product consumers and 120RLC Partners.


Distribution Channel: A consumer may only apply for our 120RLC Product via our approved 120RLC Partners (Distributors).

We have oversight over how the 120RLC Product is promoted and issued.

We regularly monitor our 120RLC Partners’ websites and marketing material to ensure they 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.

Our own website contains:

  • 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.

6. Periodic Review and Review Triggers

To ensure that the 120RLC Product continues to meet the objectives and needs of its 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;

  • customer 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.


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



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.

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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 and distributor feedback; and

  • Review of distribution channels and conditions.

9. Contact

Should you have any queries regarding this TMD, please contact us at or 1300 019 417.

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