Target Market Determination

NEXT PERIODIC REVIEW DATE: 3 MONTHS FROM EFFECTIVE DATE

 

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 as at 5 November 2024.

 

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1.  Purpose of this TMD

 

This TMD has been prepared by Elepay for its ‘180-Day Product’ (Product) in compliance with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001. 

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This TMD sets out the class of consumer for which the 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 Product to the target market; 

• information relating to reviews and monitoring of the Product 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. 

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This TMD does not offer a comprehensive outline of the 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 Product. 

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2.  Background to the 180 Product

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The Product is part of a suite of PayLater Products offered by Elepay to Australian Property Owners who require a flexible short-term loan for a fixed amount to be used for property-related or personal purposes (Loan Purpose).  

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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 (for example, an appointed attorney or executor of a deceased estate); or  

• any person or entity who has the consent of the Owner to acquire the Products relating to the Owner’s property.

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3.  Class of consumers that comprises the Target Market

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The Product is designed exclusively for consumers who meet our Eligibility Criteria and who wish to obtain a personal loan to fund a Loan Purpose (Target Market).

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3.1.  CLASS OF CONSUMERS WITHIN THE TARGET MARKET

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The  Product is for the class of consumers who: 

• falls within the definition of Australian Property Owner (see above) and requires a short-term flexible loan for a fixed loan amount; 

• are seeking finance with flexible payment options, a capped plan fee for the term of the loan and the ability to make early repayments without additional charges;  

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

• are able to repay the loan amount by the scheduled repayment date(s);  

• in the event that the consumer’s application is subject to a Monetization Event, the consumer is agreeable to repaying the loan (in full) upon completion of the Monetization Event (even if this occurs prior to the scheduled repayment date(s)). 

 

"Monetization Event" means an anticipated foreseeable event from which the consumer is expected to receive funds to repay the Elepay loan. This generally includes the sale of real property but may include other events, such as refinancing and other sources of income (e.g.  inheritance windfall, commission or bonus payment). 

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3.2.  EXCLUDED CLASS OF CONSUMERS

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The Product is not suitable for consumers who: 

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

• do not otherwise meet Elepay’s Eligibility Criteria; 

• are considered vulnerable persons (for example, suffering from any form of cognitive impairment);

• require an ongoing line of credit;

• require a redraw facility; 

• are not prepared to provide security over their real property. 

3.3.  ELIGIBILITY CRITERIA 

To be eligible for the 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);

• meet Elepay’s standard credit assessment, lending and suitability criteria (as Elepay deems appropriate);

• satisfy Elepay’s Free Equity Assessment and/or Income Serviceability Assessment (note: the type of assessment applicable depends on the type of Monetization Event and Payment Type selected); 

• require funding of a minimum amount of $100; 

• require funding of an amount which does not exceed the Maximum Funding Threshold in circumstances where the consumer is selling their Property (see below). ​

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3.3.1  Free Equity Assessment 

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The Free Equity Assessment verifies whether the consumer has sufficient Free Equity in their property to repay the loan once the property has sold. 

"Free Equity" is calculated by determining the market value or forecasted sale price of the property less the following: 

• associated sale costs (including sales commission and legal fees); and 

• total value of debt and liabilities relating to the property (including mortgages and caveats).  

 

“Maximum Funding Threshold” means the internal assessment used to determine a consumer’s maximum borrowing capacity. Consumers may borrow up to 90% of the assessed Free Equity in their secured property, with this rate varying based on the property’s sale status. Consumers who select the Multiple Payment Option must also satisfy the Income Serviceability Assessment. 

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3.3.2 Income Serviceability Assessment

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Consumers who select on a Multiple Payment plan must satisfy Elepay’s Income Serviceability Assessment, which determines whether the consumer has sufficient household net income to meet their repayment obligations without experiencing financial hardship. 

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These consumers will be required to:

• complete an income serviceability form outlining their net household income and expenses; 

• provide supporting documentation for any claimed source(s) of income;

• submit personal bank statements (covering the last 3 months); and  

• disclose any existing (or anticipated) circumstance or event which may affect their ability to make the required repayments. 

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3.4.  KEY PRODUCT ATTRIBUTES

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Some key attributes of the Product include: 

• Structure – the consumer enters into a direct loan with Elepay for a fixed term of 180 days;    

• Purpose of loan – the loan must be used for the Loan Purpose; 

• Payment Options – there are two payment options offered for this Product: 

  • Single Payment Option – one lump sum payment upon expiry of the loan term; 

  • Multiple Payment Option – total of 6 equal repayments over the loan term (each repayment payable every 30 days). ​

Consumers have the flexibility to select the Payment Option applicable to their plan; however, if there is no Monetization Event, they are limited to the Multiple Payment Option. 

• Payment upon completion of Monetization Event – if there is a Monetization Event, the consumer must repay the loan (in full) upon completion of the Monetization Event (even if this is prior to any scheduled repayment date(s));  

• Early Repayment – the consumer may repay the loan early (in part or full). If the consumer repays the loan (in full), they may be entitled to a discounted Plan Fee (as per the Fee Structure table below); 

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

• Default/Late fee – the consumer will be liable to pay default fees and interest in accordance with our Default Payment Policy applicable at the relevant time; 

• Other fees – other fees may apply such as a bank processing fee of 1.50% plus 30c (per credit card payment) and $2.95 (per direct debit payment), a missed payment fee ranging from $15.00 to $25.00 (depending on the nominated method of payment) and title registration fee ranging from $350 to $900 (if a registered caveat is required); 

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• Minimum Credit Limit – the minimum amount of funding provided is $100; 

• Maximum Credit Limit – the amount which does not exceed the Maximum Funding Threshold in circumstances where the consumer is selling their property;

• Security – the consumer will be required to provide a charge over real and personal property owned by the consumer;

• Direct vs Partner Plan – the Product may be obtained by a consumer directly or through an authorised Elepay partner for payment of property-related expenses incurred by the consumer from the Partner. For Partner Plans, Elepay will not be liable for any matter relating to the product or service provided by the Partner to the consumer.

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4.  Consistency between the Target Market and the Products Key Attributes

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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 Product.