Target Market Determination

Fundo Loans Pty Ltd

This Target Market Determination (TMD) has been prepared by Fundo Loans Pty Ltd ACN 604 639 143, holder of Australian Credit Licence 491418 ("Us, We, Our") to comply with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs). It applies to our Small Amount Credit Contract (SACC) product.

Target Market

Description of target market

We have assessed that this product is likely to meet the likely objectives, financial situation and needs of consumers who:

  • check_circle require credit of $500 to $2,000 for personal purposes to pay for infrequent and sometimes unforeseeable expenses or purchases, the cost of which cannot be met from their regular or usual disposable income;
  • check_circle require quick access to the loan funds;
  • check_circle require a loan application and approval process which is easy, online and seamless;
  • check_circle do not require or do not want a long-term loan commitment or access to revolving credit;
  • check_circle can afford the repayments for the loan without hardship;
  • check_circle may experience difficulty in obtaining credit through mainstream credit providers, such as banks.

We have assessed that this product is likely to meet the likely objectives, financial situation and needs of a consumer within the target market because it satisfies all the above criteria.

We consider that this product may not meet the likely objectives, financial situation and needs of a consumer who:

  • check_circle requires credit for the purpose of paying regular, ongoing ordinary household expenses such as utilities;
  • check_circle has had 3 or more SACC loans within a 6-month period;
  • check_circle applies for the product less than 1 month after the repayment of their previous SACC;
  • check_circle requires a longer-term loan or access to revolving credit; or
  • check_circle requires funds for business purposes.

Description of product, including key attributes


Attribute Details
Minimum Loan Amount $500
Maximum Loan Amount $2,000
Minimum Term 5 weeks
Maximum Term 6 months
Interest Rate N/A
Repayment Frequency Weekly, fortnightly, monthly
Fees and Charges

Establishment fee of 20% of the amount financed.

Monthly fee of 4% of the amount financed.

Distribution Conditions

Distribution Channels

Distributor Conditions and assessment
Direct distribution by Fundo

Fundo distributes the product directly to consumers via our website.

Applications are received electronically. The application form includes questions which seek to help us identify whether the applicant falls within the target market for the product. Financial data is verified via applicant-provided access to the applicant’s bank account statements. The verified data and application details are assessed against a defined set of credit assessment criteria. The following factors that are built into our application, assessment and approval process are designed to ensure that our product is distributed to customers within the target market:

  • The screening questions that are included in the loan application and which must be completed by the applicant for the application to progress.
  • The assessment and approval criteria programmed into our auto assessment system do not allow approval of applications that will place the consumer into financial hardship.
  • Our credit analysts who assess loan applications are highly trained professionals who are skilled in determining whether a consumer falls outside the target market parameters.

Where the application satisfies all criteria for approval and the application reveals no indications that the applicant is not within the target market for the product, the application is auto approved by our Loan Management System (LMS). Where the application fails to satisfy sufficient approval criteria, it is auto declined by LMS. Applications that do not meet the criteria for auto approval or auto decline are then passed to a team of highly trained credit analysts, who assess the application against the business’ credit criteria and policies and the product target market to enable them to provide an approval or decline decision.

We ensure that all material on our website is consistent with the product features and provides sufficient information about the product to enable consumers to make an informed decision about whether to apply for the product.

We have assessed that this distribution channel, including the conditions, is likely to direct distribution of the product to consumers within the target market because it provides rapid and straightforward access to the loan approval process, provision of loan funds to approved applicants without delay and an assessment and approval process that ensures that the loan repayments will not place the consumer in financial hardship.

Review Triggers

The occurrence of one or more of the following events will prompt us to review this TMD to ensure that the TMD remains appropriate:

  • check_circle There is a significant dealing in the product to consumers outside the target market;
  • check_circle We identify that the product has caused, or may be likely to cause, consumer harm;
  • check_circle The number of complaints we receive from consumers over a 3-month rolling period is more than 20% greater than the number of complaints received in the prior rolling quarter, subject to exceptions for distortions caused by low overall complaint numbers;
  • check_circle Applications for hardship relief we receive from consumers in a rolling 3-month period is more than 20% greater than the number of applications for hardship relief received in the prior rolling quarter;
  • check_circle Loan defaults in a calendar month exceed 7% of all loans;
  • check_circle The value of the loans with defaults which become bad debts in a rolling 3-month period is more than 5% of our loan book by value;
  • check_circle The average number of loans per customer per year exceeds 3;
  • check_circle There is a material change to the product or the terms and conditions;
  • check_circle There is a material change in the law or Regulator expectations.

Review Periods

First review date: 31 October 2024

Periodic reviews: The TMD will be reviewed annually, with the review completed by the anniversary date of the TMD.

Trigger reviews: Review of the TMD will commence within 10 days of the date we identify a trigger event.

Distribution Information Reporting Requirements

The following information must be provided to us by distributors who engage in retail product distribution conduct in relation to this product:

Type of information Description Reporting period
Complaints

Number of complaints

The details of a specific complaint

Every 3 months

Within 10 business days
Significant dealing/s

Date or date range of the significant dealing/s and description of the significant dealing (e.g. why it is not consistent with the TMD)

As soon as practicable, and within 10 business days after becoming aware