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 4914184 (“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.

1) What is the Target Market for Our SACC Product?

The target market for out SACC product are:

  • check_circle need amounts of between $300 and $2,000
  • check_circle need to pay for infrequent and sometimes unforeseeable expenses or purchases that cannot be met from their regular or usual disposable income;
  • check_circle want the funds quickly;
  • check_circle want the loan application and approval process to be easy, online, and seamless
  • check_circle are not interested in long term loans;
  • check_circle need the loan for personal and non-business purposes;
  • check_circle can afford the repayments on the product without hardship
  • check_circle want contract documents to be clear and easy to understand
  • check_circle want easy access to customer services to discuss payments, hardship and terms of the contract if required.

2) What are the Key attributes of Our SACC Product?


The key attributes of our SACC product are:

  • check_circle Loan amounts from $300 to $2000.

  • check_circle Terms of 5 weeks to 20 weeks.

  • check_circle Fixed credit charges - Establishment fee of 20% of the Amount Financed and Monthly fee of 4% of the Amount Financed.

  • check_circle Transparent, legible and easily understood contract documents, including a financial table and standard loan terms.

  • check_circle Ready access to customer services and hardship policy.

  • check_circle Fast on-line application and approval process

  • check_circle Loans are only for personal and non-business purposes.

3) How do the key attributes of Our SACC Product meet the Needs, Objectives and Financial Situations of the Target Market?


The key attributes of our SACC product meet the needs, objectives and financial situations of consumers in its target market because:

  • check_circle Our SACC product:
    • Provides easy access short term finance for consumers for their infrequent and sometimes unforeseeable expenses and purchases.

    • Loan amounts are aligned to the amounts requested by the target market consumers in their loan applications

    • Loan terms match the consumers’ needs, requirements and objectives and financial situation.

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    All our SACC loans are for personal non-business purposes.

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    The application process is online and can be completed quickly.

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    Our contract documents are short, legible and easy to understand.

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    We provide ready access to online and telephone customer service.

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    Historical data shows that this product has:

    • Low Default rates;
    • Few hardship applications;
    • Few customer complaints;
      and these are within an acceptable range and indicate that the product is suitable for the target market and is meeting the customer needs, objectives, requirements and financial situations.

4) What are our Distribution Channels and Conditions for this Product?

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    All our Distribution channels present the product appropriately to consumers as follows:

    • Our website which contains:

      • no misleading information;

      • all relevant disclosures and warnings required by law;

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

    • All third party referrers are:

      • vetted before being allowed to present our product;

      • subject to regular monitoring;

      • required to enter into referral agreements with us.

    • We do not make any unsolicited offers of credit.

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    We have adopted the following Voluntary Distribution Conditions to ensure that our product is distributed appropriately to its target market:

    • If a customer has 3 loans within a 6 month period or applies for a loan less than 1 month after completion of their last loan with us, we will not lend to them within the next 3 months unless they affirms in writing:

      • that the product is suitable for their situation;

      • is not being used as an informal line of credit; and

      • is only being used for infrequent and unforeseeable expenses and purchases outside the household.

    • No loans to any customer for the purpose of paying regular, ongoing ordinary household expenses such as utilities.

    • We do not make any unsolicited offers of credit.

  • check_circle

    All our products are distributed in compliance with our responsible lending obligations.


5) What are the Trigger Events for us to Review this TMD?

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    We will review this TMD if the following occurs in relation to this product:

    • The number of defaults which become bad debts in a 3 month period exceeds 5% of the Amounts Financed in our loan book by value.

    • The number of complaints from approved SACC loan customers in a 3 month period increases by 20% over the previous quarter.

    • The number of hardship applications in a 3 month period increases by 20% over the previous quarter.

    • The average number of loans per customer per year exceeds 6.

  • The responsible manager will collect, assess and review all the above data every month. We will also respond to external sources such as:

    • AFCA;
    • ASIC;
    • Community based consumer organisations;
      and seriously consider their observations, complaints and comments..

    If any of the above Trigger Events occur, we review this TMD as if it were a Periodic Review describe below.

6) When will we Periodically Review this TMD?

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    We will conduct annual periodic reviews whether or not a trigger event has occurred in the previous year.

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    The responsible manager will conduct the reviews of this TMD.

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    The Responsible Managers will report to our board of directors within two weeks of conducting a review following occurrence of any trigger events. Such a review will detail:

    • What factors may have caused these trigger events to occur, including external factors not related to the design and distribution of our product;

    • Appropriate recommendation/s in respect of which of the follow actions we should take:

      • No change if all of our DDOs as published above are being met;

      • Redesign of the product (needs a redesign);

      • Implementation of a new distribution condition/s (is required);

      • or

      • Withdrawal of the product from distribution (must cease to be offered).