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12-MONTH PRODUCT

Target Market Determination

NEXT REVIEW DATE: 15 MARCH 2024

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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 and distribution and sales channels.  This Target Market Determination (TMD) is effective as at 15 March 2023.

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1. Purpose of this TMD

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This TMD is published pursuant to the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 and is aimed at providing members, distributors, consumers and any other interested third parties an understanding of the following:

  • product features and our appropriate target market;

  • distribution conditions and restrictions and sales practices relevant for our target market;

  • our TMD review regime and events or circumstances which would trigger a review; and

  • the meaning of, and how we deal with, significant dealings.

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This TMD does not offer a comprehensive outline of our products and services, nor is it a substitute for obtaining independent legal or financial advice. Consumers should read the full terms and conditions before applying for a product.


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2.  Background


Elepay offers its 12-month Product to Australian Property Owners who intend to style, renovate or improve their residential home through our exclusive 12-month partners. The aim of this product is to allow property owners to enhance their property whilst providing additional time for them to repay associated costs.


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3.  Product Description


RANGE OF PRODUCTS

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Our 12-month Product is designed to allow property owners to conduct home renovation work via our selected 12-month Partners and defer the payment of our Partner’s fees over a period of 12 months (Target Market).

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OBJECTIVES AND NEEDS

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The primary objectives and requirements of our Target Market, and some of the key attributes which ensure our products are suitable for the above Target Market, are specified below:

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4.  Eligibility Criteria


To be eligible for Elepay 12-month Product, the consumer must satisfy the following requirements:

  • be 18 years of age or over;

  • be a registered owner of an Australian residential property;

  • proposes to renovate their property with our selected approved Partners;

  • meet Elepay’s credit assessment criteria which includes:

    • satisfying Elepay’s credit score rating and ensuring the consumer is not going through bankruptcy or financial hardship;

    • providing information and evidence (including recent pay slips) to ensure there is sufficient combined household net income to make the required. Elepay instalments and other payment obligations (plus retain surplus income);

    • ensuring that the consumer will not be experiencing financial hardship if the loan was granted – this includes assessing the serviceability of the consumer and equity position of the property;

    • meet Elepay’s identity verification criteria which includes providing current forms of photo identification and undertaking further verification (if required).

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Our 12-month Product is not suitable for consumers who:

  • do not meet the above criteria;

  • intend to conduct renovation work with an unapproved supplier;

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

  • are considered vulnerable persons including those who are:

    • suffering from any form of cognitive impairment;

    • unemployed or not receiving any form of consistent income;

    • have low levels of financial literacy.

 


5.  Distribution Conditions


APPROPRIATENESS STATEMENT

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Elepay considers the 12-month Product (including its key attributes) to be appropriate for the Target Market in light of their objectives, financial situation and needs. This determination is partly based on the past outcomes and feedback of our consumers and exclusive Partners.

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DISTRIBUTION CONDITIONS

The distribution channel surrounding our 12-month Product is controlled and limited as consumers may only apply for this product if they obtain a referral link from Elepay. These links are only offered to consumers if they have been referred by our exclusive 12-month Partners (distributors).

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Distribution Conditions – the Partner

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Distribution Conditions – the Consumer

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6.  Review and Review Triggers


To ensure that Elepay 12-month Product continues to meet the objectives and needs of our Target Market, it is necessary that we conduct a review of:

  • our product attributes and Target Market;

  • our eligibility criteria; and

  • our distribution channels and conditions.

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

  • our eligibility and application phase;

  • partner feedback and our online partner portal;

  • sales information;

  • customer information;

  • payment information (including funds recovered at settlement and otherwise);

  • feedback and complaints (from consumer and partners); and

  • default information and extended repayment terms.

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REVIEW PERIOD

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

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REVIEW TRIGGERS

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There are certain events or triggers which may result in Elepay determining that this TMD is no longer appropriate for the Target Market. Such events will trigger an immediate review of this TMD and may result in Elepay ceasing to offer its 12-month Product.

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These triggers include:

  • we receive a substantial number of complaints from consumers or distributors;

  • a material portion of our consumers are experiencing financial hardship or defaulting under their loan;

  • 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 must be varied;

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

  • notification from ASIC;

  • 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 10 business days should we have reasons to believe that a significant dealing has occurred either by us or our distributors. Our distributors are also obliged to inform us of any significant dealing events. We will monitor 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:

  • Any product design matters;

  • TMD review meetings;

  • Consumer and distributor feedback; and

  • Review of any 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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