Target Market Determination

NEXT PERIODIC REVIEW DATE: 15 MARCH 2024

 

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 25 August 2023.  

 

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1.  Purpose of this TMD

 

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

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This TMD sets out the class of consumer for which the 180 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:

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• 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.

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This TMD does not offer a comprehensive outline of the 180 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 180
Product.

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2. Background to the 180 Product

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The 180 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 Products relating to the Owner’s property
  (for example, Elepay may require the registered proprietor to sign a Deed of Consent).

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The primary objective of the 180 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.

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To offer the 180 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).
 

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3. Class of consumers that comprises the Target Market

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Elepay’s 180 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 180 Partners on the basis that there is a foreseeable monetization
event (Target Market).

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CLASS OF CONSUMERS WITHIN THE TARGET MARKET

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The 180 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 180 Partners;

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

• are not currently experiencing financial hardship;

• are able to make five (5) equal instalments to repay the loan amount, equally spread out across the last 60 days of the
  consumer loan, without causing financial hardship.

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EXCLUDED CLASS OF CONSUMERS

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The 180 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 180 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.

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^ Default interest and other fees apply, see below.

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Eligibility Criteria and Other Product Key Attributes

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ELIGIBILITY CRITERIA

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To be eligible for the 180 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 and supporting documentation regarding any other registered encumbrance);

  • a copy of the real estate agent sales appointment form;

  • a copy of the contract of sale (if available);

  • a copy of any valuation of the property (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 180 Partners of a minimum amount of $100.00.

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OTHER KEY PRODUCT ATTRIBUTES

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Other key attributes of the 180 Product are:

• Structure –the 180 Product is structured so that the Consumer enters into a loan for a period of 180 days, under which Elepay disburses funds directly to the 180 Partner for payment of the agreed Sale Costs incurred by the consumer (from the Partner);​

• Purpose of loan - the 180 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 repay the loan amount via five (5) scheduled repayments equally spread out
  across the last 60 days of the consumer loan, though early repayment is possible without penalty (see below). If the
  consumer sells his or her property, then the loan amount must be paid (in full) at settlement even if settlement occurs prior
  to any scheduled repayment date;

• Partner’s goods or services – the 180 Partner will be solely liable for the products and services provided by the Partner to
  the Consumer;

• Fee Structure – the Fee structure for the 180 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 due date. This is subject to any claim the consumer may have for financial
    assistance;

  • 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);

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• 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 180 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).

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4. Consistency between the Target Market and the 180 Product 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 180 Product.