Purpose of this Document

The purpose of this Target Market Determination (“TMD”) is to comply with the Design and Distribution Obligations incorporated under Chapter 7 of the Corporations Act 2001 (“the Act”) by the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.

The TMD aims to provide consumers and distributors with information about the class of consumers that comprises the target market for the Product, taking into account their objectives, financial situation and needs. It also specifies any Product distribution conditions and restrictions and deals with reviews of the TMD as well as distributor arrangements.

Legal Disclaimer

This document is not a credit disclosure document and does not include all relevant terms and conditions associated with this Product. It does not take into account any person’s individual objectives, financial situation or needs. Individuals interested in making use of this product should carefully read the Issuer’s Credit Guide and any other disclosure documents before making a decision whether to use this Product.

Description of Target Market

This section is required under section 994B(5)(b) of the Act.

The target market has been established by assessing the Product (including its key attributes) and the consumer objectives, financial situation and needs for which the Product is likely to be appropriate. The class of consumers who fall within the target market for the Product is described below, based on the objectives, financial situation and needs of the consumer and the key attributes of the Product.

Description of Product and Key Attributes 

The key attributes of this Product are: 

• A list of key Product attributes and consumer eligibility requirements eg size and term of the loan, payment structure, fees and charges will vary as to the size of the loan required and therefore also will the repayment terms.

Product and Target Market Consistency

The Product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market based on the following:

• The assessment that the Product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market is based on an analysis of the attributes and characteristics of the product and establishing that they are consistent with the likely requirements of consumers in the target market.

Description of Consumer Objectives, Financial situation and Needs

Customers in the target market for a Small Amount Credit Contract are those wanting to: 

• Finance a small expense for personal use, for example: unexpected bills, car expenses, or medical and dental costs.

• Borrow between $300 and $2,000;

• Borrow without the need to put down a security (unsecured lending); 

• Repay the loan over a term between 6 months to 12 months by making repayments comprising of principal and monthly fees.

Customers may already have another loan and/or have previously obtained a personal loan in the past. For some it might be the first time they're taking out a Small Amount Credit Contract (SACC) Loan. Therefore, there are verifying levels of knowledge and experience of this product category across the different customer groups. They need to be able to afford the repayments over the term of the loan.

Customers who are in the target market are:

• may have objectives both financial situation and needs, could require a personal loan

• Are Australian citizens, Australian permanent residents, New Zealand citizens, Work visa holders and Sponsorship/spouse visa holders;

• Aged 18 years old or older; customers older than 70 (inclusive) are not eligible;

• Employed - could be full-time, part-time, casual or self employed;

• Can be on Centerlink benefits, however Centerlink benefits cannot make up the majority of their monthly income (unless the customer is of pension age);

• Have reasonable credit history.

Excluded Classes of Consumers

This Product is unsuitable for persons:

• Who do not qualify under the responsible lending requirements imposed by the National Consumer Credit Protection Act 2009 (“National Credit Act”), will be unable to comply with their financial obligations under the Product terms, or could only comply with substantial hardship.

• For whom the Product will not meet their requirements or needs.

• who receive more than 50% of their income from government benefits such as Centrelink and whose repayments will exceed 20% of their earnings.

• Are on Centerlink benefits only; age pension excluded; 

• Include any disqualification that may indicate the Product is unlikely to meet the consumer class objectives, financial situation and needs

• Are unemployed;

• Are on overseas visitor and/or on a student visa;

• Want a personal loan longer than 12 months;

• Want more than $2,000, or less than $300.

Distribution Conditions and Restrictions
This section is required under s994B(5)(c).

Distribution Methods

Money Centre’s product may be advertised through the following channels: 

• Campaigns;

• Running across traditional broadcast and digital media to build awareness and drive engagement;

• Digital platforms, including: Paid search (e.g. Google Ads), Social media (e.g. Facebook, Instagram, TikTok);

• Video and audio streaming platforms (e.g. YouTube, Spotify);

• Banner and display advertising on third-party websites.

Distribution Conditions

This product is distributed subject to the following conditions and requirements:

• The distribution conditions, targeted advertising, providing specific content about the Product on the Money Centre website, including lending guidelines, use of staff scripts specific to the Product to individuals that meet eligibility requirements, targeting individuals that have the appropriate borrowing capacity, and providing lending guidelines and training to external Factors Considered

In assessing the appropriateness of the distribution methods, conditions and restrictions, the Issuer has taken into account the following factors:

• The comparatively wide target market for the Product

• The Issuer’s ability to restrict distribution by providing sufficient lending guidelines and eligibility requirements

• The Issuer’s ability to manage the distribution channels

• The capability of existing distribution methods to reach the intended target market, based on past outcomes

Our prospective distribution methods include where Money Centre may consider previous instances where the product was issued through a specific distribution method as part of its assessment to determine the appropriateness of that distribution method
Money Centre is the sole distributor of the product. All customers who apply for a product with Money Centre (whether directly or via a third-party lead referrer) are required to complete an application that is managed in-house. Throughout the loan application process, Money Centre assesses the customer’s eligibility against the identified target market, based on the customer’s needs, objectives, and financial situation. Loan applications are evaluated by our trained staff, and funds are disbursed directly from Money Centre to the approved customer.

Reviewing the TMD
The Issuer will review this TMD as follows:

Review Triggers
This part is required under section 994B(5)(d) of the Act.

If events or circumstances occur that would reasonably suggest that the TMD is no longer appropriate, the Issuer will review the TMD. This may include:

• an event or circumstance that would materially change a factor taken into account in making the target market determination for the Product a change in regulation, a substantial change in government benefits schemes rules resulting in reduced consumer income.

• a material change to the design or distribution of the Product

• a significant dealing in the Product that is not consistent with the product’s TMD

• the nature and extent of any feedback received from distributors or users of the product and significant changes in customer complaints, loan default rates.

• experiencing significant regulatory issues with industry bodies or government entities like ASIC investigations.

Mandatory Review Periods

This part is required under section 994B(5)(e) and (f) of the Act.

The product will be reviewed on an annual basis. The product will also be reviewed if one of the following review triggers are breached.

Distributors: Reporting & Required Information

This part is required under s994B(5)(g) & (h).

Review trigger Trigger methodology

1. Changes to Product Terms 
   If the product terms are adjusted in any capacity (including, but not limited to: loan amount, fee structure, loan term) which causes repayments to be altered within the calendar quarter.
2. Complaints Lodged
   Distributors are required to report and detail in writing all complaints in relation to the Product covered by this TMD to the Issuer every 12 months. In the proportion of “SACC” account holders raising complaints about “Irresponsible lending” exceeds the defined internal threshold within a calendar quarter.
3. Default Rates
   Where the proportion of “SACC” loan contracts that enter delinquency exceeds the defined internal IPF Digital threshold within a calendar month.
4. Hardship Rates
   If the proportion of new “SACC” account holders entering a financial hardship variation exceeds the defined internal IPF Digital within a calendar quarter 
5. Review Period
   An initial review of this Target Market Determination will occur within 12 months and will be reviewed at least every 12 months thereafter. The manager is responsible for initiating the review process at least one month prior to the end of each review period. Currently set to December annually.
6. Information Reporting 
   Below is the required information to be reported in respect to the product. Unless otherwise stated, the first reporting period commences on the date this Target Market Determination is made and each subsequent reporting period commences at the end of the prior reporting period. Reporting specific complaints, recording details of client and the complaint as soon as possible or within 10 business days. We will record the number of complaints as soon as possible or within 10 days. Who is required to report: Manager.
7. Reviewing this TMD
   We will review this TMD in accordance with the below: Last Reviewed March 2026.

Internal review

Annually, from the effective date.

Periodic reviews

At least annually following the last review, with the review completed by the anniversary date of the TMD, irrespective of whether or not a trigger event has occurred in that year.

Review triggers or events

The occurrence of one or more of the following review triggers or events (which reasonably suggest the TMD is no longer appropriate) will prompt us to review this TMD within 10 business days of the date we identify a trigger event: 

• Occurrence of a significant dealing that is required to be reported to ASIC; 

• We identify that the product has caused, or may be likely to cause, consumer harm; 

• The number of complaints (IDR/EDR) 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; 

• The proportion of hardship applications we receive from consumers over total funded loans in a rolling 3-month period is more than 30% greater than that in the prior rolling quarter; 

• The value of the loans that defaults for more than 30 days at the first scheduled repayment exceeds 7% of all loans written in that month, calculated based on a 6-month rolling average;

• The value of the loans within defaults which becomes bad debts (DPD 120+) is more than 5% of our loan book (DPD 120-), calculated based on a 3-month rolling average;

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

• A material change to the design or distribution of the product or the terms and conditions including related documentation;

• A material change in the law, regulator expectations or applicable industry standards that may affect the operation of the product.

[Other information]

Appropriateness of the TMD

This section is required under s994B(5)(c) and s994B(8)(a) &(b).

The Issuer has reviewed the Product and its key attributes by considering its purpose, past outcomes and likely future outcomes, and has reasonably concluded that the Product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market as described above, when offered to the consumer in accordance with the distribution conditions listed above. The comparatively wide target market of the Issuer has been a factor in assessing why the distribution conditions and restrictions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed.

Disclaimer: This suggested template should not be regarded as legal advice but rather as general guidance on the necessary inclusions on the Target Market Determination (TMD) required by the Design and Distribution obligations (incorporated under Ch 7 of the Corporations Act 2001 by the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019). Users should complete the document based on their own products, target market and distribution approach. It is recommended that users obtain financial and/or accounting advice as required.