TARGET MARKET DETERMINATION

ABOUT THIS DOCUMENT

SwiftCash takes a customer-centric approach in the design and distribution of our products. We want to ensure that our customers are obtaining the financial products that are appropriate for their specified requirements, objectives and needs.

This document should not be treated as a substitute for a full summary of product terms and conditions. We encourage all customers to consider the full terms and conditions of the product before making a decision.

What is a Target Market Determination?
A Target Market Determination (TMD) describes the type of customers that a financial product is targeted at (Target Market) and any information relating to the distribution and review of the product. It ensures that financial products are appropriately designed for, and marketed to, the target market.

TARGET MARKET

Product Description

In order to be eligible for a SwiftCash personal loan, at a minimum, consumers must:

  • be an Australian Citizen or Permanent Resident;
  • have an Australian residential address;
  • be at least 18 years of age;
  • be employed with a level of income which supports the affordability of the product under responsible lending criteria;
  • pass the SwiftCash credit assessment criteria.

The product has been designed for customers who:

  • Desire a fixed rate loan for a significant personal expense or other eligible purpose as outlined in our credit policy;
  • Want a fixed term from 2 to 24 months;
  • Want a completely online application and approval process;
  • Want a choice of weekly, fortnightly or monthly repayment frequency;
  • Require certainty around the loan repayments and frequency; and
  • The ability to make extra repayments without charge.

Objectives, Financial Situation and Needs

The SwiftCash online application process asks a series of questions to ensure a SwiftCash Personal Loan will most likely be consistent with the consumer’s objectives, financial situation and needs.

Specifically, SwiftCash ensures consumers have a need or objective satisfied by:

  • a loan for an amount between $2,050 and $8,000;
  • a preference for a loan term between 2 and 24 months;
  • a preference for a completely online means of applying, managing and accessing credit;

AND, are in a financial situation where they can:

  • afford loan repayments without substantial financial hardship;
  • are employed with a reliable income;
  • demonstrate an ability to meet repayments including current debt commitments; and
  • satisfy the SwiftCash credit assessment criteria.

Excluded Class of Consumers

This product has not been designed for persons who are not individuals (for example, a company), or individuals who:

  • are temporary Australian residents or visitors;
  • are under the age of 18;
  • require a loan for an amount less than $2,050 or more than $8,000;
  • require a continuing line of credit;
  • are seeking funds for illegal purposes; 
  • are seeking funds for everyday living expenses, that is, expenses that one would not typically save for; 
  • are unemployed or source a majority of their income from government benefits;
  • are unable to satisfy SwiftCash’s affordability, creditworthiness and/or income requirements; 
  • are at risk of substantial hardship under current circumstances; and/or
  • require a loan for flippant or hazardous purposes (such as gambling).

PRODUCT DISTRIBUTION

Distribution Conditions and Channels

All applications for a SwiftCash Personal Loan can only be made directly via the SwiftCash website, with assistance from SwiftCash support staff if necessary. Our minimum eligibility form filters out all customers who do not meet our minimum eligibility requirements. The online application process asks a series of questions that are designed to gather sufficient information to determine that approved customers will likely fall within the target market. Customers should answer all online questions accurately and if unsure of what a question means get in touch with SwiftCash support.

SwiftCash distributes the Personal Loan product via online channels and referral programs. SwiftCash has selected keywords to help drive online search engine results towards those consumers most likely to be eligible for a SwiftCash Personal Loan. SwiftCash also may distribute the product via referral programs with partner organisations. These partner organisations receive training on the eligibility criteria and other information to ensure referred consumers are likely to fall within the target market.

Adequacy of distribution conditions and restrictions

The class of consumers directed to the SwiftCash website are likely to fall within the target market given the distribution network.

This assessment is supported through the education of any referral providers on the consumers likely to be eligible for a SwiftCash personal loan. That is, consumers who require a completely online solution to access a personal loan for the purposes of debt consolidation or some other purpose.

SwiftCash, as the issuer, will in its sole discretion then determine both the eligibility and appropriateness of the personal loan and if it meets the consumers requirements and objectives. 

REPORTING AND MONITORING

Review

SwiftCash has processes in place to monitor the effectiveness of this TMD. Constant monitoring and subsequent reviews are integral in ensuring the product design and distribution is meeting the requirements, objectives and needs of the intended target market.

SwiftCash will collect information to determine if a review trigger or other event would suggest that the TMD is no longer appropriate and should be reviewed. This information will include but is not limited to customer complaints, loan volumes, default rates and reviewing any circumstances where a loan was provided contrary to the TMD.

The below table outlines when this TMD will be reviewed and under what conditions.

Initial review
  • 3 months after the date this TMD was put into place (4th October 2022)
Periodic review
  • At least every 12 months
Last review
  • 15th January 2024
Review triggers and events
  • Material change to the design or distribution of the product, including changes to the terms and conditions applicable to this product;
  • Changes to laws and regulations that apply to this product;
  • A significant dealing in the product is identified which is not consistent with the target market determination is identified in over 5% of customers in any given calendar quarter based on specific complaint information;
  • Different ways of distributing the product are introduced;
  • Adverse feedback from external stakeholders on the design or distribution of this product from ASIC, AFCA or otherwise communicate to us that they have identified a systemic issue or if the number of complaints referred exceeds 15 in any given calendar quarter;
  • Total number of hardship applications received from funded customers exceeds 5%;
  • The total outstanding balance of payments more than 14 days overdue as a percentage of total amount originated is greater than 15% in any given calendar quarter;
  • The number of funded complaints received from customers as a percentage of total funded loans is greater than 5% in any given quarter;
  • An external event such as negative media coverage or regulatory attention.

In the occurrence of a review trigger or event, SwiftCash will review this TMD no later than 10 business days after becoming aware.

Complaints and Significant Dealings

Specific complaints will be reported on as soon as practicable and within 10 business days of receipt of complaint. Reporting will capture the name and contact details of the complainant and the substance of the complaint.

Complaint reports will be conducted quarterly outline the number of complaints in each calendar quarter.

Significant dealings will be reported on as soon as possible and no longer than 10 business days after becoming aware. The significant dealing date and description of why it was not consistent with the TMD.

All complaints can be forwarded to support@swiftcash.com.au.

Main Information

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