Effective date: 2 October 2021

Last updated: 29 January 2024

Prepared by Wagepay Pty Ltd, ABN 15 645 114 629, and its subsidiaries (“we”/”us”/”our”). This Target Market Determination (TMD) is for our Wage Advance product.

What is a TMD?

This TMD describes:

1. the attributes of the product;
2. the class of customers that the product has been designed for;
3. how the product attributes meet the target market needs;
4. the product distribution conditions;
5. review periods for the determination;
6. review triggers for the determination.

Product key attributes

The key attributes of the product are:

• credit amounts ranging from $100 to $2,500.
• credit term of 1 to 32 days.
• a standard fixed credit charge of 5%.
• a standard annual interest rate of 24%
• mobile app and web browser portal.
• transparent, legible and easily understood contract, including financial table and terms.

Target market

The class of consumers that is the target market for the product are consumers who:

• are interested in a short-term loan pending payment of their regular wage;
• need amounts of between $100 and $2,500;
• need to pay for purchases and expenses, which may be regular and on-going, and which, for whatever reason, they cannot pay for these expenses in a given pay cycle from their disposable income;
• are assessed as being able to afford the repayment on the product;
• want the funds quickly;
• want the account setup process to be simple, online, and quick;
• want product terms that are clear and easy to understand;
• want ready access to self-service options and perform customer service requests online;
• are not interested in medium or long product term lengths;

Critical assessment

In making this TMD, a critical assessment must be made to determine how the product meets the needs of the target market.

Distribution conditions

The following conditions apply to how the product is distributed.

Scheduled reviews

We will conduct periodic reviews of this TMD. The product manager will conduct all Design and Distribution Obligation (DDO) reviews and report the results of the review to the board of Wagepay. The report must be provided to the board within two weeks of conducting a review and specify:

1. Trigger events have occurred, if any.
2. Why that event has occurred, if known and if it is attributable to an external source or to the design and distribution of our product.
3. What, if any, action to take in order to ensure compliance with DDO, such as:
   • No change if all is within the parameters published above; or
   • The product needs a redesign;
   • A new distribution condition is required; or
   • The product must cease to be offered

Other review triggers

We will conduct further reviews if a trigger event occurs. The product manager will monitor for the trigger events on a monthly basis. We will review this TMD if the following trigger events occur in relation to this product:

1. One or more terms of the product are altered and we consider that this alteration reasonably suggests that this TMD is no longer appropriate.
2. Feedback, regulatory orders or directions are received from a regulator which suggest this TMD is no longer appropriate.
3. The number of defaults as a percentage of advances increases by 10% in a 3-month period.
4. The number of complaints from approved customers as a percentage of customers increases by 10% in a 3-month period.

Significant dealings

If at any time, we detect that more than 5% of the consumers receiving our product within a three (3) month period are not within our Target Market, we shall report this to ASIC as a Significant Dealing within ten (10) business days.