UNIPAY FINANCE PTY LTD
Target Market Determination (TMD)
Medium Amount Credit Contracts – Personal Loans
Prepared and published in accordance with the requirements for credit issuers under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.
Product Overview
This product is a Medium Amount Credit Contract (MACC) as defined in Section 204 and regulated by Sections 32A and 32B of the National Credit Code under the National Consumer Credit Protection Act 2009.
Key Features:
- Loan amounts: $2,001 to $5,000
- Loan term: 6 to 24 months
- Interest rate: Up to 47.6158% p.a. (Annual Cost Rate)
- Establishment fee: $400
- Secured or unsecured (secured loans may require a motor vehicle or other asset as collateral)
- Fixed interest rate with equal repayments
- Repayment frequency: weekly, fortnightly, or monthly
- No early termination fees, no balloon payments
Target Market
This loan is suitable for consumers who:
- Are aged 18 to 70
- Are Australian citizens or permanent residents
- Have a stable income and proven credit history
- Have a stable residence
- Can offer security, such as an unencumbered vehicle
- Meet affordability criteria and responsible lending obligations
- Are capable of understanding credit obligations and provide necessary financial documentation
Excluded Consumers
This product is not suitable for consumers who:
- Are bankrupt or under a debt agreement
- Are under 18 or over 70 years old
- Do not have a stable income
- Are not permanent residents or citizens
- Cannot provide required financial information
- Do not understand the nature of a credit contract
Consumer Objectives, Financial Situation & Needs
Likely Objectives:
- Easy and quick online application process
- Fast approval and response times
- Fixed rates with predictable payments
- Flexible repayment frequency
- Access to clear product information
- Minimized financial risk
- A product that meets short-term financial goals
Likely Financial Situation:
- Stable employment income
- Not retired, unemployed, or underemployed
- Good credit history and manageable debt
- Controlled spending, particularly on gambling or Buy Now/Pay Later services
- Bank statements that show no recent financial hardship
- Income that supports both existing commitments and proposed repayments
- No known financial issues that could affect repayment ability
Likely Needs:
A loan between $2,001–$5,000 (plus a $400 fee) for purposes such as:
- Purchasing assets or goods
- Debt or bill consolidation
- Vehicle repairs, travel, weddings, funerals
- Education, home renovation
- Other short-term financial needs
Why This Product Matches the Target Market
This product is simple, transparent, and designed to align with the objectives, financial conditions, and needs of the intended consumers. Key features—like fixed rates, short loan terms, and flexible repayment options—directly support the financial circumstances and preferences of the target market.
Unipay Loans’ distribution model—emphasizing fast, accessible service—enhances compatibility with consumer expectations.
Distribution Method
Unipay Loans distributes the product directly through:
- Online applications and phone-based contact
- Marketing channels such as websites, email, postal mail, social media, and traditional advertising (radio, TV, print)
Loan approvals are finalized by Unipay Loans, which supervises both internal and broker-led distribution with a focus on compliance with the Design and Distribution Obligations.
Distribution Conditions and Restrictions
To ensure the product reaches the appropriate audience, the following conditions apply:
- Strict adherence to this TMD
- All representatives must follow internal loan suitability policies
- Distributors must consider vulnerability, timing, and potential decision fatigue of applicants
- Measures are in place to minimize consumer harm
Why These Conditions Help Prevent Misdistribution
These guidelines are embedded in employment and distributor contracts and are reinforced through regular training and compliance checks. Regular reviews ensure alignment between product features and target market needs.
Review Triggers for Product or TMD
A review will be triggered if:
- There are legislative or regulatory changes
- A significant number of applications are received from consumers outside the target market
- Internal reviews or distributor reports highlight product-market mismatch
- Economic, cultural, or socio-economic shifts affect the target market
- There’s evidence of material harm or poor outcomes
Review Frequency
- Initial review: Within 2 years of publication
- Regular reviews: Every 2 years
- Ad hoc reviews: Within 10 business days of any material concerns being reported to the TMD Manager
If warranted, ASIC will be notified via a Significant Dealing Notification within 10 days.
Additional Early Review Triggers
- Legislative changes
- Surge in default or complaint rates
- Unexpected consumer behaviour
- Deteriorating product performance
- Distribution issues or non-compliance
Complaint Reporting by Distributors
- Monthly reporting by in-house and third-party distributors
- Immediate reporting if complaints appear material or systemic
- Non-representative staff are also encouraged to report issues at any time
Complaint Reporting Format and Detail
Reports should be sent by email to the Responsible Manager/TMD Manager and must include:
- Number and timing of complaints
- Consumer names
- Issue descriptions (with reference to TMD criteria)
- Resolutions and time taken
- Any unresolved complaints
Other Reporting Requirements
Distributors must report any emerging trends, even in the absence of current material complaints, if a future issue may arise without timely intervention.
Significant Dealings
A significant dealing occurs when:
- There’s high demand from outside the target market
- The product is issued to consumers under 18, or non-citizens/permanent residents
- The product is distributed in a way that violates company policy (except where fraud is involved)