Target Market Determination (TMD)
Branch Loans Pty Ltd
Effective from May 2025
A. Purpose and overview
1. This Target Market Determination (TMD) has been developed to:
-
assist consumers ( (as that term is defined in section 5 of the National Consumer Credit
Protection Act 2009) within the Target Class (as defined below), obtain suitable financial
Products having regard to their ‘likely objectives, financial situation and financial needs’, and
- assist distributors distribute the Products in a manner consistent with this TMD.
2. The Products include the provision of credit to retail consumers pursuant to Div 2 of Pt 2 of the
Australian Securities Investments Commission Act 2001 (ASIC Act). Branch Loans Pty Ltd (the
Issuer) is therefore a credit provider and is regulated under the National Consumer Protection
Act
2009 (National Credit Act).
3. This TMD specifically covers the following Branch Loans Pty Ltd products (Products):
- Cash Loans (Small Amount Credit Contract) - loans from $200 to $2,000;
- Personal Loans (Medium Amount Credit Contract) - loans from $2,001 to $4,600
4. This document is not a full summary of the Products’ terms and conditions contained in the customer
terms issued by Branch Loans Pty Ltd (and any supplementary documents), nor is this TMD intended
to provide financial product advice
TARGET CLASS |
Product |
Cash Loans (Small Amount Credit Contract) |
Personal Loans (Medium Amount Credit Contract) |
Likely objectives |
This Product is suitable for borrowers with the following likely
objectives, financial situation and financial needs:
- Fixed monthly repayments;
- Short term loans of no more than 12 months;
- Loan amounts not exceeding $2,000;
- Some early repayment flexibility.
|
This Product is suitable for borrowers with the following likely objectives, financial situation and
financial needs:
- Borrowers looking for loan products with fixed
fees, fixed interest and fixed repayments;
- Short to medium term loans not exceeding 16
months;
- Loan amounts from $2,001 to $4,600
- Some early repayment flexibility.
|
Likely financial situation and needs |
This Product is suitable for a Target Class with the following
likely financial situation and needs:
-
Access to smaller loan amounts on a short-term basis
to meet emergencies or other unexpected liabilities;
- Borrowers with differing levels of repayment
abilities;
- Borrowers with stable income including on welfare
benefits;
- Borrowers that may not satisfy the lending history
requirements of mainstream lenders;
- Borrowers with differing levels of financial literacy;
- Borrowers with a range of personal needs;
- Borrowers who have the ability to repay the loan
amount with fees;
- Borrowers seeking unsecured lending;
- Borrowers seeking an online solution for financing
options;
- Borrowers seeking a face to
face solution for financing options.
|
This Product is suitable for a Target Class with the following
likely financial situation and needs
-
Borrowers seeking medium amount loans who
may not have access to savings to meet the
purchase price of goods and services in full;
- Borrowers with differing levels of repayment
abilities
- Borrowers with stable income including on welfare
benefits
-
Borrowers who have the ability to repay the loan
amount with fees over the shorter to medium
term;
- Borrowers that may not satisfy the lending history
requirements of mainstream lenders;
- Borrowers with developed levels of financial literacy;
- Borrowers seeking an online solution for
financing options;
- Borrowers seeking a face-to-face solution for
financing options
- Borrowers seeking finance with security as an
option;
|
Key Product Attributes |
This Product contains the following key attributes:
- Fixed loan terms from 2 months and up to 12
months
- Ability for borrowers to elect
weekly/fortnightly/monthly repayment terms;
- Ability for borrowers to make early repayments
without penalty;
- Unsecured loans;
-
Streamlined online loan application process to
provide borrowers access to emergency funds
conveniently;
-
Ability to transfer loan funds to the borrower’s
account (depending on borrower’s bank) quickly
subject to responsible lending obligations;
- Fixed application fee of 20% and monthly fee of 4%
- Upfront and transparent fee structure;
|
This Product contains the following key attributes:
- Fixed loan terms from 11 months and up to
16 months
- Fixed charges;
- Ability for borrowers to elect
weekly/fortnightly/monthly repayment terms;
- Ability for borrowers to make early repayments
without penalty;
-
Ability to quickly transfer loan funds to the
borrower’s account (depending on borrower’s
bank) subject to responsible lending criteria;
- Fixed application fee of $400 and fixed credit fee
structure of 45%
- Upfront and transparent fee structure;
- Ability for borrowers to apply for secured or
unsecured loans.
|
Ineligible/excluded class of consumers |
Branch Loans Pty Ltd has determined that the Product is not
suitable for the following class/type of consumers:
- Consumers seeking borrow more than $2,000;
- Consumers under the age of 18;
- Consumers not receiving a regular stream of
income;
- Consumers who do not meet the minimum take
home income or benefits requirements;
-
Consumers who exceed the cost-of-living expenses
criteria (whether for single or joint borrowers);
- Consumers who are currently bankrupt or in a Part IX
debt agreement;
- Consumers who have finance defaults listed after
bankruptcy;
- Consumers with no permanent address;
- Consumer under a debt consolidation
arrangement;
- Consumers seeking to refinance existing loans
into a new loan;
- Consumers in hardship
|
Branch Loans Pty Ltd has determined that the Product is
not suitable for the following class/type of consumers:
- Consumers seeking to borrow less than $2,001;
- Consumers seeking to borrow more than $4,600;
- Consumers under the age of 18;
- Consumers not receiving a regular stream of
income;
- Consumers who do not meet the minimum take
home income or benefits requirements;
-
Consumers who exceed the cost of living expenses
criteria (whether for single or joint borrowers);
- Consumers who are currently bankrupt or in a Part
IX debt agreement in the last 12 months;
- Consumers who have finance defaults listed after
bankruptcy;
- Consumers with no permanent address;
- Consumer under a debt consolidation
arrangement;
- Consumers in hardship;
|
B. Conditions and restrictions on distribution
1. Branch Loans Pty Ltd has determined that based on the Products’ key attributes, the Products have a
fairly broad target market.
2. The Products are distributed through the following channels:
- Online; and
- Branch Loans Pty Ltd Branches.
3. If Branch Loans Pty Ltd or its distributors become aware that the distribution conditions outlined in
this TMD are no longer adequate such that consumers outside of the Target Class are able to gain
access to the Products, this TMD shall immediately be reviewed
C. Events and circumstances likely to suggest this TMD is no longer appropriate for the Target
Class
Branch Loans Pty Ltd has determined that the following events and circumstances will make the
Products no longer appropriate to the Target Class:
-
Where a significant number of ineligible consumers or consumers out of the Target Class are able
to gain access to the Product;
-
In circumstances where the distribution of the Products described in this TMD are no longer
applicable;
-
Where Branch Loans Pty Ltd determines the Products are no longer appropriate having
regard to the objectives and financial circumstances and needs of the Target Class.
D. Review of TMD
1. This TMD shall be reviewed periodically at least every 6months from the date of the Initial Review
Date.
2. Any of the following circumstances shall trigger a review of this TMD:
-
Where the Product is deemed to no longer be consistent with the likely objectives, financial
situation and needs of the Target Group;
-
Where the distribution conditions of the Product are found to be inadequate and consumers
outside of the Target Group are able to acquire the Product;
-
An external event that would create a material change to the design or distribution of the
Product, such as any changes to the legislation;
- An occurrence of a Significant Dealing (as set out in section E.3 below);
-
Where the total percentage of hardship applications is greater than 3% of the total number of loans
entered into over that 6 month period;
-
Where the number of complaints received directly and from distributors about the Product over
6 months is greater than 3% of the total number of loans entered into in the over that 6 month
period;
-
Any other reasonable circumstances which Branch Loans Pty Ltd reasonably believes will
warrant a review of this TMD.
E. Reporting obligations and continuous monitoring of this TMD
1. To ensure that the Product meets the reporting obligations set out under the ASIC Regulations Guide
274, Branch Loans Pty Ltd requires its distributors to:
- Provide number of requests for hardship applications;
- Provide rates of arrears and defaults;
- Provide rates of early payout;
- Provide the number of complaints;
- The substance of any complaints;
- Reports from distributors of Significant Dealings;
-
Provide any other relevant information which Branch Loans Pty Ltd determines is relevant and
necessary;
-
Provide general feedback as to whether the Product continues to be suitable for the specific
target market outlined in this TMD.
2. All distributors are required to report to Branch Loans Pty Ltd in accordance with the
following reporting periods:
- 6 months for the purposes of the TMD for non-complaint related reporting; and
- 2 Business Days in respect of a complaint
3. For the purposes of this TMD, a “Significant Dealing” shall mean any of the following
occurrences in relation to consumers outside of the target class acquiring a loan
The dealing is significant because it constitutes a transaction which has resulted in, or will or is likely
to result in, significant detriment to the customer because the distribution of the Product results in
more than 5% of customers outside the Target Class being issued the Product
4. The reporting obligations shall apply to the following distributors:
- Branch Loans Pty Ltd itself as a distributor;
- Branch Loans Pty Ltd Branches;
5. All complaints received by distributors in relation to this Product (including those in written form) will be
reviewed immediately upon receipt of the complaint.
6. Branch Loans Pty Ltd is required to notify ASIC of any Significant Dealings within 10 business days.
Issue Date May 2025
Last Review Date May 2025
Next Review Date November 2025