Target Market Determination
Branch Loans Pty Ltd

Effective from June 2026

A. Purpose and overview

1. This Target Market Determination (TMD) has been developed to:

  1. 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
  2. assist distributors distribute the Products in a manner consistent with this TMD.

2. The Products include the provision of credit to retail consumers and are subject to the design and distribution obligations regime pursuant to Part 7.8A of the Corporations Act (Cth) 2001 ASIC. Branch Loans Pty Ltd (the Issuer) is a credit provider regulated under the National Consumer Credit Protection Act 2009 (National Credit Act).

3. This TMD applies to the following Branch Loans Pty Ltd credit products (Products):

  1. Cash Loans (Small Amount Credit Contract) - loans from $200 to $2,000;
  2. Personal Loans (Medium Amount Credit Contract) - loans from $2,001 to $4,600
  3. Personal Loans – (All Other Credit) Loans from $4,601 to $8,000

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 and All Other Credit) Personal Loans (All Other Credit)
Likely objectives This Product is likely to be consistent 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.
  • require access to short-term consumer credit for a specific and identifiable purposes (other than for ongoing non-discretionary expenses);
This Product is likely to be consistent with the following likely objectives, financial situation and financial needs:
  • Consumers seeking a medium amount credit contract with fixed repayments and a defined repayment term;
  • Consumers requiring credit for a specific, identifiable purpose rather than seeking finance for non-discretionary ongoing living expenses
  • Short to medium term loans not exceeding 16 months;
  • Loan amounts from $2,001 to $4,600;
  • Consumers seeking some early repayment flexibility.
 This Product is likely to be consistent with the following likely objectives, financial situation and financial needs:
  • Consumers seeking a credit contract with fixed fees and fixed repayments and a defined repayment term;
  • Short to Medium term loans not exceeding 20 months;
  • Loan amounts from $4,601 to $8,000
  • Consumers seeking 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;
  • Consumers with stable income including on welfare benefits;
  • Consumers that may not satisfy the lending history requirements of mainstream lenders;
  • Consumers with differing levels of financial literacy;
  • Consumers who have demonstrated capacity to meet repayments without substantial hardship;
  • Consumers seeking unsecured, fixed-term credit with transparent repayment obligations
  • Consumers seeking an online solution for financing options;
  • Consumers seeking a face to face solution for financing options.
  • Consumers who are able to meet essential living expenses after repayment obligations;
  • The product is not designed to be a substitute for ongoing household income.
 This Product is suitable for a Target Class with the following likely financial situation and needs:
  • Consumers seeking medium amount credit who may not have access to savings to meet a particular purchase or expense in full;
  • Consumers with a regular and stable income stream sufficient to meet repayments without substantial hardship;
  • Consumers who are able to meet non discretionary living expenses after making repayment obligations;
  • Consumers who may not satisfy the lending history requirements of mainstream lenders but who demonstrate repayment capacity;
  • Consumers seeking unsecured fixed-term credit with transparent fees and repayment obligations;
  • Consumers seeking finance with security as an option;
 This Product is suitable for a Target Class with the following likely financial situation and needs:
  • Consumers seeking personal loans over $4,601 who may not have direct access to savings;
  • Consumers who have the ability to repay the loan amount with fees over the medium to longer term;
  • Consumers with consistent income streams sufficient to meet repayments without substantial hardship;
  • Consumers who are able to meet essential living expenses after making repayment obligations;
  • Consumers that may not satisfy the lending history requirements of mainstream lenders but who demonstrate repayment capacity;
  • Consumers with understanding of financial literacy;
  • Consumers applying through online or branch channels who can complete required verification and suitability assessments.
  • Consumers 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 Consumers to elect weekly/fortnightly/monthly repayment terms;
  • Ability for Consumers to make early repayments without penalty;
  • Unsecured loans;
  • Streamlined online loan application process to provide Consumers access to emergency funds conveniently;
  • Ability to transfer loan funds to the Consumer’s account (depending on Consumer’s bank) quickly subject to responsible lending obligations;
  • Fixed application fee of 20% and monthly fee of 4%
  • Upfront and transparent fee structure;
  • Consumers applying through online or branch channels
 This Product contains the following key attributes:
  • Fixed loan terms from 11 months and up to 16 months;
  • Fixed fees and fixed repayments;
  • Ability for consumers to elect weekly, fortnightly or monthly repayment terms;
  • Ability for consumers to make early repayments without penalty;
  • Fixed application fee of $400 and fixed annual credit costs not exceeding 45%
  • Upfront and transparent fee structure;
  • Consumers applying through online or branch channels
 This Product contains the following key attributes:
  • Fixed loan terms from 19 months and up to 20 months;
  • Fixed fees and fixed repayments;
  • Ability for Consumers to elect weekly/fortnightly/monthly repayment terms;
  • Ability for Consumers to make early repayments without penalty;
  • Ability to quickly transfer loan funds to the Consumer’s account (depending on Consumer’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 Consumers to apply for secured or unsecured loans.
  • Consumers applying through online or branch channels
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 who do not receive a regular and verifiable stream of income;
  • Consumers who exceed the cost-of-living expenses criteria (whether for single or joint Consumers);
  • Consumers who are currently bankrupt, subject to a Part IX debt agreement, or in current financial hardship;
  • 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 seeking the product for ongoing living expenses;
  • Consumers displaying indicators of vulnerability, coercion or financial distress that require decline or alternative assistance (see Section B below).
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 who do not receive a regular and verifiable income stream;
  • Consumers who do not meet minimum affordability, expense verification or repayment surplus requirements;
  • Consumers who are currently bankrupt, subject to a Part IX debt agreement, or in current financial hardship;
  • Consumers seeking the product for ongoing living expenses, debt spiraling, repeated refinancing, or where the purpose of credit is unclear;
  • Consumers displaying indicators of vulnerability, coercion or financial distress that require decline or alternative assistance (see Section B below).
Branch Loans Pty Ltd has determined that the Product is not suitable for the following class/type of consumers:
  • Consumers seeking to borrow more than $4,600;
  • Consumers seeking to borrow more than $8,000;
  • Consumers under the age of 18;
  • Consumers who do not receive a regular and verifiable stream of income;
  • Consumers who do not meet minimum affordability, expense verification or repayment surplus requirements;
  • Consumers who are currently bankrupt, subject to a Part IX debt agreement, or in current financial hardship;
  • Consumers who have finance defaults listed after bankruptcy;
  • Consumers with no permanent address;
  • Consumer under a debt consolidation arrangement;
  • Consumers displaying indicators of vulnerability, coercion or financial distress that require decline or alternative assistance (see Section B below).

B. Consumer Vulnerability Controls

Distribution and assessment controls are designed to identify indicators of vulnerability, including:

  • hardship indicators;
  • high-frequency gambling transactions;
  • recent default activity;
  • signs of financial coercion.

Applications identified as presenting elevated vulnerability risk may require enhanced assessment, manual review, additional verification, reduced exposure limits or decline.

C. 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:

  1. Online; and
  2. Branch Loans Pty Ltd Branches.

3. Branch Loans will take reasonable steps to ensure the product is distributed consistently with this TMD, including:

  • implementing automated eligibility controls;
  • monitoring consumer outcomes;
  • conducting periodic compliance reviews;
  • implementing vulnerability escalation processes;
  • reviewing complaint and hardship trends.

4. 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.

D. 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:

  1. Where a significant number of ineligible consumers or consumers out of the Target Class are able to gain access to the Product;
  2. In circumstances where the distribution of the Products described in this TMD are no longer applicable;
  3. 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.

E. Review of TMD

1. This TMD must be reviewed at least every 12 months from the Issue Date, and earlier if a review trigger occurs.

2. Any of the following circumstances shall trigger a review of this TMD:

  1. Where the Product is deemed to no longer be consistent with the likely objectives, financial situation and needs of the Target Group;
  2. Where the distribution conditions of the Product are found to be inadequate and consumers outside of the Target Group are able to regularly acquire the Product;
  3. An external event that would create a material change to the design or distribution of the Product, such as any changes to the legislation;
  4. An occurrence of a Significant Dealing (as set out in section F.3 below);
  5. Where the total percentage of hardship applications is greater than 6% of the total number of loans entered into over that 12 month period;
  6. Where the number of complaints received directly and from distributors about the Product over 12 months is greater than 6% of the total number of loans entered into in the over that 12 month period.
  7. Any other reasonable circumstances which Branch Loans Pty Ltd reasonably believes will warrant a review of this TMD
  8. Any regulatory action or guidance issued by a regulator
  9. A material change to the Product terms and conditions.
  10. Any other reasonable circumstances which Branch Loans Pty Ltd reasonably believes will warrant a review of this TMD.

F. 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:

  1. Provide number of requests for hardship applications;
  2. Provide rates of arrears and defaults;
  3. Provide the number of complaints;
  4. The substance of any complaints;
  5. Reports from distributors of Significant Dealings;
  6. Provide any other relevant information which Branch Loans Pty Ltd determines is relevant and necessary;
  7. 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:

  1. 6 months for the purposes of the TMD for non-complaint related reporting; and
  2. 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

A significant dealing may arise where one or more dealings, or a pattern of dealings, are inconsistent with this TMD and are significant having regard to the proportion of consumers outside the target market, the nature and extent of any actual or potential consumer detriment, and the nature and extent of the inconsistency with this TMD.

  • a material proportion of consumers are outside the target market;
  • actual or potential consumer detriment is identified;
  • systemic distribution failures occur;
  • vulnerable consumers are disproportionately impacted;
  • complaints or hardship rates materially exceed thresholds;

4. The reporting obligations shall apply to the following distributors:

  1. Branch Loans Pty Ltd itself as a distributor;
  2. 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.

G. Governance and Oversight

The TMD is subject to:

  • Delegated committee approval;
  • Periodic compliance review;
  • Annual reassessment;
  • Version control;

Ownership:

  • Chief Executive
  • Compliance Manager
  • Responsible Manager

Issue Date June 2026
Last Review Date December 2025
Next Review Date June 2027