About this document
This target market determination (TMD) seeks to offer consumers, distributors, and staff with an understanding of the class of consumers for which this product has been designed, having regard to the objectives, financial situation and needs of the target market.
This document is not to be treated as a full summary of the terms and conditions of our personal loan product., which are set out in our loan terms and conditions which are available on request. You must refer to the relevant loan terms and conditions applicable to the product when deciding about whether or not to take a loan from us. Different terms and conditions apply depending on the amount of the loan you take from us.
When we refer to “us” or “we” in this document it is a reference to us, Realty Assist Australia Limited which is the issuer of the personal loan product.
|Name of Product
|Name of Issuer
|Realty Assist Australia Limited trading as ‘VPACollect’ (“Realty Assist”)
|Date of this Target Market Determination
|5 October 2021
|Overview - Description of Target Market and Product
VPACollect is a lending product offered by Realty Assist which offers vendors of residential (and certain commercial) properties access to funding for marketing, furniture styling and cosmetic improvements – known as Vendor Paid Advertising (VPA) – once they have agreed on a marketing schedule with their real estate agent.
The vendor has a choice to pay for these costs up-front or to defer payment of these costs to, where possible, better align the payment obligation for these costs with receipt of the sale proceeds or release of deposit funds. The typical consumer that wishes to use our product is a person who does not wish to pay for the above type of expenses upfront but wish to defer the payment obligation to better align with the receipt of the sale proceeds or release of deposit funds.
The product is a fixed cost short-term credit product used for funding marketing, furniture styling and cosmetic improvements in order to market residential or commercial properties for sale.
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide required documentation and supporting evidence in their application for the product. Unless the lender’s criteria are met, consumers will not be eligible to receive the product.
|Eligibility criteria for our loans
To be eligible for one our loans, you must:
This product is consistent with the needs and objectives of customers who are seeking fast, flexible and short-term finance.
|Exclusion criteria for loans
|We will not give you one of our loans if we determine that you are not in our target market or do not meet our eligibility criteria set out above.
|When we will take security for repayment of the loan
We may ask for security for repayment of the loan at any time. The loan contract gives us this right.
When we take security for repayment of a loan, we do this by registering a mortgage against your property and/or a caveat.
|Consistency between target market and the product
The personal loan products have been designed to suit a wide target market of consumers who require access to a credit facility to assist with maximising the sale price of their property by allowing them to cover the costs associated with preparing and selling their property (excluding large scale structural renovations).
The loan term is consistent with the purpose of the loan and means that the customer is not paying for the loan beyond it’s expected benefit date.
|How we distribute the loan product and who are the Distributors
VPACollect is distributed to property vendors via estate agents who have been appointed as our distributors and also direct to property vendors who submit an application through our digital portal.
Where the product is distributed via real estate agents, then the product is only offered to property vendors who have appointed real estate agents that are clients of Realty Assist.
The method of distribution of the product makes it likely that a customer using the VPACollect product is in the target market and meets our eligibility criteria.
We have distribution conditions in place which are designed to help ensure that our loan product is only sold to consumers in the target market and are likely be consistent with the likely objectives, financial situation and needs of the consumers.
We ensure that:
|Adequacy of distribution conditions and restrictions
We will ensure that:
We will take reasonable steps to ensure that our distribution conditions will, or will be reasonably likely to, result in distribution of our loan product in a manner consistent with this target market determination.
|Timing and process by which we review our Target Market Determination
We will review this target market determination as follows:
|Reporting by Distributors
We require our distributors to report to us within thirty (30) days of the end of each quarter (March, June, September and December) each year and provide us with information about the number of complaints received about the product during the immediately preceding quarter.
We require our distributors to report to us within thirty (30) days prior to the Initial Review, each Periodic Review and each Annual Review as detailed above on matters specified by us.
We require our distributors to report to us within seven (7) days if they receive any complaints about the product.
|Description of events which constitute a “Trigger Event”
A trigger event is any event or circumstance that should objectively give rise to a reasonable belief on our part that this Target Market Determination is no longer appropriate having regard to a variety of factors, including (but not limited) to any of the following:
|Annual Review Event
The following matters constitute an annual review event but do not of themselves necessarily indicate that a trigger event has occurred, namely an event or circumstance has occurred that reasonably suggests that the TMD is no longer appropriate. The occurrence of the following events may merely indicate a change in economic circumstances. However, an annual review of the following matters is to be conducted to determine as accurately as possible the underlying cause of the event. The annual review events are:
|Availability of this Target Market Determination
We will ensure that this target market determination is made available on our website and available to prospective consumers prior to distribution of this loan product.