Target Market Determination – Unregulated Consumer Credit
Legal disclaimer
A Target Market Determination (TMD) is required under section 994B of the Corporations Act 2001 (Cth) (Corporations Act). It sets out the target market for the product, triggers to review the target market and certain other information. It forms part of 1derful’s design and distribution framework for the product.
This document is not a product disclosure statement and is not a summary of the product features or terms of the product. This document does not consider any person’s individual objectives, financial situation or needs. Persons interested in acquiring this product should carefully read the terms and conditions at https://meetbree.com.au/bree-app-terms-conditions/ before deciding whether to buy this product.
Target Market Determination
| Name of product | Bree App |
| TMD date | 24/02/2023 |
| TMD Version | 1 |
| Product description | The Bree App is a digital, mobile app only, product which offers the ability to upload bills, and to have them paid instantly on credit, with the payment amount split over a number of instalments. The tool is aimed at busy people who want to outsource some of the effort in remembering when to pay bills and to help them smooth out their bill payments over regular instalments as well as easing the financial impact. The user chooses an instalment option for repayment, currently 4 equal fortnightly instalments or 8 equal weekly instalments. Upon the due date of each instalment, the instalment amount is automatically debited from the user’s nominated funding source (ie a debit or credit card linked to a bank account). The first instalment is taken prior to the bill being paid. |
| Key product attributes | • Pay Now or pay later in no more than 62 days. • Monthly subscription fee is payable whenever the user has an active subscription, with the first subscription amount being charged when the customer activates the product. • The user can deactivate their subscription and continue to pay down any instalments already created, however can’t continue to upload new bills. • Payment processing fees, where applicable. • There are no late fees, or interest on the Product • Users will have a credit limit, based on a credit assessment of the customer, and will not be able to borrow more than their current credit limit. • The user’s account will be blocked if they default in making scheduled instalment repayments and they will be unable to upload further bills until the account is up to date. • 1derful has readily available assistance for customers in hardship which includes but is not limited to, extended payment plans, and removal of ongoing subscription costs. We also connect users in need with money coaches to help them work through challenging circumstances. |
| Issuer name | 1derful Pty Ltd |
| Issuer ABN | 30 636 589 538 |
| Regulatory status | This product is issued pursuant to the continuous credit exemption under section 6(5) of the National Credit Code. Under section 12BAA of the Australian Securities and Investments Commission Act 2001 (Cth), the provision of credit pursuant to that exemption remains subject to the design and distribution requirements of the Corporations Act. |
Target Market
The Target Market is the class of persons who are the type of customer set out below, who have the needs and objectives set out below and are in the financial situation set out below.
Type of Customer
This product is designed for people who are seeking a product to assist them in paying small bills (between $200 and $1,000) and wish to:
- simplify their bill paying process; and/or
- are looking for flexibility in cashflow management and to smooth payments over a period of time.
- Want to make use of ‘pay on time’ discounts provided by many utility providers.
- obtain credit to immediately pay bills and repay the credit over a short period of time in instalments, without interest or late fees.
- Are looking to earn reward points through their other credit facilities, while not having to pay a surcharge for using credit cards.
These people would have the following features:
- Are comfortable with the simplicity of a digital-only product.
- are Australian residents.
- are at least 18 years old and have the capacity to enter into a legally binding contract.
- will use the credit in their individual capacity for personal use.
- hold a valid and verifiable email address, mobile number and residential address.
Excluded Customers
This product is not suitable for:
- Individuals under 18 years of age.
- Individuals with a history of poor credit, as indicated by credit bureaus, or who do not meet our credit criteria.
- Individuals who intend to use the product only for small payments (given the monthly subscription fee pricing model).
- Individuals who cannot be matched against a credit bureau record.
- Individuals who cannot verify their identity to the satisfaction of 1derful.
- Individuals who do not have a valid and verifiable residential address, email address and Australian mobile number.
- Individuals who are not the holder of a valid and verified Australian-issued debit or credit card attached to a bank account.
- Customers who are not able to access the product through digital means.
Needs and objectives
The customer who is obtaining the product will have the following needs and objectives:
- require a small amount of credit (between $200 and $1,000) to enable them to pay regular bills.
- Would benefit from a product which provides the flexibility of paying automatically using a debit or credit card.
Target Market Appropriateness
1derful considers that the product (including its key attributes) is likely to be consistent with the likely objectives, financial situation and needs of consumers as it provides the means for Consumers to access funds in the form of a short term loan to pay for bills.
Distribution Conditions/Restrictions
The Bree App is distributed solely by Alectura Pty Ltd trading as Bree. Bree may only market and promote the product through:
- advertising through media (including social media), physical marketing materials (such as banners, brochures or flyers) and any other marketing material available to the general public; and
- any other 1derful approved communication channels (including telephone, email and social media).
It has been determined that the distribution conditions and restrictions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed. The distribution conditions are appropriate and will direct distribution towards the target market for whom the product has been designed (for example consumers with digital experience given this product is distributed and administered online).These distribution conditions are supported by 1derful’s application handling processes, which include checks to ensure the consumer is eligible for credit under the Bree App.
Review Triggers
This TMD will be reviewed where 1derful determines that any of the following has occurred:
- ASIC reportable significant dealing outside of TMD.
- Significant or unexpectedly high number of complaints (as defined in section 994A(1) of the Act) regarding product design, product availability or any distribution condition, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.
- Significant or unexpectedly high numbers of missed repayments or bad debt rates being higher than our tolerance.
- Unfavourable reviews of the product
- Material change to key product attributes, terms and conditions, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.
- The use of Product Intervention Powers, regulator orders or directions in relation to the distribution of this product, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.
- A significant breach event relating to the design or distribution of this product, where the product issuer considers this would reasonably suggest that (i) this product is unsuitable for a particular cohort of customers or (ii) the TMD may no longer be appropriate.
| Review periods | Maximum period for review |
| Initial review | 12 months |
| Subsequent review | Every one year from the initial review |
The review period allows for the collection of data for 1 year, plus three months for the completion of the review.
Distributor Information Reporting Requirements
| Regulated person(s) | Requirement | Reporting deadline |
| All distributors | To the extent a distributor is aware of dealings outside the target market these should be reported to the issuer, including reason why acquisition is outside of target market, and whether acquisition occurred under personal advice. | Quarterly * |
| All distributors | Complaints (as defined in section 994A(1) of the Act) where the nature of the complaints relate to product design, product availability and distribution conditions. The distributor should provide all the content of the complaint, having regard to privacy. | Quarterly * |
| All distributors | Significant dealing outside of target market under section 994F(6) of the Act. | As soon as practicable but no later than 10 business days after distributor becomes aware of the significant dealing. |
Other Information
1derful reserves the right to amend the TMD at any time if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance or for any reason 1derful considers as a proper reason to amend the TMD.
If you have any questions about our products or this TMD, please contact us on support@meetbree.com.au or support@1derful.io.