Target Market Determination
1. 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 for and its main attributes, 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 product’s terms and conditions and is not intended to provide financial advice. Consumers must refer to the relevant terms and conditions when making a decision about this product.
Terms and Conditions to which this TMD applies
This TMD applies to the Snaffle Subscription, Line of Credit and Sale of Goods by Instalments (Snaffle Subscription) referred to in the following Terms and Conditions:
Snaffle Subscription Terms and Conditions
Date from which this TMD is effective:
5 October 2021
2. Class of consumers that is the target market
The information below summarises the overall class of consumers that is the target market for Snaffle Subscription based on the product key attributes and the objectives, financial situation and needs of the target market with respect to which this Snaffle Subscription as a financial product was designed for.
This Snaffle Subscription has been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the product (including the key attributes). The class of consumers the Snaffle Subscription is designed for is:
A consumer who for personal and or financial reasons may not be able to or is unwilling to acquire goods or services by paying for these goods or services upfront and whose objectives to acquire goods or services by paying for these by instalments is met by;
The consumer applying and obtaining a line of credit that is solely used for the purchasing of goods and or services;
The goods or services are used predominantly for domestic household purposes;
The consumer being approved under the Snaffle Subscription terms and conditions for a Snaffle Wallet®;
The line of credit in the Snaffle Wallet can be used by the consumer, at their discretion, for the purchase of goods and or services from approved merchants;
The line of credit is the maximum amount that the consumer can utilise to acquire goods and or services with fixed monthly repayments depending on the term the consumer applied for;
Once the consumer pays part or the whole of the credit utilised to acquire the goods and or services, the consumer will be able to use the available credit to acquire additional goods and or services to the value up to the approved credit limit;
Product description and key attributes
The key eligibility requirements and product attributes of this Snaffle Subscription are:
that an Applicant must be a subscriber to Snaffle, reside in Australia, be at least 18 years of age, have a consistent and ongoing form of income, provide a verifiable form of identification, meet Snaffle Subscription lending criteria including providing information and substantiation of their financial situation, income and expenses as well as objectives (responsible lending obligations) and agree to the Snaffle Subscription terms and conditions.
that an Applicant will establish a line of credit with a maximum monthly credit limit in their Snaffle Wallet to be used to purchase goods and services where the Snaffle Wallet is accepted and pay by instalments over a fixed term with repayments due monthly by direct debit.
the available credit in the Snaffle Wallet can be used for additional purchases that is within the credit limit or as the debt is reduced.
interest is charged on the total purchase price of the goods and services obtained in the Purchase of Goods by Instalments agreement for a fixed term with additional fees and charges limited to dishonouring a direct debit payment, duplicated documents, paper statements and enforcement expenses.
If the consumer does not use the Snaffle Subscription line of credit, the consumer will not be charged.
a security is taken over the acquired goods as prescribed by the National Consumer Credit Protection Act 2009 (Cth) and or registered under the Personal Property Securities Act 2009 (Cth) or depending on the goods and or services acquired, the consumer may be asked to pay a deposit.
Objectives, financial situation, and needs
This product has been designed for individuals who for personal and or financial reasons is not able or not willing to acquire goods and or services by paying for those goods and or services upfront and who:
need credit to obtain goods and services where the Snaffle Wallet is accepted;
with the objective to have access to a line of credit that they can use now, in the future or reuse as the debt is reduced and pay by instalments over a fixed term at a fixed interest rate;
are able to pay the instalment amount over their chosen periodical period based on the assessment of their financial situation that we complete, and the Applicant agrees with, to establish the line of credit in their Snaffle Wallet; and,
are agreeable to provide security in the goods or depending on the goods and or services provide a deposit for the amount required by Snaffle.
Consistency between target market and the product
This product is likely to be consistent with the likely objectives, financial situation and needs of the class of consumer in the target market. This is based on an analysis of the key terms, features and attributes of the product and a finding that these are consistent with the identified class of consumers.
3. How this product is to be distributed
This product is designed to be distributed through the following means:
This product should only be distributed under the following circumstances:
to individuals that meet eligibility requirements; have the appropriate borrowing capacity, and in accordance with the credit criteria.
Adequacy of distribution conditions and restrictions
The distribution channels and the product attributes and terms and conditions will ensure that consumers who purchase the Snaffle Subscription are the designated class of consumers for which it has been designed for. This is based on an assessment of the distribution channels, product attributes and terms and conditions and restrictions and the assessment that they are appropriate and will assist the distribution being directed towards the target market.
4. Reviewing this TMD
We will review this TMD in accordance with the below:
Within 6 months of the effective date.
At least every three years from the initial review.
Review triggers or events
Any event or circumstances arise that would suggest the TMD is no longer appropriate. This may include (but not limited):
a material change to the design or distribution of the product, including related documentation;
occurrence of a significant dealing;
distribution conditions found to be inadequate;
external events such as adverse media coverage or regulatory attention;
changes in regulatory environment;
customer feedback; and
significant changes in metrics, including, but not limited to, customer queries, complaints, defaults and terminations.
Where a review trigger has occurred, this TMD will be reviewed within 10 business days.
5. Reporting and monitoring this TMD
We may collect the following information from our distributors in relation to this TMD.
Distributors will report all complaints in relation to the product(s) covered by this TMD on a quarterly basis. This will include written details of the complaints.
Distributors will report if they become aware of a significant dealing in relation to this TMD within 10 business days.