This is MYPAYFAST Pty Ltd's (ABN 15 645 258 831) (“MyPayFast”) Target Market Determination in compliance with its Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs). It applies to our salary advance credit contract products.
MyPayFast’s target market is consumers who:
need amounts of between $100 and $750 to assist in paying expenses and managing their cash flow;
want partial access their salary or wages in advance through a simple online application process with easy to understand documents;
are not interested in long or medium loan terms but want short term credit;
can afford the repayments on the product without hardship;
want easy access to customer services to discuss payments, hardship and terms of the contract.
The key attributes of MyPayFast’s products is:
a salary advance for up to 25% of your wages or salary up to a maximum amount of $750;
repayment to be made on the day you receive your wages or salary;
fixed fees of 5% of the salary advance;
simple, legible and easily understood contract documents;
ready access to customer services;
quick and easy on-line application and approval process available through a web based application with only a few steps.
The key attributes of MyPayFasts’s product meet the needs, objectives and financial situations of consumers in its target market because:
the product provides easy access short term salary advance for consumers for to assist them in paying expenses and managing their cash flow;
the loan amounts are closely related to the amounts required by the target market consumers in their loan applications and is limited to 25% of the amount the consumer earns making the repayments affordable and achievable for the consumers;
short terms match the consumers’ needs, requirements and objectives, and financial situation;
the application process is online and can be completed quickly and easily;
the documents are our contract documents concise and easy to understand;
we provide ready access to online customer service via Zendesk and emails;
our limited historical data shows that this product haslow Default rates and few customer complaints and any defaults or complaints are within an acceptable range and indicate that the product is suitable for the target market and is meeting the customer needs, objectives, requirements and financial situations.
All MyPayFast’s Distribution channels present the product appropriately to consumers as follows:
Our website contains only up-to-date and accurate information;
The application process is a short process which seeks the consumers informed consent and ;
All third-party referrers are vetted before being allowed to present our product, subject to regular monitoring and required to enter into referral agreements with us.
We do not make any unsolicited offers for our salary advance product.
Our advertisements contain accurate and plain English information so they are easily understood;
We have adopted the following Voluntary Distribution Conditions to ensure that our product is distributed appropriately to its target market:
No salary advance to any customer whose only source of income is Centrelink Benefits, unemployed or self employed
Customer earns a minimum of $450 per week
Is at least 18 years of age;
MyPayFast will review this determination if the following occurs in relation to theproduct:
The number of defaults in a 3-month period increases by 30%.
The number of complaints from approved customers in a 3-month period increases by 30%.
The responsible manager will collect, assess, and review all the above data every month.
MyPayFast will also respond to external sources such as:
Community based consumer organisations,
by conducting a review of the external communication and why the complaint has arisen.
MyPayFast will conduct quarterly periodic reviews whether or not a trigger event has occurred in the previous quarter.
The responsible manager will conduct all reviews of this determination.
The responsible manager will report to the board of MyPayFast within two weeks of conducting a review as to:
if any trigger events have occurred;
what factors may have caused these trigger events to occur including external factors not related to the design and distribution of our product (i.e. a lockdown relating to a health order);
which of the following actions MyPayFast should take in relation to the product as a result of the trigger events:
no changes if all of the design and distribution obligations above are being met;
the product needs a redesign;
a new distribution condition is required; or
the product must cease to be offered.