Target Market Determination Document

This is some information about the overview of the
loan process at Direct Personal Loans

Direct Personal Loans Pty Ltd ABN 34 109 721 271

Australian Credit Licence 388081

Target Market Determination Document

How to use this document

The purpose of this document is to provide guidance on completing a Target Market Determination (TMD) to meet the requirements of the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Bill. This document is a prescribed document under the Corporations Act 2001 (CTH) to describe the class of person (the target market) for whom the product was designed. It is not advice.

In using this document consider the nature of the product, including any product variations, and the distribution approach when creating TMD.

Target Market Determination Products

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, 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 Contractual Terms and Conditions and Privacy Policy and any supplementary documents which outline the relevant terms and conditions under the product when making a decision about this product.

This TMD applies to SACC’s and MACC’s referred to and written under the following Direct Personal Loans Policy Documents & Guidelines;  

* Direct Personal Loans Credit Guide Brochure

* Direct Personal Loans Policy Documents & Guidelines

* Direct Personal Loans Privacy Policies

* Direct Personal Loans NCCP Compliance Plan

* Electronic Transactions Act

* National Consumer Credit Protections Act and Enhancements Act

Date from which this target market determination is effective 

5th October 2021

2. Class of consumers that fall within this target market

The information below summarises the overall class of consumers that fall within the target market for SACC’s and MACC’s based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet. The Personal loans is for persons who want the discipline of making regular repayments repayments to repay the total loan balance within a planned term.

These products have been designed for consumers whose likely objectives, financial situation and needs (examples as listed below) are aligned with the product (including the key attributes). 

A SACC and MACC are for those who:

* Are seeking an amount of credit for the purposes of a mechanical expense, registration or insurance, event or outing, household goods or renovations, weddings or funerals, medical or dental, motor vehicle or boat and basically any item that is considered essential or otherwise. A SACC and MACC are a short-term advance to meet a cash shortfall of any kind, for any consumer, of any age over 18 years, providing the application meets a very strict financial analysis under the NCCP Act along with other

regulatory guides the corporation abides to.

Target Market Determination

- Small Amount Credit Contract “SACC” $200 to $2000 from 4 weeks to 52 weeks Under NCCP Act 2009

- Medium Amount Credit Contract “MACC” $2100 to $5000 from 4 weeks to 104 weeks. Under NCCP Act 2009

Product description and key attributes Product description and key attributes

The key eligibility requirements and product attributes of a SACC and MACC are:

* Term of the loan, how interest, fees, charges and repayments are structured for circumstance, and restrictions on type of income and housing and representation arrangements if applicable.

* Product must be not unsuitable, meaning the purpose of the loan must be tangible under the circumstances and the product must meet or contribute to that purpose to derive a benefit to the consumer.

Objectives, financial situation, and needs Objectives, financial situation, and needs

This product has been designed for individuals who:

* Are seeking an amount of credit for the purposes of a mechanical expense, registration or insurance, event or outing, household goods or renovations, weddings or funerals, dental or medical, motor vehicle or boat and basically any item that is considered essential or otherwise. A SACC and MACC is a short-term advance to meet a cash shortfall of any kind, for any consumer, of any age over 18 years, providing the application meets a very strict financial analysis under the NCCP Act along with other regulatory guides the corporation abides to.

* The Personal Loan is not designed for, nor appropriate for loan objectives relating to gambling, alcohol or illegal purposes. 

Excluded class of consumers

This product has not been designed for individuals who:

* Are represented, in hardship of for when hardship looks apparent.

* The product appears to be unsuitable or does not meet the purpose.

* The product does not offer any benefit or advantage to the consumers objectives

* Are unable to meet a suitable financial analysis showing ample expendable income to service the debt without hardship.

* The product is unable to be written without full compliance to the NCCP Act and other guides the company abides to.

Consistency between target market and the product

Consistency between consumer and product is based on need, objectives and financial affordability for each individual and their circumstances. 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

Distribution channels

This product is designed to be distributed through the following means:

*online, contact centres; franchise network; authorised representatives etc…

Distribution conditions

This product should only be distributed under the following circumstances:

* To individuals that meet eligibility requirements; individuals that have the appropriate borrowing capacity, and in accordance with lending guidelines by Direct Personal Loans and under the appropriate regulatory Act’s, Guides and Legislation.

Adequacy of distribution conditions and restrictions

This is based on an assessment of the distribution conditions and restrictions and that they are appropriate and will assist distribution in being directed towards the target market for whom the product has been designed.

4. Reviewing this target market determination

We will review this target market determination in accordance with the below:

Initial review: Within the 1st 12 months of the effective date. 

Periodic reviews: At least every 3 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; and  

* Significant changes in metrics, including, but not limited to, complaints etc.

* Breach of the NCCP Act and Responsible Lending Guidelines.

* Change in legislation.

* Significant numbers of hardship applications with 6 weeks of the loan being issued

Where a review trigger has occurred, this target market determination will be reviewed within 30 business days.

5. Reporting and monitoring this target market determination

We may collect the following information from our distributors in relation to this TMD.

Complaints: Direct Personal Loans and its distributors will report to the issuer (Direct Personal Loans Pty Ltd, Management Team on 0499 540 490 or via email dpl@bigpond.net.au or via our website directpersonalloan.com.au) all complaints in relation to the product(s) covered by this TMD either at that time or on a quarterly basis through systems implemented to capture as such. This will include written details

of the complaints.

Significant dealing: If a substantial amount of distribution is occurring outside the TMD or if distribution outside the target market is causing significant consumer harm) *Direct Personal Loans and its distributors will report to the issuer (Direct Personal Loans Pty Ltd, Management Team) if they become aware of a “significant dealing” that is not consistent with this TMD within 10 business days. The issuer on receipt of these significant dealings will report to ASIC within 10 business days.


Reporting to ASIC on request:  In the event there are no breaches in the review period that require reporting to ASIC, Direct Personal Loans on request from ASIC would provide the terms in which our TMD applies which would determine as there were no Compliance breaches in the reporting period that this would relate to no breached to our Design and Distributions Obligations in that same period, thus nothing to report.



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