Target Market Determination

TMD Determination for Non-Cash Payment Product

Target Market Determination
Product: Prospa Business Account and Visa Debit Card
Non-cash payment product
Issuer Hay Limited ACN 629 037 403 Australia Australian Financial Services License 515459 (Hay Limited)
Start Date: Date the determination was made July 2022
Version: 2.0
Scheduled Review Date: July 2023
Target Market:

Class of consumers that comprise the target market for the product

Consumer Description:

This describes consumers in the target market

Eligibility criteria for the product:

Customers will need to satisfy specific eligibility criteria to maintain this product. Customers must:

  • Be an individual
  • Be aged 18 years or older to apply for the account
  • Have a valid Australian residential address
  • Have been an approved application from Prospa Advance Pty Ltd

Objectives & Needs

This product is targeted at individuals with the likely objectives, financial situation and needs of wanting:

  • Access to a debit card to make purchases with an internationally branded scheme such as Visa
  • To store money in an account without the ability to access interest on their balance
  • To manage access to funds available in the account or on the account through spend limits, merchant blocking and card management

Financial Situation

  • At the time of application, the person has the right to open a Non-Cash Payment product account and has access and the ability to transfer funds in Australian dollars to preload the facility and pay fees.
Product Description:

This describes the non-cash payment product.

  • A Non-Cash Payment Product issued by Hay Limited is a fully digital transaction account that allows retail Clients to access their funds on demand.
  • Access is only possible by card, app, BSB and Account number and does not have a physical presence. Retail clients cannot make cash deposits or other withdrawals from the account via a physical branch except by using a card at an ATM where Visa Debit cards are accepted.
  • No interest can be earned on the funds deposited in the account.
  • Overdrawing the account is not permitted,
  • Spend control and merchant category code limitations:
  • The card program prohibits spending at unsuitable or inappropriate merchants for the Target Market to reduce harm.
  • The card program has limits in place for the account balance and daily spending.
  • Account owners can further restrict spending by a merchant to customise the product to suit their needs.
  • The account owner can impose daily or weekly spending limits to suit the product to their needs.
Appropriateness Statement:

This explains why the product is consistent with the target market’s likely objectives, financial situation, and needs.

The issuer, Hay Limited, has considered that the product is likely to be consistent with the possible objectives, financial situation and needs of the Target Market as:

  • Customers can fund the account to save and or spend those funds through a Debit card accessing the Visa network or through a BSB and Account number via Direct Entry or NPPA; and
  • Customers can manage access to the funds through spend limits, merchant blocking and card management.
Category Description
Distribution Conditions:

The conditions and restrictions on the distribution of the product

Marketing and Promotion

This condition applies to marketing and promotional materials that describe the product

Condition 1

The authorised distribution partner must only market and promote the product as a reloadable Non-Cash Payment Product in Australia.

This condition is suitable as the issuer has distributed this product using these methods, with limited risk to consumers.

Retail Product Distribution Conduct (other than Marketing)

This condition applies to all conduct (other than marketing), such as issuing, arranging, and providing disclosure material.

Condition 2

An authorised distributor must only engage in retail arranging, distribution and

providing factual product advice:

  • through the Prospa Business Account website and Prospa Business app;
  • to prospective small business customers who are individuals and meet Hay Limited’s minimum eligibility criteria for the product; and
  • to issue a Non-Cash Payment Product to retail customers after applying for and completing the application process.
  • This condition is suitable as the issuer has distributed this product using these methods, with limited risk to consumers.
Review Triggers:

The events and circumstances that would reasonably suggest the determination is no longer appropriate

The issuer, and any distributor of this product, must cease retail product distribution conduct in respect of this product when the issuer determines a material event or circumstance has occurred concerning:
Material Complaints Material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.
Product Performance Evidence, as determined by the issuer, of the product’s performance, in practice, may suggest that the product is not appropriate for the target market.
Distributor Feedback Reporting from distributors, or consistent feedback from distributors on the target market, suggesting that the determination may no longer be appropriate.
Substantial Product Change A significant change to the product features outlined in the product description will likely make the determination no longer appropriate for the target market.
A significant change to the product because of regulatory, legislative or code changes will likely result in the determination no longer being appropriate for the target market.
Significant Dealing A material pattern of dealings in the product or distributor conduct is inconsistent with the determination.
Notification from ASIC A notification from ASIC requiring immediate cessation of product distribution or conduct concerning the product.
Review Trigger Information Reporting requirements The distributor of this product must provide the following information to Hay Limited within the below timeframes.
Product Complaints data Information relating to complaints received, including the number and complaint summary details by the distributor of this product and provided quarterly within ten days of the end of the Quarter.
Significant Dealings Any significant dealings of the product to customers who are outside the target market. These should be provided as soon as practicable and no later than 10 business days after the distributor becomes aware.

Note that when printed, this document may have been superseded. Please refer to https://www.prospa.com/target-market-determinations  for the most current version of this document. Hay Limited ACN 629 037 403 Australia Australian Financial Services License 515459 (Hay) effective July 2022

Document Control

Version Date Comments
1.0 5 October 2021 Determination commenced due to the new DDO Regime.

 

2.0 29 July 2022 Template updated to accommodate Shaype Platform Clients where the non-cash payment product is integrated into a platform Client’s product or service.