What is a Target Market Determination?

This Target Market Determination (TMD) sets out the intended market for the credit activities which SmartFee Personal Pty Ltd ABN 44 126 530 489 (Australian Credit Licence number 392210) (SmartFee Personal) intends to engage in, and the conditions placed on SmartFee Personal and its business partners when distributing and promoting its credit products.

We also describe the circumstances in which we may be required to review this TMD, which are referred to as ‘Review Triggers’. For the avoidance of doubt, this TMD does not relate to the commercial/business lending arrangements offered by SmartFee Pty Ltd ABN 70 168 943 486.

Why are we required to have TMDs?

We are required by law to have TMDs. Part 7.8A of the Corporations Act 2001 (Cth) requires us to publish a TMD for any financial products which we distribute to consumers.

When making a decision to utilise our products, customers should read this TMD to ascertain if they fall within the categories of individuals which our credit products are aimed at (our Target Market) and you must refer to the relevant terms and conditions of the ‘Borrower Agreement’/’Invoice Payment Agreement’ (Borrower Agreement) and our other disclosure documents.

Our Target Market

SmartFee Personal aims to assist individuals who engage professional services firms (such as accountants and lawyers) by providing funding to pay invoices issued to them. The funding is intended to reduce the burden of meeting large invoices, so that customers have the ability to engage professional firms and finance the payment of their professional services invoices over a period of time.

The funding allows the customer to pay those invoices over an elected number of instalments, ranging from three to twelve months with the interest rate varying depending on the number of instalments and the amount of funding required.

SmartFee Personal services consumers who are utilising professional services firms for predominantly personal, domestic or household purposes (i.e. not for business purposes). The table below matches the attributes of our credit products to the objectives and needs of our Target Market. SmartFee Personal has determined that the attributes of our product meets the needs and objectives of our Target Market.

Financial Suitability of Target Market

SmartFee Personal aims to assist with fee funding to customers who meet SmartFee Personal’s financial suitability criteria, which require the individual:

• to be solvent;

• to be able to meet their minimum required repayments under the Borrower Agreement without suffering substantial hardship;

• to submit evidence to SmartFee Personal as to their income, assets and liabilities.

Eligibility Criteria for our products

In order to be eligible for this product, the individual will need to satisfy the following criteria:

• be an individual aged 18 years and over;

• have an Australian residential address;

• be an Australian citizen or an Australian permanent resident;

• require fee funding for professional services fees rendered for predominantly personal, domestic or household purposes (i.e. not for business purposes) with a professional services firm that has entered into the relevant fee funding agreements with SmartFee Personal;

• who have met our financial suitability criteria described above.

Distribution Conditions

SmartFee Personal deals strictly through referrals by our partner professional services firms (Partners). We have written agreements with each of our Partners which set out the conditions on which each Partner is able to refer individuals who they have performed services for that may be subject of the invoice funded by SmartFee Personal.

SmartFee Personal retains absolute discretion as to whether to enter into any credit contract with an individual referred to us by a Partner. We ensure that each Partner is appropriately trained to understand the features of SmartFee Personal’s product and they must follow procedures that are prescribed by SmartFee Personal when referring potential customers.

Where an individual is referred to SmartFee Personal, personal information relating to the individual is required to be submitted through our portal to ascertain if the individual meets our eligibility criteria, with that information also submitted by the customer via our portal. The portal uses various criteria and systems when automatically interrogating the information provided by the individual, including collecting evidence of the customer’s ability to meet the repayments required under the Borrower Agreement and conducting credit checks of the customer.

SmartFee Personal’s staff which created and monitor the portal and each Borrower Agreement are able to distribute the products offered by SmartFee Personal, because:

• they are appropriately qualified to understand SmartFee Personal’s eligibility criteria, and our general conduct obligations at law;

• are able to explain to individuals the features, benefits, trade-offs, and key differences between the different options for the products offered by SmartFee Personal;

• are required to follow strict internal procedures when overseeing determinations of suitability made by the portal; and

• are monitored by SmartFee Personal’s responsible manager(s), and are subject to the jurisdiction of the Australian Financial Complaints Authority (AFCA).

Review Triggers

SmartFee Personal is required by law to consistently review the suitability of its products to our Target Market. SmartFee Personal has determined that if any of the following events occur, then SmartFee Personal will undertake a review of this TMD: