Target Market Determination - Unloan Variable Home Loan

Require a home loan with a variable interest rate

The home loan account has a variable interest rate, meaning that repayments will vary based on changes to the interest rate.

Require a home loan for any of the following purposes:

• purchasing, refinancing or renovating a residential owner occupied or investment property;

• consolidation of personal debt;

• purchase of land;

• personal needs or personal investments;

• off the plan purchase.

The loan amount can be used for any one or more of the purposes of purchasing, refinancing or renovating a residential owner occupied or investment property; consolidation of personal debt; purchase of land; personal needs or personal investments; off the plan purchase.

Ability to access redraw

Customers may access any additional repayments made ahead of the loan schedule at any time. No fees apply.

Require a loan of $10,000 or more

The minimum loan amount is $10,000

Ability to make unlimited payments in excess of the required monthly repayment amount

Customers may make additional payments into the loan at any time to save on interest. No fees apply.

Ability to view and manage the loan online

Customers can securely view, manage, and change the loan via the Unloan website and mobile app.

The Financial Situation of the Target Market are customers that meet Unloan’s credit assessment criteria which includes:

• Demonstrating the capacity to make the required repayments and the ability to pay off the loan without substantial hardship; and
• Where determined by Unloan to be required, (based on the customers’ deposit size, security, applicant and loan attributes), will pay Lenders Mortgage Insurance.

Unloan views that its processes in place, including assessing the customer’s ability to service the home loan account, will mean that the product will likely be consistent with the Financial Situation of the Target Market.

Online (Unloan website)

The product is distributed through the Unloan website, initiated by the customer and supported by Unloan staff as necessary. The Unloan website provides customers with key information about this product including its product attributes, applicable rate type and fees. Customers have the ability to discuss this product and their options with appropriately trained staff. Unloan will contact the customer if further information or verification is required to complete the product application. Unloan views that origination through this process is appropriate given customers:

• must meet eligibility requirements;
• are provided key information about this product through the application process; and
• have the ability to discuss this product and their options with appropriately trained staff.

In-person or only staff assisted channels (e.g., in branch, solely over the phone, with a relationship manager or mobile banker)

The product cannot be distributed through in-person or only staff assisted channels, however customers may contact Unloan via phone for assistance in completing the online application.

Accredited third party brokers

The product cannot be distributed through third party channels.

Customer Outcomes

Unexpected trends in customer outcomes which are significantly inconsistent with the intended product performance, including:

• Early closures of Unloan accounts (within 12 months of funding);
• customers who are in hardship arrangements.

Complaints

Unexpected trends in complaints received from customers who acquired the product, which relate to the customer’s purchase or use of the product, for example:

• distribution (e.g., misrepresentation or mis-selling from staff);
• product suitability (e.g., sale of Unloan Variable Rate home loan to a customer that prefers the certainty of a fixed rate); and
• product attributes (e.g., customers complaining that an offset feature is not offered).

Incident Data

A material incident or significant number of incidents in relation to the product’s design or distribution that identify breaches of our legal or regulatory obligations.

Significant Dealings

Any significant dealing of the product to customers who are outside of the Target Market.

Notification from ASIC

The receipt of a product intervention power order from ASIC requiring CBA to immediately cease retail product distribution conduct in respect of the product.

Changes to the product

The material alteration of the product or product terms and conditions (e.g. adding to, removing or changing a key product attribute; significant change to distribution channel and distribution strategy).

Product complaints data

Information relating to complaints received including number of complaints, third party distributor identifier information, product name and complaint verbatim.

Quarterly, and in any case no later than 10 business days from the end of the quarter.

Significant Dealings

Any significant dealing of the product to customers who are outside of the Target Market.

As soon as practicable, and in any case, no later than 10 business days after becoming aware.