Target Market Determination - Unloan Variable Home Loan

This document describes the type of customers for whom Unloan is most appropriate, and how Unloan is made available to our customers.

At a glance

What is a Target Market Determination?

A Target Market Determination (TMD) describes the cohort of customers that the product is targeted at (the Target Market) and any conditions around how the product is distributed to customers (the Distribution Conditions).

It also describes the events or circumstances where we are required to review the Target Market Determination for a financial product (the Review Triggers).

Start date: 17 May 2022

Next review due: 17 May 2023

Review period: At least every 12 months from the start date of this Target Market Determination.

To save a copy of this TMD, use the print function of your browser. If you’d like a PDF copy, please email We will send this to you free of charge.

Why does Unloan need to have Target Market Determinations?

We’re required to have Target Market Determinations under law. The purpose of the law is to make sure customers are at the centre of our approach when designing and distributing our financial products. This document is not a substitute for the product’s terms and conditions or other disclosure documents.  

When making a decision about this product, customers must refer to the relevant Product Disclosure Statement (PDS), Terms and Conditions or other disclosure documents.

Target Market

The table below matches the Product Attributes to the Objectives and Needs of the Target Market for this product. Unloan has assessed that the product including its Key Attributes are likely to be consistent with the Objectives and Needs of the Target Market.

Objectives and Needs

Product Attributes

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 top up the loan and increase the amount borrowed

Through a top up, customers can borrow an additional $10,000 or more, subject to equity held in your property and our approval.

Ability to view and manage the loan online

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

Financial Situation

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. 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.

Eligibility Criteria for the Product

Customers will need to satisfy certain eligibility criteria, including that customers must: 

  • be individuals 18 years of age or above;
  • hold a current Australian Drivers’ License or Passport;
  • provide sufficient security in accordance with Unloan’s credit assessment criteria, including acceptable residential mortgage.

Applications for home loans are subject to the Unloan’s standard credit approval process.

Distribution Conditions

Unloan will have oversight over how the product is promoted and issued. The product can only be distributed to customers in accordance with Unloan’s product and process requirements. All customers must satisfy Unloan’s credit assessment criteria which demonstrates the customer’s capacity to service the credit facility. In addition, the below table identifies the distribution channels which the product can be sold through and sets out the conditions that apply to each channel. Unloan views that the conditions specified are appropriate and are of a nature that it will be likely that the product will be distributed to the target market.

Distribution Channels

Conditions that make product distribution through the channel appropriate


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.

Third Party:

Accredited third party brokers

The product cannot be distributed through third party channels.

Review Triggers

If any of the below review triggers occur, or if an event or circumstance has occurred that would reasonably suggest that the TMD may no longer be appropriate, Unloan will undertake a review of this TMD:

Information Type


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.


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).

Review Trigger Information Reporting Requirements

The following information must be provided to CBA by all third parties responsible for the retail product distribution conduct of this product in accordance with this TMD, within the required timeframes:

Information Type


Time Frame for Reporting

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.

Product Issuer: Commonwealth Bank of Australia ABN 48 123 123 124 AFSL and Australian credit license 234945