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: 18 December 2023
Next review due: 18 December 2024
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 [email protected]. 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.
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Objectives and Needs
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Product Attributes
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Require a home loan with a variable interest rate
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The home loan account has a variable interest rate, meaning that
repayments will vary based on changes to the interest rate.
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Require a home loan for any of the following purposes:
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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.
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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.
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Ability to access redraw
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Customers may access any additional repayments made ahead of the loan
schedule at any time. No fees apply.
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Require a loan of $10,000 or more
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The minimum loan amount is $10,000
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Ability to make unlimited payments in excess of the required monthly
repayment amount
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Customers may make additional payments into the loan at any time to save
on interest. No fees apply.
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Ability to view and manage the loan online
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Customers can securely view, manage, and change the loan via the Unloan
website and mobile app.
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Financial Situation |
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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.
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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.
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Distribution Channels
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Conditions that make product distribution through the channel
appropriate
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Proprietary: |
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Online (Unloan website)
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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;
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are provided key information about this product through the
application process; and
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have the ability to discuss this product and their options with
appropriately trained staff.
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In-person or only staff assisted channels (e.g., in branch, solely over
the phone, with a relationship manager or mobile banker)
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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.
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Third Party: |
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Accredited third party brokers
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The product cannot be distributed through third party channels.
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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:
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Information Type
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Description
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Customer Outcomes
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Unexpected trends in customer outcomes which are significantly
inconsistent with the intended product performance, including:
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Early closures of Unloan accounts (within 12 months of funding);
- customers who are in hardship arrangements.
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Complaints
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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:
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distribution (e.g., misrepresentation or mis-selling from staff);
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product suitability (e.g., sale of Unloan Variable Rate home loan to a
customer that prefers the certainty of a fixed rate); and
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product attributes (e.g., customers complaining that an offset feature
is not offered).
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Incident Data
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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.
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Significant Dealings
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Any significant dealing of the product to customers who are outside of the
Target Market.
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Notification from ASIC
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The receipt of a product intervention power order from ASIC requiring CBA
to immediately cease retail product distribution conduct in respect of the
product.
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Changes to the product
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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).
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Review Trigger Information Reporting Requirements
The following information must be provided to Unloan 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 |
Description |
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.
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Quarterly, and in any case no later than 10 business days from the end of the quarter.
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Significant Dealings |
Any significant dealing of the product to customers who are outside of the Target Market.
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As soon as practicable, and in any case, no later than 10 business days after becoming aware.
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Product Issuer: Commonwealth Bank of Australia ABN 48 123 123 124 AFSL and Australian credit license 234945
