Target Market Determination
Small Amount Credit Contract (SACC)
1.About this document
This Target Market Determination (TMD) has been prepared by Fundo Loans Pty Ltd ACN 604 639 143, Australian Credit Licence 491418 ("Us, We, Our") to comply with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs).
This document sets out the class of consumers for which our product is designed and likely appropriate for (target market), and conditions and circumstances for how the product can be distributed and when it needs to be reviewed. This is to make sure we're keeping consumers at the centre of our approach to the design and distribution of our financial products.
This TMD is not a summary of the terms and conditions of this product and does not constitute financial advice. Consumers should refer to the terms and conditions before acquiring the product to ensure that it is appropriate for their particular objectives, financial situation and needs. It applies to:
Product:
Small Amount Credit Contract (SACC)
Issuer:
Fundo Loans Pty Ltd ACN 604 639 143, Australian credit licence 491418
Effective date:
2 February 2026
2.Target market
Description of the target market
We have assessed that this product is likely to meet the likely objectives, financial situation and needs of consumers who:
- are individuals, at least 18 years of age and meet Fundo's eligibility and lending criteria;
- require credit of $500 to $2,000 for personal purposes to pay for infrequent and sometimes unforeseeable expenses;
- require the loan funds to be promptly disbursed into their nominated bank account;
- require a loan application and approval process which is easy, online and seamless;
- do not require or do not want a long-term loan commitment or access to revolving credit;
- require repayments under the product and any other SACC product to be 10% or less of their net income;
- demonstrates the financial capacity to meet their payment obligations under the loan (i.e. pay the principal repayments and fees for the product when they become due and payable) without substantial hardship;
- may experience difficulty in obtaining credit through mainstream credit providers, such as banks.
We have assessed that this product, including its key attributes, is likely to meet the likely objectives, financial situation and needs of a consumer within the target market because it satisfies all the above criteria.
We consider that this product may not meet the likely objectives, financial situation and needs of a consumer who:
- requires credit for an amount less than $500 or more than $2,000;
- requires credit for the purpose of paying regular, ongoing, ordinary household expenses such as utilities unless it is to pay for accumulated arrears or infrequent amounts due to special circumstances;
- has had 3 or more SACC loans within a 6-month period with us;
- requires a longer-term loan that can be repaid over more than 39 weeks or access to revolving credit; or
- requires funds for business purposes.
3.Product description and key attributes
| Product Attribute |
Details |
| Minimum Loan Amount |
$500 |
| Maximum Loan Amount |
$2,000 |
| Minimum Term |
4 weeks |
| Maximum Term |
39 weeks |
| Interest Rate |
N/A |
| Repayment Frequency |
Weekly, fortnightly, or monthly |
| Fees and Charges |
Establishment fee of 20% of the amount financed; a monthly fee of 4% of the amount financed; and a dishonour fee of $35 per failed repayment. |
4.Distribution conditions and restrictions
Distribution Channels
Distributor Conditions and assessment
| Direct distribution by Fundo |
Fundo Loans distributes the product directly to consumers via an online application form on our website at fundo.com.au or through our mobile app.
Applications are received electronically. The application form includes questions which seek to help us identify whether the applicant falls within the target market for the product. Financial data is verified via applicant-provided access to the applicant's bank account statements. The verified data and application details are assessed against a defined set of credit assessment criteria.
The following factors that are built into our application, assessment and approval process are designed to ensure that our product is distributed to customers within the target market:
- The screening questions that are included in the loan application and which must be completed by the applicant for the application to progress.
- The assessment and approval criteria programmed into our auto assessment system do not allow approval of applications that will place the consumer into financial hardship.
- Our credit analysts who assess loan applications are highly trained professionals who are skilled in determining whether a consumer falls outside the target market parameters.
Where the application satisfies all criteria for approval and the application reveals no indications that the applicant is not within the target market for the product, the application is auto approved by our Loan Management System (LMS).
Where the application fails to satisfy sufficient approval criteria, it is auto declined by LMS. Applications that do not meet the criteria for auto approval or auto decline are then passed to a team of highly trained credit analysts, who assess the application against the business' credit criteria and policies and the product target market to enable them to provide an approval or decline decision.
Our staff are monitored through assurance programs such as sample file monitoring for errors and to ensure we are meeting our regulatory obligations and remain consistent with our internal policies and procedures.
Our website and mobile app contain sufficient information for consumers to enable them to make an informed decision about whether to apply for the product and evaluate whether it suits their needs and objectives. Our distribution channels appropriately present the product by:
- Accurately displaying product and pricing related information;
- Clearly presenting the information relating to a consumer's likely eligibility for the product;
- Comparison examples of two similar products (SACC and MACC) that assist consumers in selecting the right product;
- Information about the products with a summary of key benefits, fees and charges, in an easy to navigate format;
- Not providing false or misleading information; and
- Displaying all relevant disclosures or warnings as required by law.
We have assessed that this distribution channel, including the conditions, is likely to direct distribution of the product to consumers within the target market because it provides clear and straightforward access to the loan approval process, provision of loan funds to approved applicants only without delay and an assessment and approval process that ensures that the loan repayments will not place the consumer in financial hardship.
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| Third Parties |
This product cannot be distributed through third parties. |
5.Reviewing this TMD
We will review this TMD in accordance with the below:
| Initial review |
Annually, from the Effective date. |
| Periodic reviews |
At least annually following the last review, with the review completed by the anniversary date of the TMD, irrespective of whether or not a trigger event has occurred in that year. |
| Review triggers or events |
The occurrence of one or more of the following review triggers or events (which reasonably suggest the TMD is no longer appropriate) will prompt us to review this TMD within 10 business days of the date we identify a trigger event:
- occurrence of a significant dealing that is required to be reported to ASIC;
- we identify that the product has caused, or may be likely to cause, consumer harm;
- the number of complaints (IDR/EDR) we receive from consumers over a 3-month rolling period is more than 20% greater than the number of complaints received in the prior rolling quarter, subject to exceptions for distortions caused by low overall complaint numbers;
- the proportion of hardship applications we receive from consumers over total funded loans in a rolling 3-month period is more than 30% greater than that in the prior rolling quarter;
- the value of the loans that defaults for more than 30 days at the first scheduled repayment exceeds 7% of all loans written in that month, calculated based on a 6-month rolling average;
- the value of the loans with defaults which becomes bad debts (DPD 120+) is more than 5% of our loan book (DPD 120-), calculated based on a 3-month rolling average;
- the average number of loans per customer per year exceeds 6;
- a material change to the design or distribution of the product or the terms and conditions including related documentation;
- a material change in the law, regulator expectations or applicable industry standards that may affect the operation of the product.
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6.Distribution information reporting requirements
We will collect the following information from our distributors who engage in retail product distribution in relation to this product:
| Type of information |
Description |
Reporting Period |
| Complaints |
Details of any complaint during the reporting period including:
- the number of complaints; and
- details of the specific complaint
|
Quarterly, within 10 business days of the end of each period. |
| Significant dealing/s |
Date or date range of the significant dealing/s and description of the significant dealing (e.g. why it is not consistent with the TMD). |
As soon as practicable, and within 10 business days after becoming aware. |
