Target Market Determination
Vield Personal Loan
This Target Market Determination (TMD) has been prepared in accordance with the Pt 7.8A of the Corporations Act (Cth) 2001 and its related regulations and regulatory guidance. TMDs are designed to assist:
- issuers to ensure that the financial products they design and issue are likely to be consistent with the objectives, financial situation and needs of the consumers for whom they are intended (the Target Market);
- issuers and distributors to ensure that they take reasonable steps to ensure that the financial products are distributed to the Target Market; and
- issuers to monitor consumer outcomes and review products to ensure that consumers are receiving financial products that are likely to be consistent with their likely objectives, financial situation and needs.
General Disclaimer
This TMD is general in nature and should not be construed as financial advice. Consumers should obtain independent advice prior to acquiring the product to ensure that it is appropriate for their specific objectives, financial situation and needs.
Product
Vield Personal Loan
Issuer
LSL Alternative Credit Pty Ltd (ABN 55 641 811 181), Australian
Credit Licence No. 526970.
Distributor
Vield Capital Pty Ltd (ABN 38 672 205 113) a credit
representative of the Issuer, with credit representative
number 553950
| Product | Vield Personal Loan |
|---|---|
| Issuer | LSL Alternative Credit Pty Ltd (ABN 55 641 811 181), Australian Credit Licence No. 526970. |
| Distributor | Vield Capital Pty Ltd (ABN 38 672 205 113) a credit representative of the Issuer, with credit representative number 553950 |
| The Product is designed for consumers who: | Key terms and attributes of the Product that make it appropriate to the Target Market |
|---|---|
| (a) Meet the following eligibility criteria: (i) are 18 years old or older; (ii) are employed on a full-time, part-time, or casual basis; and (iii) are a temporary, permanent resident or citizen of Australia. | Cell |
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Target Market
The Product is designed for consumers who:
consumers who:
(a) Meet the following eligibility criteria:
(i) are 18 years old or older;
(ii) are employed on a full-time, part-time, or casual basis;
and
(iii) are a permanent resident or citizen of Australia.
(b) Are seeking one or multiple small to
medium value secured loans, for a short,
fixed term
(c) Are seeking a secured loan for personal
or domestic use
(d) Own highly liquid virtual assets and are
willing to use these assets as security for
the loan.
(e) Require certainty on their repayments
and interest, with limited flexibility on
early repayments;
(f) are able to complete online applications
and use mobile software applications;
and.
(g) can demonstrate the ability to repay the
loan
Key terms and attributes of
the Product that make it appropriate to the Target Market
Eligibility the loan will not be suitable for
consumers who do not meet this eligibility
criteria. Accordingly, The Distributor will only offer
the loan to consumers who meet the eligibility
criteria.
Loan Amount a loan amount of at least $2000
and up to $250,000.
Term a fixed 12-month period.
Multiple Loans a customer may request multiple
loans, limited to 3.
Maximum Loan Amount customers will be
limited to a maximum loan amount of 50% of the
total Security Assets they provide as security for
each loan.
Intended Use customers are required to
acknowledge and agree that the loan is intended
to be used for personal and domestic use.
Security customers will be required to provide
liquid virtual assets (see below) as security for
the loan.
Security Assets customers must have highly
liquid virtual assets (i.e. ETH, BTC or USDC) and
transfer those assets in a wallet held by the
Distributor. These assets will be used as security
for the loan.
Interest Rate Interest is calculated daily on the outstanding loan balance and is compounded daily.
Fees include
2% Origination Fee on each loan and every subsequent loan if a user successfully applies for another loan
Repayments customers are able to repay the loan at anytime but will be required to make make regular, scheduled interest-only repayments quarterly to pay down the loan balance over the term as stipulated in Loan Agreement
Early Repayments customers are able to make
early repayments, but must agree to paying the early-repayment fee as stipulated in Loan Agreement.
No Redraws customers are not able to access any extra repayments that have been made to the loan in excess of their scheduled repayments.
Online process applying and managing this loan
will be online and through mobile application.
Affordability and suitability assessment The
Distributor’s online and mobile application form
will require the consumer to provide information.
The Distributor will assess this information
against its affordability and suitability criteria to
ensure that the loan is suitable for the
consumer’s needs and objectives and that the
consumer can repay the loan.
Customers who may be unsuitable for this Product
This Product may be unsuitable for people:
- who lack a fundamental understanding of virtual assets and the inherent market risks may not be able to make the right decisions concerning virtual asset-backed loans.
- with a low tolerance for risk, particularly if they cannot afford the potential market fluctions in the value of their virtual assets, virtual asset markets are notably unpredictable, and such fluctuations can result in the need to liquidate the security if not carefully monitored.
- who are not in a financially stable position or who already have a large amount of debt. Additional financial responsibilities, particularly those secured by virtual assets, may worsen their financial hardship.
- with an unstable or irregular income may find the repayment demands of a loan challenging to meet.
- who do not have income or enough assets to be able to sevice the loan.
- who are unable to maintain the necessary Loan-to-Value (LVR) ratio due to the volatile nature of their virtual assets may find themselves ineligible for the loan amount they desire.
- without a definitive and clear repayment strategy, which includes managing interest and returning the principal, should contemplate the potential risks of this Product.
- who wish to actively trade their virtual assets or use it for some other purpose, as the loan must be fully repaid before the virtual assets can be accessed again.
Distribution Conditions and Restrictions
The following conditions and restrictions to the distribution of Vield Personal Loans will apply so that the product is likely to be provided to customers
in the Target Market.
These conditions and restrictions:
- limit the channels through which the product can be provided;
- ensure the Distributor is adequately trained, monitored and accredited; and
- ensure the product is distributed in accordance with a consistent process.
Condition
Appropriateness of distribution
Channel
The Product will be distributed by
the
Distributor, direct to the customer,
through the following channels:
•
the Distributor’s mobile
applications (both Android and
iPhone);
•
The Distributor's web
application and website;
•
through requests received
from the Distributor’s website.
It has been assessed and
considered appropriate for the
Distributor to be the exclusive
distributor of the Product.
Accordingly, limiting the
distribution
channel to one distributor, will
ensure that:
•
marketing is directed at
customers who fit within the
Target Market;
•
processes are in place to
ensure that products are only
distributed to customers who
fit within the Target Market;
and
•
the Product is suitable for a
relatively narrow Target Market;
•
The required information is
collected from customers to
assess whether customers are
in the Target Market;
•
training, monitoring and
controls will be simple to
implement.
Training,
monitoring and
accreditation
The Product will only be provided
to customers by exclusively
through the
Distributor who will:
•
effect and maintain the
relevant licenses;
•
be trained by the Issuer; and
•
have its distribution activities
reviewed and monitored by the
Issuer.
Training, monitoring and
accreditation standards will
ensure the Distributor:
•
will undergo background
checks on key personnel;
•
complies with all relevant
law relating to distribution of
the Product; and
•
Adopt distribution
practicespractices in
accordance with the Issuer’s
own policies and standards.
This will ultimately enable the
Distributor to assess customer
requests and determine whether
they are in the Target Market.
Distribution
process
The Product will only be distributed through the Distributor’s channels
mentioned above. These channels will require the Distributor to collect all
necessary information to determine whether a customer fits within the
definition of the Target Market.
mentioned above. These channels will require the Distributor to collect all
necessary information to determine whether a customer fits within the
definition of the Target Market.
The Distributor will collect
information from customers who
apply for the Product to ensure
they are in the Target Market. This
includes:
•
Information for the
Distributor’s affordability
and suitability assessment to
ensure customers meet the
affordability requirement;
•
Information relating to the
intended purpose and use of
the Product to ensure
customers’ needs and
objectives are likely to be met;
•
Assessing the information
collected to ensure customers’
are likely to meet their financial
obligations.
Periodic Reviews
TMD Date
12 December 2023
Last Review Date
12 December 2023
Reviews
Initial Review
12 months after the TMD Date
Periodic Reviews
12 months from the date of the previous review.
Review Triggers
The following events are review triggers that would reasonably suggest that the TMD is no longer appropriate:
- A significant dealing of the Product to consumers outside the Target Market occurs.
- The number of complaints received from consumers:
- is equal to 5% of our customer base or
- has increase by 10% or more from the the average number of complaints per month for 2 consecutive months in relation to the Product.
- There is a material change to the Product or the terms and conditions.
- When the number of:
- hardship applications is greater than 5% of our customer base;
- overdue loans is greater than 5% of current loans;
- forced loan close-outs is greater than 3% of current loans; and/or
- defaults is greater than 5% of current loans; and
- There are significant changes to Australian Credit Laws or other applicable laws that affect this Product.
Reporting
The following information must be provided to the Issuer by the Distributor:
Type of Information
Description
Reporting Period
Specific complaints
Details of the complaint,
including the name and
contact details of the
complainant and the
substance of the complaint
As soon as practicable, and in any
event within 10 business days of
receipt of the complaint
General complaints
Number of complaints
Every 3 months
Significant dealing(s)
Date or date range of the
significant dealing(s) and a
description of the significant
dealing.
As soon as practicable, and in any
event within 10 business days after
becoming aware of the significant
dealing