The Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 requires Campaign Agent Pty Ltd ACN 608 962 812 (CampaignAgent) to publish our Target Market Determination (TMD) in respect of each of its products. A Target Market Determination explains who our products are designed for and how they are distributed to our customers.
VPAPay is a financial product offered by CampaignAgent which provides vendors of residential (and certain commercial) real estate access to credit to cover the costs of marketing, staging, styling and cosmetic improvements – known as Vendor Paid Advertising (VPA) – to their property once they have agreed on a marketing schedule with their selected real estate agent. CampaignAgent offers a vendor the choice to pay for their VPA expenses up-front or to defer payment of their VPA expenses through a loan to better align the repayment obligation with the receipt of the sale proceeds.
Consumer description: A person who does not wish to pay for their VPA expenses upfront and would like to defer the repayment of their VPAPay expenses to better align with the receipt of the sale proceeds.
Financial Situation: A person who will have the financial capacity to repay the VPA expenses and CampaignAgent’s fees when the amount becomes payable and due.
Product Description: A fixed cost credit product used to fund the marketing, staging, styling and cosmetic improvements in order for a vendor to market their residential (and certain commercial) property for sale. The key attributes of VPAPay are:
VPAPay is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless CampaignAgent’s criteria are met, consumers will be deemed ineligible to receive the product.
VPAPay is distributed to property vendors who submit an application through CampaignAgent’s digital portal. VPAPay is only offered to property vendors who have appointed a real estate agent that is a client of CampaignAgent. VPAPay is only eligible to those vendors that meet our eligibility requirements which include providing a signed sales authority with their real estate agent and in certain cases an agreed marketing schedule. In addition, funds are advanced directly to a vendor’s real estate agency on their behalf.
The distribution of the product makes it likely that a VPAPay borrower is in the target market, being vendors of Australian real estate.
Review: Annually.
Review triggers: A review of the TMD will be triggered if CampaignAgent determines a material event or circumstance has occurred in relation to:
Significant dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.
SmartCommission is a financial product offered by CampaignAgent which allows real estate agents of residential (and certain commercial) properties early access to their commission income once the sale of the property is unconditional. The agent has a choice to receive an advance of their commission between the unconditional sale and settlement of the property.
Consumer description: A real estate agent who wishes to access their commission income between the unconditional sale and settlement of the property they have sold.
Financial situation: A person who will have the financial capacity to repay the commission amount and CampaignAgent’s fees and interest when the amount becomes payable and due.
Product description: A short-term credit product used to access commission income early. The key attributes of SmartCommission are:
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria are met, consumers will be deemed ineligible to receive the product.
SmartCommission is distributed directly to real estate agents via CampaignAgent’s digital portal. The applicant must be employed or otherwise contracted or engaged by a real estate agency that has entered a contractual arrangement with CampaignAgent.
The product is limited to those agents who meet our eligibility requirements which includes providing an unconditional contract of sale and a sales authority which evidences their entitlement to a commission.
The distribution of the product makes it likely that a customer acquiring the SmartCommission product is in the target market, being agents of Australian real estate.
Review: Annually.
Review triggers: A review of the TMD will be triggered when CampaignAgent determines a material event or circumstance has occurred in relation to:
Significant dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.
DepositNow is a financial product offered by CampaignAgent which allows vendors of Australian real estate early access to a portion of the equity from their settlement proceeds once the sale of the property is unconditional.
Consumer description: A vendor who wishes to access a portion of the equity from their settlement proceeds between the unconditional sale and settlement of the property they have sold. The vendor must have available equity in the property they have sold to borrow against.
Financial situation: A person who will have the financial capacity to pay the principal and CampaignAgent’s fees and interest when the amount becomes payable and due.
Product description: A credit product used to access a portion of the equity from their settlement proceeds prior to settlement. The key attributes of DepositNow are:
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria are met, consumers will be deemed ineligible to receive the product.
DepositNow is distributed directly to vendors who have used CampaignAgent’s VPAPay product for the marketing of their sold property. Vendors apply directly to CampaignAgent online.
A condition of the product is that an applicant must provide an unconditional contract of sale in respect of the property sold and a title search is undertaken to ensure all applicants are on title.
The distribution of the product makes it likely that a customer acquiring the DepositNow product is in the target market, being a vendor who has sold their property
Review: Annually.
Periodic Review: At least annually from the initial review
Review Triggers: A review of the TMD will be triggered when the issuer determines a material event or circumstance has occurred in relation to:
Financial hardship – a material number of customers experiencing financial hardship as a result of obtaining the product.
Material complaints – receiving material complaints regarding the terms of the product or its manner of distribution.
Material product changes – a material change to the product or the manner of distribution that is likely to result in the determination not appropriate for the target market.
Evidence of fraud – evidence of fraud by customers and or their real estate agents (for example, funds not being used for the intended loan purpose or the discovery of non-complying eligibility documentation).
Changes in applicable laws and regulations – changes to applicable laws and regulations that result in the design of the product no longer being appropriate for the target market.
Large number of vendors applying for the product who are not eligible.
Significant Dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.
DepositNow+ is a financial product offered by Campaign Agent Pty Ltd (CampaignAgent) which offers vendors of Australian real estate early access to a portion of the equity from their settlement proceeds once the sale of the property is unconditional.
Consumer description: A vendor who wishes to access a portion of the equity from their settlement proceeds between the sale and settlement of the property they have sold unconditionally. The vendor has available equity in the property they have sold to borrow against.
Financial Situation: A person who will have the financial capacity to pay the principal and fees and interest when the amount becomes payable and due.
Product Description: A credit product used to access a portion of their equity from their settlement proceeds prior to settlement. The key attributes are:
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria is met, consumers will be deemed ineligible to receive the product.
DepositNow+ is referred to vendors exclusively via CampaignAgent’s real estate agency partners. Once vendors receive their exclusive access, they can apply directly to CampaignAgent online.
A condition of the product is that an applicant must provide an unconditional contract of sale in respect of the property sold and a title search is undertaken to ensure all applicants are on title.
The distribution of the product makes it likely that a customer acquiring the DepositNow+ product is in the target market, being a vendor who has sold their property and is referred via CampaignAgent’s agency partner.
Initial Review: Within 6 months of the effective date
Periodic Review: At least annually from the initial review
Review Triggers: A review of the TMD will be triggered when the issuer determines a material event or circumstance has occurred in relation to:
Financial hardship – a material number of customers experiencing financial hardship as a result of obtaining the product.
Material complaints – receiving material complaints regarding the terms of the product or its manner of distribution.
Material product changes – a material change to the product or the manner of distribution that is likely to result in the determination not appropriate for the target market.
Evidence of fraud – evidence of fraud by customers and or their real estate agents (for example, funds not being used for the intended loan purpose or the discovery of non-complying eligibility documentation).
Changes in applicable laws and regulations – changes to applicable laws and regulations that result in the design of the product no longer being appropriate for the target market.
Large number of vendors applying for the product who are not eligible.
Significant Dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.
PMPay is a financial product offered by CampaignAgent which allows landlords of residential (and certain commercial) properties access to credit for costs such as maintenance, repairs and advertising related to their investment properties. A landlord can defer these payments over four equal instalments over an eight-week period to better align the repayment obligation with their cashflow requirements.
Consumer description: A landlord who wishes to defer repayment of property related costs, such as maintenance, repairs or advertising, to better align the repayment obligation with their cashflow requirements. An eligible consumer must:
Financial situation: A person who will have the financial capacity to pay the principal and CampaignAgent’s fees when the amount becomes payable and due.
Product description: A credit product used to spread the payment of investment property-related costs over a period of 8-weeks. The key attributes of PMPay are:
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria are met, consumers will be deemed ineligible to receive the product.
PMPay is distributed to landlords who submit an application through CampaignAgent’s digital portal. The product is only offered to landlords who have appointed a property manager to manage the property to which the costs relate. PMPay loans are paid directly to the real estate agency managing the investment property on the owner’s behalf.
The distribution of the product makes it likely that a customer acquiring the PMPay product is in the target market, being a landlord of an investment property requiring funds for investment property related costs.
Review: Annually.
Review Triggers: A review of the TMD will be triggered when CampaignAgent determines a material event or circumstance has occurred in relation to:
Significant dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.
A Home Preparation Loan is a financial product offered by CampaignAgent which allows vendors of residential (and certain commercial) real estate access credit for maintenance, repairs and minor works to prepare their property for sale, once they have agreed on the marketing schedule with their real estate agent. The vendor has a choice to pay for their costs up-front or to defer payment of these costs to better align the repayment obligation with the receipt of the sale proceeds.
Consumer description: A person who does not wish to pay for the preparation costs upfront and wishes to defer the repayment obligation to better align with the receipt of the sale proceeds.
Financial situation: A person who will have the financial capacity to pay the Home Preparation Loan amount and CampaignAgent’s fees when the amount becomes payable and due.
Product description: A fixed cost credit product used for funding maintenance, repairs and minor works in order to market residential or small commercial properties for sale. The key attributes of a Home Preparation Loan are:
The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria are met, consumers will be deemed ineligible to receive the product.
Home Preparation Loans are distributed to property vendors who submit an application through CampaignAgent’s digital portal. The product is only offered to property vendors who have appointed real estate agents that are clients of CampaignAgent. The product is limited to those vendors that meet our eligibility requirements which includes providing a signed sales authority with their real estate agent, invoices in respect of the repairs, maintenance and minor works to be undertaken and in certain cases an agreed marketing schedule.
The distribution of the product makes it likely that a customer acquiring the Home Preparation Loan product is in the target market, being vendors of Australian real estate.
Initial review: Within 1 year of the effective date.
Periodic review: At least annually from the initial review.
Review triggers: A review of the TMD will be triggered when CampaignAgent determines a material event or circumstance has occurred in relation to:
Significant dealing – Notify ASIC in writing as soon as practicable, and in any case within 10 business days after becoming aware of a significant dealing that is inconsistent with this determination.