fbpx
//
The leading provider in Pay Now and Pay Later solutions for vendors.

Target Market Determination

 

Effective Date: 5 October 2021

The Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 require CampaignAgent to publish our Target Market Determination. 

A Target Market Determination explains who our products are designed for, and how they are distributed to our customers. 

VPAPay:

VPAPay is a financial product offered by Campaign Agent Pty Ltd (CampaignAgent) which offers vendors of residential (and certain commercial) real estate access to funding for marketing, furniture styling and cosmetic improvements  – known as Vendor Paid Advertising (VPA) –  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 their marketing 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 marketing 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 VPA amount and fees and interest when the amount becomes payable and due.

Product Description: A fixed cost short-term credit product used for funding marketing, furniture styling and cosmetic improvements in order to market residential or small commercial properties for sale. The key attributes are:

  • The VPA payment is made directly to the real estate agent on behalf of a vendor
  • The requirement to make re-payment of the VPA amount and fees and interest at the earlier of the due date, deposit release, settlement or withdrawal of the property from sale.

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.

VPAPay is 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 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 customer acquiring the VPAPay 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 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 purposes of advertising / preparing a property for sale)

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 for uses not related to the sale of property or a large number of non-vendors applying for the product.

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:

SmartCommission is a financial product offered by Campaign Agent Pty Ltd (CampaignAgent) which offers 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  a portion of their commission between the sale and settlement of the property.

Consumer description: An agent who wishes to access their commission income between the sale and settlement of the property they have sold unconditionally.  

Financial Situation: A person who will have the financial capacity to pay the commission amount and 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 are:

  • Availability to borrow up to 50% of their commission entitlement.
  • The requirement to make repayment of commission amount and fees and interest at the earlier of the 62 days, deposit release, settlement or the date that agent ceases to be entitled to the commission.

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.

SmartCommission is distributed directly to real estate agents and principals via CampaignAgent’s digital portal. The applicant must be employed or otherwise contracted or engaged by a real estate agency that has entered into 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.

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 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 customerss (for example 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 agents applying for the product who are not eligible or who require funding for longer than 62 days.

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:

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 to enable the vendor to purchase another property.

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 for the purpose of buying another property. 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:

  • All vendors on title apply together
  • Availability to borrow up to 80% of their available equity up to $500,000
  • The requirement to make repayment of the principal amount and fees and interest on the earlier of settlement or 6 months.

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 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

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.