Target Market Determination
Billie Loans Pty Ltd ACN 679 740 973 ("Billie")
Effective Date: 15 December 2024
Status: Current
About this document
This Target Market Determination (TMD) describes the class of customers the product has been designed for, having regard to the financial position, objectives, and needs of the target market. It also describes the conditions under which it must be distributed and how Billie will review this document to ensure it remains appropriate.
This Target Market Determination should not be considered as a comprehensive document detailing the product's terms and conditions and does not constitute financial advice. Consumers are encouraged to review the product's Terms of Service and any accompanying documents, which outline the applicable terms and conditions, before making a decision regarding this product.
Terms of Service to which this Target Market Determination applies
This TMD applies to the short term credit product ("Billie Pay Advance") offered by Billie Loans Pty Ltd. The Billie Pay Advance is governed by the following terms and conditions:
Terminology: In this TMD, "pay advance" and "short-term loan" are used interchangeably and refer to the same product with the same economic effect: a short-term advance of funds with a fixed fee and no interest, repayable within 60 days or less.
- Billie Loans Pty Ltd Terms of Service; and
- Billie Loans Pty Ltd Loan Agreement.
Date from which this target market determination is effective
- 15th December 2024
Class of consumers that fall within this target market
The information below summarises the overall type of consumers that fall within the target market for the Billie Pay Advance based on the product's core features and how it aligns with the financial situation and needs of consumers that it has been designed to meet.
Billie's Billie Pay Advance loans have been designed for customers who:
| Customer Characteristics | Key attributes of Billie's Billie Pay Advance loan that make the product appropriate for the target market |
|---|---|
| Are an Australian resident, have the right to work in Australia, and receive their salary paid into an Australian bank account. | Availability: available Australia wide to Australian domiciled natural persons being paid a salary in Australia. |
| Earn at least $300 in salary per week through employment, and 50 per cent or more of their income is paid by an employer. | Suitability: Billie applies its suitability checking process to ensure the product is consistent with the customer's needs, predominantly to advance a proportion of the customer's predictable salary. |
| Are 18 years of age or older. | Age Eligibility: The product is restricted to individuals aged 18 and older, ensuring that customers have the legal capacity to enter into a loan agreement and are generally better positioned to understand and meet their repayment obligations. |
| Are seeking a small to medium value, fixed term, fixed fee, short-term credit product that is not revolving. |
Amount: Loan amount of at least $200 and up to $1,000. Term: Term of at least 1 day and up to 60 days that does not automatically renew, redraw or extend and must be repaid in full by expiry date. Repayment Profile: Customers make regular, scheduled repayments to pay down the loan balance over the term. Interest Rate & Fees: zero interest and one single fee of 5% of the amount borrowed. |
| Are not experiencing financial hardship. | Financial Stability Screening: The product is designed for customers who are currently not experiencing financial hardship, ensuring that borrowers can meet their repayment obligations without exacerbating financial strain. |
| Are seeking an unsecured loan for short term personal or domestic purposes; | No Security: Customers are natural persons who seek funding for temporary needs and are not required to provide an asset as security for the loan. |
| Can satisfactorily demonstrate that they are able to afford to repay the loan within its scheduled term. | Billie processes: Billie applies its affordability and suitability assessment process to determine whether the product is consistent with the customer's needs and objectives and demonstrates the customer's ability to repay the loan. |
Product description
The Billie Pay Advance offers short-term credit at a fixed cost, giving customers immediate access to funds through the Billie mobile or online platform. Instead of interest or late fees, a single, one-off fee of up to 5% applies. Repayments are scheduled to align with the customer's regular pay cycle (weekly, fortnightly, or monthly) and are due within the agreed term. Under the loan agreement, the maximum term for a Billie Pay Advance is capped at 60 days.
Key Eligibility Requirements
To be eligible for a Billie Pay Advance, applicants must meet the following eligibility requirements:
- Be 18 years or older, is domiciled in Australia and an Australian resident or has demonstrated the right to work in Australia;
- Have a current driver's licence issued by an Australian government authority, passport or Medicare card (or otherwise pass the identification criteria set out by Billie);
- Be employed and earn at least $300 income per week. Employment may include self-employment, provided that the applicant is an individual and all other eligibility criteria is met; and
- Have 50 percent or more of their income paid by an employer.
Key Product Attributes
The Billie Pay Advance has the following key attributes:
- Applicants may request up to $1,000 per Billie Pay Advance, subject to their net income, spending patterns, repayment history, and Billie's assessment of their creditworthiness.
- Billie applies a one-time transaction fee equal to 5% of the credit amount provided. There are no interest charges or additional fees.
- Repayments are generally scheduled in installments aligned with the consumer's pay cycle (weekly, fortnightly, or monthly), as identified by Billie's systems. In some cases, consumers can request alternative repayment dates that deviate from their standard pay cycle.
- Under the loan agreement, a Billie Pay Advance can have a term of up to 60 days.
- Billie does not offer revolving credit facilities or redraws. Each advance must be fully settled before a new application is considered.
- Existing customers who have fully repaid all previous loans may apply for another advance.
Alignment of the Product with the Target Market
Billie's evaluation and testing indicate that the pay advance aligns with its intended audience because:
- The eligibility requirements are directly designed to match the target market's characteristics, ensuring that consumers who do not meet these conditions cannot access the product; and
- The key features of the Billie Pay Advance are purposefully structured to support the likely goals, financial situations, and needs of the defined target market.
This product is not intended for individuals who, at the time of their initial application do not meet the key eligibility requirements.
How this product is to be distributed
This product is designed to be distributed through digital means via a mobile and web-based application, with marketing and advertising conducted via partnerships, sponsorships, referrals, social media and digital marketing channels.
This product should only be distributed to individuals who meet the eligibility requirements described above and who have demonstrated the financial capacity to repay the principal balance of the Billie Pay Advance inclusive of the 5% application fee.
Adequacy of distribution conditions and restrictions
Billie has assessed the adequacy of the distribution conditions and restrictions of the Billie Pay Advance and formed the view that they are appropriate for the following reasons:
- The Billie Pay Advance is distributed through digital means to allow Billie to meet the consumer need of on-demand access to a portion of their pay in advance. Digital technology, including mobile and web-based applications, are primary product access points for Australian consumers, and a primary method through which Australian consumers manage their finances; and
- The marketing and distribution channels for Billie's pay advance are selected based on an assessment of the distribution conditions and restrictions to determine that they are appropriate and will assist distribution in being directed towards the target market for whom the product has been designed.
Reviewing this target market determination
Billie will review this target market determination in accordance with the below:
Initial review
Within 12 months of the effective date.
Periodic reviews
At least every two years from the initial review.
Review triggers or events
In addition, Billie will review this document earlier if one or more of the following occurs, where they reasonably suggest that the TMD is no longer appropriate:
- There is a material change to the product or its distribution. For example, a change to a key product attribute or a material change to a distribution channel.
- There is a change in law or its application, a change in relevant industry code, a court decision, ASIC or other regulatory guidance or action that materially affects the product. For example, if a change in the law requires Billie to change or remove a key product attribute or a product intervention order is made by ASIC in respect of the product.
- There is a significant increase beyond expected levels in complaints or disputes, or a significant change in the nature of complaints or disputes relating to the product.
- Billie has information about the way in which the product is being distributed, operating or being used by customers that reasonably suggests the TMD is no longer appropriate.
Where a review trigger has occurred, this TMD will be reviewed within 10 business days.
IMPORTANT INFORMATION This target market determination is not a recommendation, opinion or advice that any person acquire the product or is within the target market for the product. It does not summarise the terms or risks of the product and is not an offer of, or invitation to apply for, the product to any person in Australia or elsewhere.