Target Market Determination

1. About this Document

This Target Market Determination [TMD] has been prepared by TodayPay Pty Ltd ACN: 60657301212 (Us, We, Our) in compliance with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs). It applies to our TodayPay product.

This TMD is not to be treated as a full summary of TodayPay’s terms and conditions and is not intended to provide financial advice. Customers must refer to the relevant terms and conditions under the product when making a decision about this product.

This TMD is effective from 1 February 2022

2. Product Description

TodayPay is a short-term pay advance product for consumers who desire to access a portion of their salary in advance via the TodayPay mobile or web-based app in order to meet their short term cash needs. An interest free, fixed 5 percent service fee is charged for each pay advance request.

TodayPay’s repayment cycle is aligned to the customers pay cycle, which may be weekly, fortnightly or monthly.

TodayPay has been designed to be a safe product for consumers, with strong inbuilt protections. TodayPay customers start with a low pay advance amount which only increases with time and successful repayments. Newer customers who cannot make their repayment on the due date, won’t be able to receive an increase in pay advance. An automated re-evaluation of the pay advance amount is carried out if customers do not repay a received pay advance in a timely manner, which leads to a reduction in the pay advance amount for future requests. Continued late repayments ultimately lead to the customer's account being suspended. In this way, TodayPay protects their customers from building up debt and ensures that the pay advance amount takes into account the financial situation of the customer.

Although customers may potentially pay late fees on pay advances over time, our late fee cap ensures that the total amount of late fees paid never exceeds 24 percent of the requested amount.

TodayPay offers a generous and highly accessible hardship program for customers that are experiencing hardship. Requests for hardship assistance are always accepted and we provide customers that are experiencing hardship with a wide range of flexible payment plan options.
We do not require evidence from customers to support their hardship requests and we freeze the late payment fees.

TodayPay does not conduct aggressive debt collection practices or legal enforcement of debts and also does not participate in the credit reporting system when the customers find themselves unable to meet their repayment obligations.

For these reasons, the TodayPay product is suitable for a wide range of consumers within the TMD.

3. TodayPay’s Target Market and eligibility requirements

3.1. Class of consumers

The TodayPay pay advance product has been designed for individuals who:

• Are 18 years of age or older and are an Australian resident.

• Are employed and receive their income paid into an Australian bank account.

• Are the holder of a valid and verified Australian-issued debit card.

• ​​Can provide a valid delivery address in Australia.

• Can successfully verify their identity to the satisfaction of TodayPay.

• Earn at least $500 income per week, and 50 per cent or more of their income is paid by an employer.

• Would like to access amounts of between $10 and $300 to assist in paying expenses and managing their cash flow.

• Are not self employed.

• Are seeking a low cost, short-term pay advance product.

• Want protection to avoid excessive fees, with hard caps on late fees.

• Are not experiencing financial hardship.

• Want to resolve a temporary financial need, such as medical expenses, life events, paying bills and rent, shopping, entertainment, travel, and vehicle expenses.

• Need to manage the timing of personal finances, including unexpected expenses and/or expenses beyond the affordability of their pay cycle.

• Would benefit from a product that is zero cost upfront or, if late fees happen to be paid, is low cost relative to other financial products that are available in the market.

3.2. Excluded class of consumers

The TodayPay pay advance product has not been designed for individuals who:

• Are seeking to access a pay advance beyond $300.

• Are under 18 years of age.

• Are experiencing financial hardship

• Do not have a regular income.

• Are not Australian citizens.

• Earn wages less than $500 per week.

• Wish to repay via Credit Card.

• Are self employed

4. The Key product attributes of TodayPay

The key product attributes of the Product are:

• No charging of interest or establishment fees.

• Fixed service fee of 5 percent of the requested pay advance amount.

• Pay advances are up to 25 percent of the customer's regular wage or salary with a maximum of $300.

• Variable pay advance amount based on customer repayment history and capabilities and inability to spend over the set limit.

• No charging of late fees when the customer pays on time.

• Freezing of late fees for customers who apply for hardship.

• Repayment only via direct debit or Debit Card.

• Offering to enter a payment plan when a customer is experiencing hardship.

• Customers have the ability to defer repayments for one pay cycle to manage unforeseen circumstances.

• Customers authorise TodayPay to direct debit the repayment amount on the nominated repayment date(s).

• Every pay advance needs to be fully settled before a new advance can be requested to avoid building up debt.

• Terms of up to 61 days.

5. Consistency between target market and the Product

The TodayPay pay advance product is consistent with the identified class of market based on the following criteria:

• Consumers who do not meet the above-mentioned eligibility criteria are not able to create an account with TodayPay and thus are not able to access the service.

• The key attributes of the TodayPay pay advance product have been specifically designed to meet the likely objectives, financial situation and needs of consumers in the target market stated above.

6. Distribution conditions

6.1. Distribution channels

This product is designed to be distributed through:

• Mobile and web-based applications.

• Marketing and advertising conducted via partnerships, sponsorships, referrals.

• Social media and other online and offline marketing channels.

6.2. Adequacy of distribution conditions and restrictions

This product is to be distributed under the following conditions:

• No misleading information

• All third party distributors are vetted before being allowed to present our product and are subject to regular monitoring.

• TodayPay uses a standardised process for onboarding customers that prevents access to the service for consumers who do not meet the target market eligibility criteria as stated above.

• TodayPay’s marketing does not deliberately target consumers outside the eligibility criteria.

7. Reviewing the Target Market Determination

The responsible manager will review this TMD in accordance with the below:

Initial reviewBy 5 October 2022Periodic reviewsAt least every two years from the initial reviewReview triggers or eventsAny of the below triggers may indicate that the TMD is no longer considered appropriate for the target market and a review of the TMD is to be undertaken by TodayPay:

• Change to the design or distribution of the product.

• External events such as adverse media coverage or regulatory attention.

• Changes to credit assessment practices.

• A significant increase in volumes of complaints.

• Changes to economic conditions.

• Increases or decreases in default and dishonour rates.

• Customers being charged late fees while they are in a hardship arrangement.

• Customers paying late fees over the cap.

• Customers outside of TMD are able to access the service.

• Increase in consumers requesting hardship assistance.

• Changes to the regulatory framework

• Changes to the nature of users who use our product