Target Market Determination

 

About this document

This Target Market Determination (“TMD”) is effective from 1 March 2021.

The purpose of this TMD is to offer consumers, agents and staff an understanding of the class of consumers for which this product has been designed, having regard to the objectives, financial situation, and needs of the target market. T

his TMD is not to be treated as the entire set of product terms and conditions and is not intended to provide financial advice. Consumers should refer to the product Terms of Service which outline the terms and conditions under the product when making a decision about the Cujo offerings and products.

This TMD describes the customers within our target market, but does not consider a customer’s personal needs, objectives or financial situation.

Class of consumers that fall within Cujo’s target market

The information below summarises the overall class of consumers that comprise the target market for the Cujo Products, based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet.

The Cujo Products have been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the product (including the key attributes), and specifically for residential renters in Australia who want to spread the cost of living and moving homes over time, with no hidden fees or interest rates.

The Key Eligibility Criteria of the Cujo Products are:

  • The individual must be over the age of 18 years and hold a valid Australian payment card.

  • The individual must have a valid email address and mobile number.

  • The individual must be a resident of Australia.

  • The identity of the individual must have been verified for Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) legislation purposes.

  • The individual must be prepared to share recent financial history via a third-party bank statement check.

  • The individual must accept Cujo’s Terms and Conditions and Privacy Policy.

Product Descriptions

BondPay is a short-term consumer finance product that allows renters to have their rental bond paid on their behalf to their leasing agent or state based rental bond authority. The renter initially pays an application fee of $150 and an upfront portion of their bond amount (20% of the bond amount). The remained of the bond amount is repaid to Cujo every month for the next 4 months, along with a monthly $25 service fee. BondPay is fully repaid after 120 days.

RentBump is a short-term consumer finance product that allows renters to have their rent paid on their behalf for a two-week period direct to their leasing agent. The renter pays an initial application fee of $65 and Cujo then pays the two-week rent advance direct to the leasing agent. The renter repays Cujo in 6 fortnightly repayments along with a $10 service fee. RentBump is repaid after 84 days.

Objectives and Needs

The Cujo Products have been designed for renters who:

  • Want to spread the cost of moving into their new home over time.

  • Want to align their repayments with their cash inflows for budgeting purposes.

  • Want to make repayments by interest-free instalments with clear and unambiguous fees.

  • Want an option to reduce monthly repayment fees by connecting their essential services thru CujoConnect

  • Want longer, flexible plan options relative to other consumer finance providers.

  • Want to make repayments without missing an instalment or experiencing hardship.

  • Need to receive an instant approval decision to gain access to the Cujo Products and provide certainty on their cost of moving homes.

Financial Situation

The Cujo Products have been designed for individual renters who:

  • meet the eligibility criteria at the time of their application;

  • have the objective of obtaining short term assistance in paying their rental bond or rent

  • are able to pay the initial instalment and activation fees

  • are able to make the monthly or fortnightly repayments

Excluded Class of Consumers

The Cujo Products have not been provided for individuals who:

  • are under 18 years of age;

  • are non-Australian residents;

  • do not earn at least 50% of their income from employment

  • who do not have a regular income (at least two income payments from an employer within the last period) from an employer;

  • are seeking sums above $2500, or longer term finance.

  • are seeking drawdown of funds directly to their own bank account

Consistency of the Products and the Target Market

Cujo has assessed and tested the Cujo Products and formed the view that they are consistent with the target market on the basis that the eligibility criteria has been specifically developed to align with the characteristics of the target market.

Renters who do not meet the eligibility criteria are unable to access the Cujo Products and the key attributes have been specifically designed to meet the likely objectives, financial situation and needs of renters in the target market described above.

How the Cujo Products will be distributed

Cujo distributes its own products directly to renters thru the Cujo website.

Cujo distributes its own product and has determined that the distribution conditions and restrictions will make it likely that the renters who apply for the Cujo Product are in the class of consumers for which it has been designed. The Key Eligibility Criteria is considered to be adequate in supporting the distribution of the Cujo Product in accordance with objectives, financial situation and needs set out above.

Reviewing, Monitoring and Reporting this TMD

Initial Review: 1 March 2022

Periodic Reviews: Annually on each anniversary of 1 March

Review Triggers:

  • Any event or circumstances that would suggest the TMD is no longer appropriate. This may include but is not limited to:

  • a material change to the design or distribution of the Cujo Product, including related documentation;

  • occurrence of a significant dealing;

  • regulatory change affecting the buy-now, pay later industry;

  • material percentage of consumer payment defaults;

  • material complaints, AFCA determinations or litigation;

  • external events such as adverse media coverage or regulatory attention; and

  • significant changes in review triggers covering matters such as:

    • inconsistency of product with target market’s likely needs, objectives or financial situation;

    • product design or implementation failures;

    • inconsistency of distribution with the TMD;

    • feedback received (including complaints); and

    • potential or actual harm to consumers

Where a review trigger has occurred, this TMD will be reviewed within 10 business days.

Significant Dealings

Cujo will notify ASIC in writing within 10 business days of it forming a view that a significant dealing in the product has occurred and which is not consistent with the TMD.