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Swag Visa Debit Card and Swag Account

Approved 16 February 2023

Swag Visa Debit Card and Swag Account

Approved 16 February 2023

1: TMD DETERMINATION FOR NON-CASH PAYMENT PRODUCT

Target Market Determination
Product:	Swag Visa Debit card and Swag Spend account
	Non-cash payment product
Issuer:	Hay Limited ABN 34 629 037 403, AFSL 515459 (Hay Limited)
Start Date:	August 2022 – The date the determination was made.
Version	February 2023
Review Date	February 2024

Target Market: Class of Retail individuals that comprise the target market of the product	Retail Individual Description: This describes Retail individuals in the target market	Eligibility criteria for the product. Customers will need to satisfy specific eligibility criteria to maintain this product. Customers must: • Be an individual • Be aged 16 years or older to apply for the account • Be an Australian resident Objectives & Needs This product is targeted at individuals with the likely objectives, financial situation and needs of wanting: • Access to a debit card to make purchases with an internationally branded scheme such as Visa • To store money in an account without the ability to access interest on their balance • To manage access to funds available in the account through spend limits, merchant blocking and card management. Financial Situation • At the time of the application, the person has the right to open a Non-Cash Payment product account and has access and the ability to transfer funds in Australian dollars to preload the facility and pay fees.
	Product Description: This describes the non-cash payment product.	• A Non-Cash Payment Product issued by Hay Limited is a fully digital transaction account that allows Retail individuals to access their funds on demand. • Access is only possible by card app, BSB and Account number and does not have a physical presence. Retail individuals cannot make cash deposits or other withdrawals from the account via a physical branch except by using a card at an ARM where Visa Debit cards are accepted. • No interest can be earned on the funds deposited in the account. • Overdrawing the account is not permitted. • There are spend control and merchant category code limitations: ◦ The card program prohibits spending at unsuitable or inappropriate merchants for the Target Market to reduce harm. ◦ The card program has limits in place for the account balance and daily spending. ◦ Account owners can further restrict spending by a merchant to customise the product to suit their needs. ◦ The account owner can impose daily or weekly spending limits to suit the product to their needs.
	Appropriate Statement: This explains why the product is consistent with the target market’s likely objectives, financial situation, and needs.	The issuer, Hay Limited, has considered the product is likely consistent with the possible objectives, financial situation and needs of the Target Market as: • Customers can fund the account to save or spend those funds through a Debit card accessing the Visa network or through a BSB and Account number via Direct Entry or NPPA; and • Customers can manage access to the funds through spend limits, merchant blocking and card management.

Category	Description
Distribution Conditions: • The conditions and restrictions on the distribution of the product	Marketing and Promotion • This condition applies to marketing and promotional materials that describe the product	Condition 1 The authorised distribution partner must only market and promote the product as a reloadable Non-Cash Payment Product in Australia. This condition is suitable as the issuer has distributed this product using these methods, with limited risk to Retail individuals.
	Retail Product Distribution Conduct (other than Marketing) • This condition applies to all conduct (other than marketing), such as issuing, arranging, and providing disclosure material.	An authorised distributor must only engage in retail arranging, distribution and providing factual product advice: • through the 91±¬ÁÏ app; • to prospective Retail individuals who are individuals and meet Hay Limited’s minimum eligibility criteria for the product; and • to issue a Non-Cash Payment Product to Retail individuals after applying for and completing the application process • This condition is suitable as the issuer has distributed this product using these methods, with limited risk to Retail individuals.
Review Triggers: • The events and circumstances that would reasonably suggest the determination is no longer appropriate	The issuer, and any distributor of this product, must cease retail product distribution conduct in respect of this product when the issuer determines a material event or circumstance has occurred concerning:
	Material Complaints	Material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.
	Product Performance	Evidence, as determined by the issuer, of the product’s performance, in practice, may suggest that the product is not appropriate for the target market.
	Distributor Feedback	Reporting from distributors, or consistent feedback from distributors on the target market, suggesting that the determination may no longer be appropriate.
	Substantial Product Change	A significant change to the product features outlined in the product description will likely make the determination no longer appropriate for the target market.
		A significant change to the product because of regulatory, legislative or code changes will likely result in the determination no longer being appropriate for the target market.
	Significant Dealing	A material pattern of dealings in the product or distributor conduct is inconsistent with the determination.
	Notification from ASIC	A notification from ASIC requiring immediate cessation of product distribution or conduct concerning the product.
Review Trigger Information	The distributor of this product must provide the following information to Hay Limited within the below timeframes.
	Product Complaints data	Information relating to complaints received, including the number and nature of the complaint. Details by the distributor of this product and provided quarterly within ten days of the end of the Quarter.
	Significant Dealings	Any significant dealings of the product to customers who are outside the target market.
	Timings and Frequency	These triggers should be provided as soon as practicable and no later than 10 business days after the distributor becomes aware. They will be reviewed and discussed under the CAR and distributor Governance meeting cycles.