Background

LoopPay (ACN 628 994 276) has entered into an arrangement with a third-party payments provider Rello Finance Pty Ltd trading as Rello (ACN 633 994 859) to offer payment solutions to property buyers and property owners. LoopPay does not directly facilitate any payments and in return for referring a client to Rello, LoopPay may receive a fee

Target Market Determination | Rello DepositPay: Early Deposit Access for Property Owners

Issuer: Rello Finance Pty Ltd, trading as “Rello” (ACN 633 994 859)

Issue Date: 1 November 2022

Review Date: 1 November 2023 Version 2.0

1 About this Target Market Determination (“TMD”)

1.1 Introduction

This document is the target market determination (“TMD”) of customers (“Vendors”) in the who seek the early release of deposits held in trust following unconditional sale of their domestic residential property. This product is referred to as ‘DepositPay’. The product is issued by Rello Finance Pty Ltd (“Rello”).

This target market determination (“TMD”) details a description of the product, including the key attributes and why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market. It also specifies any conditions and restrictions on the distribution of the product, details distributor reporting requirements and sets out set review dates as well as the events or circumstances which will prompt us to review the TMD (Review Triggers).

This TMD is required under section 994B of the Corporations Act 2001 (Cth). This document is not intended to provide financial advice. It forms part of Rello’s design and distribution framework for the product. It does not replace our terms and conditions or other disclosure documents that we may provide to our customers.

1.2 Product to which this TMD applies

Rello offers DepositPay to Vendors when the sale of their domestic residential property is unconditional and a deposit for that sale had been received from the purchaser and is held in trust for the Vendor.

Vendors generally must wait for settlement to take place (normally 30-90 days depending on which state the property is located) before they can access the deposit. Rello provides the Vendor with early access to the amount of the deposit ahead of settlement. In consideration, the Vendor sells Rello a right to receive an identified amount of the sale proceeds. The Vendor is required to buy that right back from Rello at the earlier of property settlement, release of the deposit, withdrawing the property from the sale agreement or a prescribed date – usually the settlement date prescribed in the contract of sale.

This product is available only to Vendors that sell a residential investment property in Australia.

1.3 Date from which this TMD is effective

1 November 2022 (the Effective Date).

2 Product Description and Design

A summary of terms which may apply to Deposit Advance are set out below:

Purpose		Advance funding of deposits held in trust
User		Vendor who enters into an unconditional exchange of contract to sell their residential property
Exclusions		Commercial Property, off-the-plan sales and property developments
Advance Amount		From $20,000 to $250,000 per exchanged contract
Fees		A service fee is payable based on a percentage of the Advance amount which is payable on settlement.
Repayment		The Advance Amount and service fee are payable at settlement or early deposit release
		Early repayments are possible without penalty
Term		Payment periods will match the settlement date up to 120 days.

3 The Target Market

The information below summarises the type of consumers that fall within the target market for this product, based on the key product attributes, and the likely objectives, financial situation and needs that the product has been designed to meet.

3.1 The Target Market

The information below summarises the type of Vendors who fall within the target market for a DepositPay, based on the key product attributes, their likely objectives, financial requirements and needs that product has been designed to meet.

Rello advances a percentage of the deposit amount held in trust following an approved sale of residential real estate property, to the Vendor. An approved sale transaction is one where:

• The property is residential and located in Australia;

• A contract of sale had been exchanged and the deposit paid by the purchaser; § The contract of sale is unconditional and any cooling down period had expired;

• The contract of sale gives the Vendor a right to retain the deposit if the purchaser fails to settle.

The product is designed for individuals who require access to funds following the sale of their property where they have a short term immediate requirement for those funds. (the Target Market).

3.2 Eligibility

To be eligible to access a DepositPay, a customer must: § be at least 18 years old;

• be a permanent resident or citizen of Australia;

• have a verifiable mobile telephone number and a valid address in Australia;

• have a verifiable for ID which is digitally verified

• have signed an unconditional contract of sale to sell their property;

• have title to the property sold; and

• can confirm deposit is received and held in trust.

The target market excludes sales from a deceased estate, off plan residential sales and commercial property sales.

3.3 The appropriateness of the product for customers

Rello has concluded that this product is consistent with the likely objectives, financial situation and needs of individuals in the Target Market because it provides an immediate need for money that otherwise is not available until a contract of sale is fulfilled.

Specifically, the product is designed for consumers who have the financial capacity to fulfil obligations from the proceeds of selling the property.

4 How this product will be distributed

4.1 Distribution

Rello has defined a set of distribution channels and associated distribution conditions or restrictions. DepositPay are distributed digitally:

• Online through the Rello’s Website (www.rellopay.co), where Vendors can apply directly;

• Through licenced real estate agents who inform Vendors of the availability of Rello’s DepositPay in the ordinary course of providing real estate services;

• Conveyancers and lawyers (“Settlement Agents”) who support Vendors in facilitating complex and often multiple transactions and

Each Settlement Agent or Real Estate Agent is onboarded and provided with a unique account to enable using the Rello Platform, with access to products and services. Training is provided to not make any false or misleading representation or statement about Rello or Rello’s products and services.

Third party distributors may inform Vendors of the potential availability of a DepositPay when a need is possible.

4.2 Adequacy of distribution conditions and restrictions

Rello has determined that the conditions and restrictions on distributors make it likely that Vendors who request a DepositPay will be in the class of customers that require early access to the buyer deposit on an unconditional exchange.

We consider that the distribution conditions and restrictions are appropriate and will ensure that distribution is directed towards the Target Market for whom DepositPay has been designed.

5 Reviewing this TMD

Rello has implemented the following monitoring program for the product which is designed to trigger a review of this TMD.

5.1 Review periods and review triggers

The features of the product, and this Target Market Determination, will be reviewed no later than 12 months after the date of this Target Market Determination, and thereafter annually each October to assess the product’s continued suitability for the objectives, financial situation and needs of Agencies in the target market. Reviews will take into account:

• Quarterly review of the appropriateness of the product limits.

• Quarterly review of the performance of each distribution method;

• Quarterly review of product and portfolio performance;

We will collect information on the number applications, number of active payment plans and repayments in relation to this TMD on a monthly basis.

The following circumstances (review triggers) will trigger an earlier review of this Target Market Determination, and of the suitability of the product to the target market:

• If overdue account balances exceed 10% of the total outstanding balances; and

• If the ratio of complaints received to new DepositPay advances issued exceeds 5% in any quarter.

6 Reporting and Monitoring the TMD

6.1 Product complaints

Distributors must report all complaints they receive in relation to the product to us by the middle of each month. The report must include the following:

• the number of complaints,

• the identity of the distributor;

• the product name;

• the customer name; and

• the exact details of the complaint.

6.2 Significant dealings

Distributors must report any significant dealings to us within 10 business days of becoming aware of the dealing.