RelloPay | Deferred payment plans for property marketing and listing costs
Issuer: Rello Finance Pty Ltd, trading as “Rello” (ACN 633 994 859)
Issue Date: 1 October 2023
Review Date: 1 October 2024
1.0 This Target Market Determination
This document is the target market determination (“TMD”) for consumers in the target market where payment and funding of property listing, marketing and presentation costs associated with selling a property is required (“vendor paid advertising”). The product is issued by Rello Finance Pty Ltd.
Rello provides real estate agencies and vendors with payment solutions including an option to defer the costs associated with selling a property and is distributed through third parties.
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 Target Market Determination applies
This TMD applies to the payment and funding of marketing costs by Rello in return for a share of the sales proceeds. Real estate agencies require vendors selling a home to pay marketing costs associated with selling their property at the time of entering into an exclusive agreement with a Listing Agent to sell their property. Rello provides the vendor the payment option to pay upfront or defer to settlement the payment of such marketing costs normally associated with listing and selling a property.
1.3 Date from which this target market determination is effective
1 October 2023 (the Effective Date).
2.0 Product Description and Key Attributes
This payment plan is designed for customers who require a deferred payment option for their property listing, marketing and property presentation costs when they commit to selling their property either with a listing agent or on a marketplace.
A summary of terms which may apply to the product are set out below:
3. Target Market
The information below summarises the overall class of consumers that fall within the target market for this product, based on the key product attributes, the likely objectives, financial situation and needs that it has been designed to meet.
3.1 Target Market for the Product
The product is designed for individuals who:
- Own a residential investment property in Australia which they have committed to sell;
- want the ability to pay a fee in exchange for the option to defer upfront property listing, marketing and presentation costs until settlement; and
- require an online fulfilment experience.
(the Target Market).
3.2 Product Eligibility
To be eligible for a pay later payment plan to fund for Marketing Costs, a Vendor must;
- be at least 18 years old;
- be a permanent resident or citizen of Australia;
- have verifiable mobile telephone number and a valid address in Australia;
- hold a valid ID with either a drivers licence or passport;
- have an Australian issued debit card or have agreed to a Direct Debit Service Agreement;
- own a residential property that is ready to list and sell; and
- can demonstrate commitment to sell their residential property by either signing an exclusive sales authority with a Listing Agent or have executed an agreement to list their property via an online marketplace.
4.0 How this product will be distributed
4.1 Distributor Onboarding
The table below describes the methods of distribution that are suitable for our product. It also lists the distribution conditions relevant to each channel of distribution:
|Method of Distribution||Conditions|
Direct – online
|Third party distributors||
4.2 Adequacy of distribution conditions and restrictions
We have determined that the distribution conditions and restrictions will make it likely that consumers who open the product are in the class of consumers that require a deferred payment option for costs associated with listing and preparing a property for sale.
We consider that the distribution conditions and restrictions are appropriate and will assist distribution in being directed towards the Target Market for whom the product has been designed.
4.3 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 residential property owners with the ability to make purchases of goods and services to list their property and defer the payment for these costs until property sale and settlement.
Specifically, the product is designed for consumers who have the financial capacity to service the financial obligations (including fees, if any) and repay the funds received from the sale of their property.
5.0 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 payment plans issued exceeds 5% in any quarter.
6.0 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.
6.3 Significant dealings
Distributors must report any significant dealings to us within 10 business days of becoming aware of the dealing.