Target Market Determination

RelloPay | Pay Later for Vendor Paid Advertising 

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

1.0 This Target Market Determination

1.1. Introduction 

This document is the target market determination (“TMD”) for consumers in the target market where payment and funding of marketing costs associated with selling a property is required (“vendor paid advertising”). The product is issued by Rello Finance Pty Ltd (“Rello”). 

Rello provides real estate agencies 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 November 2022 (the Effective Date). 

2.0 Product Description and Key Attributes  

This RelloPay payment plan product is designed for customers (vendors) who require a deferred payment option for vendor paid advertising costs (“VPA”). When a vendor (a seller of a residential real estate property) agrees to sell their property, they will enter into an exclusive agreement with a Listing Agent to sell a property.  

VPA costs may include:  

• property advertising and listing fees;  

• property presentation (styling); and  

• property improvement costs.  

 Under a pay later payment plan, Rello pays the agreed VPA for listing the property, to the Listing Agent. In exchange, the Vendor sells to Rello the right to receive an agreed amount form a share of the sale proceeds, which is paid to Rello at settlement of the property or on the release of the deposit, whichever is earliest. 

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  

Customers for this product are vendors who are selling residential real estate property and have signed an exclusive sales authority with a licensed real estate agency. The vendors wish to defer paying the costs of marketing their property, until the proceeds of settlement are available. 

The pay later payment plan for funding marketing costs has been designed for vendors, that require a deferred payment option to fund their VPA to maximise the chance of achieving their target selling price (the Target Market). 

Rello has concluded that this product is consistent with the likely objectives, financial situation and needs of individuals in the Target Market. The value for the Vendor includes: 

• Ensures that funds are available to market the property appropriately, to achieve the vendor’s target selling price; 
• Matches payment by the vendor of the costs of pursuing a sale with the availability of proceeds from completing the sale; and 
• Effective marketing potentially reduces the time a property is on the market, as well as maximising selling price. 

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/credit card to apply; and 
• have signed an exclusive sales authority with a Rello onboarded real estate agency. 

 4.0 How this product will be distributed  

The pay later payment plan for Marketing Costs product is distributed by Rello via a licensed real estate agency (“Agency”).  

 4.1 Distributor Onboarding 

Each distributor, an Agency is required to be onboarded with a Rello Account to use the Rello Platform and make available Rello’s products. Each Agency must satisfy our know-your-customer and AML/CTF requirements and any other checks we deem necessary. Each Agency is provided with appropriate training to not make any false or misleading representation or statement about us or about the product. 

4.2 Vendor Onboarding 

Each Vendor makes their own assessment once agreeing to the VPA costs with their Listing Agent to make an upfront payment of defer the costs associated with selling their property. A vendor will receive SMS/email communication from the Listing Agent with a “Pay Now” and “Pay Later” payment option for VPA costs once they have secured an exclusive sales listing authority.  

Vendors that select the “Pay Later” option are onboarded directly, completing an ID verification, and once verified, are presented with a payment schedule online along with the product terms and conditions. Prior to accepting the terms and conditions, the Vendor is required to review, consent, and agree to their contractual obligations and the Rello privacy policy. 

 4.3 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. 

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. 

Target Market Determination

EarlyRent | Funding for Property Improvement Costs

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

Issue Date: 1 November 2022

Review Date: 31 October 2023

Version: 1.0

1         About this Target Market Determination

1.1          Introduction

This document is the target market determination (“TMD”) for customers that own an investment property to access future rental cashflows upfront (‘Advance’) to invest in improving their property and then subsequently pay back that Advance from rent over time (“Payment Plan”). 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 Target Market Determination applies

Rello provides landlords (or customers) a deferred payment option for property improvement related costs up to $50,000 which are repaid by a series of payments from a share of the rent over time. This product is available only to landlords that own a residential investment property in Australia.

1.3        Date from which this target market determination is effective

1 November 2022 (the Effective Date).

2       Product Description and Key Attributes

This RelloPay payment plan product is designed for customers (i.e., landlord’s) who own an residential investment property and want to manage their cash flow by accessing future rental income upfront to spend on improving or maintaining their investment property and spread the cost over a series of instalments from available rental income.

Customers must be able to demonstrate their ability to make payments from rental income and must be able to pay the Advance Amount in full during the period agreed.

The key product attributes are set out below:

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        Target Market for the Product

The product is designed for individuals who:

• Own a residential investment property in Australia which is tenanted and has an agency property management agreement in place;
• want the ability to pay a fee in exchange for the option to defer upfront property improvement costs over a series of instalments payable from rental income; and
• require an online fulfilment experience.

(the Target Market).

3.2       Eligibility

To be eligible for a Payment Plan, 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;
• hold a valid  driver’s licence or passport;
• have an Australian issued debit card or have agreed to a Direct Debit Service Agreement;
• own a residential investment property that is currently leased and have an active agency rental agreement; and
• can demonstrate rental income from their residential investment property.

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 residential investment property owners with the ability to make purchases of goods and services for property improvements and defer the payment for these costs by spreading the upfront cost into a series of instalments over time which are payable from rental income.

Specifically, the product is designed for consumers who have the financial capacity to service the ongoing financial obligations (including fees, if any) and repay the funds with a portion of the rent received for the property over time.

4       How this product will be distributed

4.1        Distribution

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:

4.2       Adequacy of distribution conditions and restrictions

We have determined that the distribution conditions and restrictions will make it likely that customers who are open to the product are the type of end customers for which it has been designed because they are likely to have an agency management agreement with a real estate agency or they seeking to access funding to complete works on a residential investment property which is tenanted.

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 payment plans 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.

Target Market Determination

DepositPay | Early Deposit Access for Vendors

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:

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;
• hold a valid driver’s licence or passport;
• have signed an confirmed 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 (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.

Target Market Determination

Rello Payment Plan

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

Issue Date: 1 November 2022

Review Date: 31 October 2023

Version 2.0

1.      About this Target Market Determination

1.1          Introduction

This document is the target market determination (“TMD”) for a Rello Payment Plan which allows customers that require a payment option to spread the cost of purchases into multiple repayments over time (“Payment Plan”). It 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 and sets out the events or circumstances where we are required 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.

1.2         Product to which this Target Market Determination applies

Rello provides customers a deferred payment option for real estate payment related transactions up to $2,000. This product is available to a retail consumer base and enables consumers make purchases followed by a series of interest free repayments over time.

1.3        Date from which this target market determination is effective

1 July 2022 (the Effective Date).

2          Product Description and Key Attributes

The Rello Payment Plan is designed for customers who want to manage their cash flow and spread the cost of real estate/property related transactions over a series equal instalments.

Customers must be able to repay the payment plan via their debit or credit card in 5 equal instalments. A summary of the product attributes which may apply are set out below:

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, the likely objectives, financial situation and needs that the product has been designed to meet.

3.1        Target Market for the Product

Rello’s payment plan solutions enable tenants, landlords, prospective buyers, vendors and property owners the ability to make purchase of goods and services and defer the payment for these purchases by spreading the purchase price into a series of interest fee instalments over time.

At the time of a purchase and successful payment plan activation, the Customer pays a deposit (between 20% and 25% of the purchase price depending on the Payment Plan) followed by a series of 3 or 4 equal instalments for the balance of the purchase price in accordance with the Payment Schedule agreed by the Customer.

The product is designed for individuals who:

• require the ability to defer upfront purchases or expenses associated with a property over a series of instalments;
• require an online fulfilment and experience;
• want the option to pay now or pay later; and
• are either a tenant, landlord or property owner.

(the Target Market).

3.2       Eligibility

To be eligible for a Payment Plan, a customer must;

• be at least 18 years old;
• be a permanent resident or citizen of Australia;
• verifiable mobile telephone number and a valid address in Australia;
• hold a valid ID with either a driver’s licence or passport;
• have an Australian issued debit card to apply;
• demonstrate an ability to make payments when due;
• own their property or have an active tenancy agreement; and
• purchasing from an authorised merchant/agency.

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.

Specifically, the product is designed for consumers who have the financial capacity to service the ongoing financial obligations (including fees, if any) and repay the funds over time.

4          How this product will be distributed

4.1        Distribution

RelloPay payment plans will be distributed digitally through:

• Real Estate Agents facilitating multiple payment options to their customers that meet the eligibility criteria of the product; and
• Third party platforms that have a direct API integration with Rello and are the main supplier of technology to Real Estate Agency.

4.2       Adequacy of distribution conditions and restrictions

We have determined that the distribution conditions and restrictions will make it likely that customers who are open to the product are the type of end customers for which it 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 payment plans 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.