Target Market Determination

---

1. About this Document

This Target Market Determination (“TMD”) has been prepared by One Card Credit Pty Ltd (“OCC”) for its revolving Line of Credit (“LOC”) Product ‘Scorebuilder’ in compliance with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (“DDOs”). This TMD sets out the class of customer for which the Scorebuilder product has been designed having regard to the objectives, financial situation and needs of customers in the product’s target market.

OCC is the provider of the Scorebuilder credit facility promoted through the RentPay app. RentPay, owned by Rent.com.au. Scorebuilder is a Continuing Credit Contract, funded by OCC, accessed through RentPay which uses personal and rental payment information shared between RentPay and OCC to assess a customer’s initial and ongoing eligibility for the line of credit.

This TMD is not to be treated as a full summary of the product's terms and conditions and is not intended to provide financial advice. Customers must refer to the relevant terms and conditions under the product when making a decision about this product.

2. Class of consumers that fall within this target market

(a) Class of consumers that fall within this target market

Scorebuilder has been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the key attributes of the product.

Scorebuilder is for those consumers who are:

• currently renting a residential property or premises for private usage.
• using the RentPay app to make their rental payments.
• usually able to pay their rent without finance but want access to a safetynet which provides an alternative to traditional finance options with a short-term repayment structure for when unexpected, short term one-off expenses arise which may temporarily effect their ability to pay rent.
• seeking to avoid higher cost finance;
• comfortable with applying for and accessing a digital-only product.
• not currently experiencing financial hardship;
• able to make four fortnightly repayments for any amounts drawdown using the product without causing financial stress;
• seeking improvement in their credit score with independent credit reporting bodies without having to enter into higher cost loan contracts.

b) Excluded class of consumers

This product has not been designed for consumers who:

• are not using RentPay to make their regular rent payments;
• cannot demonstrate that they are able to make at least one month’s rent payments in full and on time.
• cannot afford the minimum repayments over two months via four fortnightly installments on the product without financial hardship;
• are in financial hardship;
• need immediate access to funds to pay their rent;
• are living in public housing; and
• not satisfy the OCC eligibility requirements.

(c) Eligibility requirements and product attributes

Eligibility requirements

All Scorebuilder consumers must be

• over 18 years of age;
• an active RentPay customer;
• able to afford to repay 25% of the credit limit per fortnight without financial hardship; and
• pass OCC’s internal credit assessment.

Product attributes

Scorebuilder is a revolving LOC that provides a 3-tiered credit limit based on the credit risk of a consumer.

Upon application for Scorebuilder, the applicant’s creditworthiness is assessed and, if approved, a conditional credit limit is assigned to the application.

This conditional limit will either be:

a) Nil (if based on the preliminary assessment the customer doesn’t currently qualify for a LOC)

b) the lesser of $150 or one week’s rent.

c) the lesser of $700 or one week’s rent.

Applicants are then required to complete a qualification period of either:

a) one month; or

b) three months;

depending on their credit risk as assessed by OCC.

During the qualification period:

a) there will be no drawdown for funds from the OCC LOC;

b) the consumer must make all their usual rent payments in full and on time through the RentPay app.

c) the consumer will pay only pay the Application Fee and Monthly Subscription Fees for the Scorebuilder product and Rentpay but no Periodic Fee.

If during the qualification period, the consumer makes all their usual rent payments in full and on time through the RentPay app, they will be given access to a drawdown up to their limit.

Even after the initial qualification period, on a monthly basis, RentPay will continue to report rental payment information to OCC which will be used for subsequent eligibility assessments.

If RentPay reports that any consumer has not paid their rent in full and on time, OCC will place a customer’s LOC on hold, thereby restricting their access to any further credit.

Accounts which:

a) are on hold for three months or more (not necessarily in succession) over the life of the product due to reports from RentPay; or

b) have five (5) missed payments within each twelve-month period will be closed.

Other key features of Scorebuilder include:

• Funds drawn down from the LOC are repaid over two months via four fortnightly installments.
• Simple online application and approval process.
• Transparent, legible and easily understood contract, including financial table and loan terms.
• Accessible via the RentPay mobile application for which the monthly Subscription Fee is $2.00.

Scorebuilder Fees

• Application Fee of $3.00
• Subscription Fee of $1.00 per month
• Periodic Fees when any amount is outstanding of:

  Repayment Frequency	Periodic Fee	Annual Cap
  Annual Cap	$2.00	$104.00
  Fortnightly	$4.00	$104.00
  Monthly	$8.67	$104.00

• Missed payment fee of $15.
  All Fees and Charges, including Missed Payment Fees and taking into account the Rentpay monthly Subscription Fee, are capped at $200 for the First Year and $125 in any subsequent years.

3. Consistency between target market and the Product

The product is consistent with the identified target market due to the following key terms, features, attributes and controls:

• Applications are only accepted via the RentPay distribution channel, thereby ensuring only RentPay customers are able to apply;
• Monthly rental payment information reporting from RentPay further ensures Scorebuilder customers remain RentPay customers;
• Data provided by RentPay ensures that Scorebuilder customers are currently renting;
• Monthly rental payment information provided by RentPay allows us to ensure Scorebuilder customers are able to make their ongoing rental payments in full and on time;
• Our assessment process assists us to identify consumers who are:
  • regularly unable to make their rent payments; or
  • are otherwise at risk of not making their Scorebuilder payments; without financial hardship.
• The qualification period during which customers must continue to make their ongoing rental payments via the RentPay app before gaining access to the LOC ensures customers are not able to apply for Scorebuilder and immediately access credit if they are financially vulnerable;
• The tiered approach to the LOC limit allows OCC to monitor customers with an assessed higher credit risk over a longer period of time before granting them access to a LOC thereby reducing the risk that credit is granted to someone who can’t afford it;
• Under comprehensive credit reporting rules, a customer’s LOC facility conduct is reported to a credit reporting body each month. This allows all customers who take out Scorebuilder, whether being utilised or not, to potentially increase their credit score with an independent credit reporting body over time;
• ● Offering consumers with a lower credit score who do not qualify for other more expensive credit products he ability to demonstrate their positive payment behaviour through their rental payment information.

4. Distribution Channels and Conditions

• There is only one distribution channel for this product which is RentPay Technology Pty Ltd under our written agreement with them.
• We regularly monitor their website to ensure that it contains:
  • No misleading information;
  • All relevant disclosures and warnings required by law;
  • An easy to follow process during which the consumer is given informed choices at every stage.
• Our own website contains:
  • No misleading information;
  • All relevant disclosures and warnings required by law;
  • An easy to follow process during which the consumer is given informed choices at every stage.
• We do not make any unsolicited offers of credit.
• We have adopted the following Distribution Conditions to ensure that our product is distributed appropriately to its target market:
  • No consumer renting in public housing is able to apply for Scorebuilder via the RentPay app.
  • No loans for business purposes;
  • We only accept applications from RentPay Technology Pty Ltd;
  • We engage Fin-Tech Services (Aust) Pty Ltd to conduct preliminary assessments of the creditworthiness of applicants;
• All drawdowns are paid to the consumer’s RentPay wallet to only be used for payment of rent not cash or other purchases.
• No access to a first drawdown will be given to a consumer who:
  • fails to pay rent through the RentPay app in full and on time during their qualification period;
  • otherwise does not satisfy the OCC credit risk assessment criteria
• No access to further drawdowns for consumers will be allowed if:
  • RentPay reports that in the preceding month the consumer did not pay rent through the Rentpay app in full and on time; or
  • the consumer misses a payment required under their OCC Scorebuilder contract;
• Any consumer who misses five (5) or more payments under their OCC Scorebuilder contract within each twelve-month period from account opening, or has their account placed on hold for three months or more (not necessarily in succession) over the life of the product due to failure to meet their rental payment obligations, will have their Scorebuilder account closed.

We are not required to undertake a full responsible lending credit assessment under the National Consumer Credit Protection Act 2009. Our credit assessment process does include;

a. recent rental payment information; b. a credit check, conducted in the preliminary assessment, which demonstrates capacity to meet recent credit obligations;

Reviewing this TMD

Review Triggers

• The proportion of accounts that have missed one or more payments is equal to or exceeds 7% of the number of accounts with an available credit limit at any time.
• The proportion of accounts that have had negative repayment history information reported to a Credit Reporting Body is equal to or exceeds 15% of the number of accounts that have an available credit limit and have drawn down funds.
• The proportion of accounts for which RentPay reports missed rental payments in the preceding month is equal to or exceeds 10% of the number of accounts with drawdowns at any time.
• The number of complaints from approved customers in a 3-month period increases by 10% or more.
• The number of consumers seeking hardship relief or restructuring of payments in a month exceeds 5% of the number of accounts with drawdowns at the end of that month.
• The proportion of accounts that have drawn down funds four or more times in the preceding twelve months is equal to or more than 25% of the number of the number of active accounts that have an available credit limit and have drawn down funds.

The Responsible Manager will collect, assess and review all the above data every month.

We will also respond to external sources such as:

• AFCA;
• ASIC;
• Community based consumer organisations

and if:

a. Complaints to these external sources increase by 10% over a 3-month period; or

b. AFCA reports a “Systemic Breach” to ASIC;

We will review this TMD.

If any of the above Trigger Events occur, this will trigger a review as if it were a Periodic Review as below.

Periodic Scheduled Reviews

• We will conduct annual periodic reviews whether or not a trigger event has occurred in the previous quarter.
• The responsible manager will conduct all reviews of this TMD.
• The responsible manager will report the board of directors of One Card Credit Pty Ltd within ten (10) business days of conducting a review as to:
  • Whether any trigger events have occurred.
  • What factors may have caused these trigger events to occur.
  • Which of the follow actions we should take:
    • No change if all of our DDOs as published above are being met;
    • The product needs a redesign;
    • A new distribution condition is required; or
    • The product must cease to be offered.

Reporting & Significant Dealings

If at any time, we detect that more than 10% of the consumers receiving our product within a three (3) month period are not within our Target Market, we shall report this to ASIC as a Significant Dealing within ten (10) business days.