Target Market Determination

Effective Date: 20 September 2023

ListSure Retail Finance Pty Ltd ACN 655 912 977 (ListSure) is an Australian Credit License holder (ACL 536827). The Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 require ListSure to publish our Target Market Determination.

A Target Market Determination describe who our products are appropriate for (target market), and any conditions and restrictions around how our products can be distributed to consumers. We also describe the events or circumstances where we may need to review this document.

We are committed to creating and maintaining a client-centric approach to the design and distribution of our products. The purpose of our Target Market Determinations is to ensure our products are suitable for the consumers we target.

Introduction – About ListSure

ListSure provides property owners who are preparing to sell their property (Property Sellers) with the ability to defer their sale costs to better align their repayment obligations with the receipt of sale proceeds. This provides Property Sellers with the ability to maximise their upfront investment in the sale of the property while managing their cash flow.

Examples of the sort of sale costs typically incurred when selling a property include:

  1. marketing and advertising costs paid to the real estate agent;

  2. ancillary costs relating to the sale of the property such as property styling, conveyancing or pest and building inspections; and

  3. minor renovations and repairs to the property.

(collectively Sale Costs).

The products that are offered by ListSure are bridging loans. This means that Property Sellers are expecting to receive a lump sum when the sale of the property settles and are intending to discharge their obligations from that lump sum.

Pay Later – Target Market Determination

Pay Later is a financial product offered by ListSure. Pay Later offers Property Sellers the ability to defer the payment of their Sale Costs in order to align their repayment obligation with the receipt of sale proceeds. In the unusual circumstances that the property does not sell, the Property Seller remains liable to repay the loan to ListSure out of their own funds.

Product description

Below is a description of the key attributes that affect whether this product is likely to be suitable for the needs of the target market.

  • a fixed cost short-term bridging loan to fund the property sale costs once these costs have been agreed with the real estate agency or service provider;

  • payment is made directly to the real estate agency, service provider, or borrower;

  • the bridging loan is required to be repaid on the earlier of settlement, deposit release, withdrawal of the property from sale, or 180 days.

Objectives, financial situation and needs

This product is designed to enable a class of consumer to make purchases whose likely needs, objectives and financial situation (outlined below) are aligned with this product and its key attributes, including consumers who:

  • do not wish to pay their Sale Costs upfront and would prefer to defer the repayment obligation to better align with the receipt of sale proceeds; and

  • have the financial capacity to pay the Sale Costs and associated fees and interest when the amount becomes payable and due.

This product is not suitable for consumers who:

  • do not meet the eligibility criteria;

  • are below the age of 18;

  • have low levels of financial literacy;

  • have low levels of technological literacy;

  • are in, or likely to experience, financial hardship

  • are going through bankruptcy; or

  • are vulnerable, including those who are:

    • suffering any form of cognitive impairment;

    • unemployed;

    • suffering from any illness affecting capacity;

    • suffering from any form of addiction; or

    • suffering from personal or financial circumstances causing significant detriment.

The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria is met, consumers will be deemed ineligible to receive the product.

Consistency between target market and product

This product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of the class of consumers in the target market, as we consider that it provides the required type of finance for that class of consumers.

We have made this determination based on an assessment of this product, including its key attributes. Individual consumers will need to consider whether this product meets their specific objectives, financial situation and needs.

Distribution

The following distribution conditions apply to this product:

  • The product can only be distributed to Property Sellers who submit an application through ListSure’s digital portal.

  • The product is only offered to Property Sellers who have (or shortly will) appoint a real estate agency.

  • The product is limited to those Property Sellers that meet our eligibility requirements that include a signed sales authority with the real estate agency and an agreed marketing budget (where requested).

The distribution conditions will make it likely that consumers who acquire this product are in the target market, being Property Sellers of Australian real estate. We consider that the distribution conditions are appropriate and will enable us to direct this product to the class of consumers who fall within the target market set out above and benefit from this product. This has been determined based on an assessment of the distribution conditions and the target market.

Review

We will review this Target Market Determination in accordance with the below:

  • Initial review. Within 1 year of the effective date.

  • Periodic review. At least annually from the initial review.

  • Review triggers. When any event or circumstance arises that suggests this Target Market Determination is no longer appropriate. This includes (but is not limited to): 

    • a material number of customers are experiencing financial hardship as a result of obtaining this product;

    • receipt of a large volume of complaints by us or a distributor;

    • material changes to the key attributes of this product or the manner of distribution that is likely to result in the determination not being appropriate for the target market;

    • change in law that result in the design of the product not being appropriate for the target market;

    • a material number of customers not using the product for the purpose of funding Sale Costs relating to the sale of their property;

    • a material number of customers that are not property owners applying for the product;

    • where we detect issues with the distribution of this product through the monitoring of daily business activities as well as the monitoring and supervision of distributors; and

    • the occurrence of a significant dealing that is inconsistent with this determination.

Reporting and monitoring

We collect the following information from customers and distributors in relation to this Target Market Determination:

  • Complaints. Report all complaints in relation to this product on a monthly basis. This will include written details of the complaints.

  • Significant dealings. Report if they become aware of a significant dealing in relation to this product that is inconsistent with this Target Market Determination within ten (10) business days.

  • Feedback. Report all feedback in relation to this product (including the performance of this product) on a quarterly basis.

Pay On Success® – Target Market Determination

Pay On Success® is a financial product offered by ListSure. Pay On Success® offers Property Sellers peace of mind that they only pay their Sale Costs when the sale of the property settles. This means that if the property does not sell, and the Property Seller has complied with the terms and conditions of the loan and is not otherwise in default, then the Property Seller is not required to repay the principal amount to ListSure.

Product description

Below is a description of the key attributes that affect whether this product is likely to be suitable for the needs of the target market.

  • a fixed cost short-term bridging loan to fund the property sale costs once these costs have been agreed with the real estate agency or service provider;

  • payment is made directly to the real estate agency or service provider;

  • if the property is sold within 1 year then the bridging loan is required to be repaid; and

  • if the property has not sold within 1 year then the bridging loan is not required to be repaid, provided the customer has complied with all terms and conditions and is not otherwise in default.

Objectives, financial situation, and needs

This product is designed to enable a class of consumer to make purchases whose likely needs, objectives and financial situation (outlined below) are aligned with this product and its key attributes, including consumers who:

  • do not wish to pay their Sale Costs upfront and would prefer to defer the repayment obligation to better align with the receipt of sale proceeds; and

  • have the financial capacity to pay the Sale Costs and associated fees and interest when the amount becomes payable and due.

This product is not suitable for consumers who:

  • do not meet the eligibility criteria;

  • are below the age of 18;

  • have low levels of financial literacy;

  • have low levels of technological literacy;

  • are in, or likely to experience, financial hardship

  • are going through bankruptcy; or

  • are vulnerable, including those who are:

    • suffering any form of cognitive impairment;

    • unemployed;

    • suffering from any illness affecting capacity;

    • suffering from any form of addiction; or

    • suffering from personal or financial circumstances causing significant detriment.

The product is only provided to consumers who are assessed as eligible to receive it. All consumers must provide the relevant documentation and evidence to use the product. Unless the criteria is met, consumers will be deemed ineligible to receive the product.

Consistency between target market and product

This product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of the class of consumers in the target market, as we consider that it provides the required type finance for that class of consumers.

We have made this determination based on an assessment of this product, including its key attributes. Individual consumers will need to consider whether this product meets their specific objectives, financial situation and needs.

Distribution

The following distribution conditions apply to this product:

  • The product can only be distributed to Property Sellers who submit an application through ListSure’s digital portal.

  • The product is only offered to Property Sellers who have appointed a real estate agency.

  • The product is limited to those vendors that meet our eligibility requirements that include providing a signed sales authority with the real estate agency and an agreed marketing budget (where requested).

The distribution conditions will make it likely that consumers who acquire this product are in the target market, being Property Sellers of Australian real estate. We consider that the distribution conditions are appropriate and will enable us to direct this product to the class of consumers who fall within the target market set out above and benefit from this product. This has been determined based on an assessment of the distribution conditions and the target market.

Review

We will review this Target Market Determination in accordance with the below:

  • Initial review. Within 1 year of the effective date.

  • Periodic review. At least annually from the initial review

  • Review triggers. When any event or circumstance arises that suggests this Target Market Determination is no longer appropriate. This includes (but is not limited to): 

    • a material number of customers are experiencing financial hardship as a result of obtaining this product;

    • receipt of a large volume of complaints by us or a distributor;

    • material changes to the key attributes of this product or the manner of distribution that is likely to result in the determination not being appropriate for the target market;

    • change in law that result in the design of the product not being appropriate for the target market;

    • a material number of customers not using the product for the purpose of funding Sale Costs relating to the sale of their property;

    • a material number of customers that are not property owners applying for the product;

    • where we detect issues with the distribution of this product through the monitoring of daily business activities as well as the monitoring and supervision of distributors; and

    • the occurrence of a significant dealing that is inconsistent with this determination.

Reporting and monitoring

We collect the following information from customers and distributors in relation to this Target Market Determination:

  • Complaints. Report all complaints in relation to this product on a monthly basis. This will include written details of the complaints.

  • Significant dealings. Report if they become aware of a significant dealing in relation to this product that is inconsistent with this Target Market Determination within ten (10) business days.

  • Feedback. Report all feedback in relation to this product (including the performance of this product) on a quarterly basis.