For the provision of credit through NAB Direct Debit Request (DDR) for the purchase of goods at Urban Rampage stores
Review period: At least every 12 months from the start date of this Target Market Determination
Start Date: 07/03/2024
Next Review Date: 07/03/2025
What is a Target Market Determination?
A Target Market Determination (TMD) describes the group of customers that the Product is designed for (Target Market) and any conditions as to how the Product is distributed to customers (Distribution Conditions).
It also describes the events or circumstances where we are required to review the Target Market Determination (Review Triggers).
Why does Coral Coast Distributors (Cairns) Pty Ltd (CCDC) trading as Urban Rampage need to have a Target Market Determination?
This TMD aims to give customers, our staff and other interested parties an understanding of who the Product is designed for, how the Product is distributed, and related information.
This TMD does not provide a complete summary of the Product’s terms and conditions and it is not meant to replace personalised financial advice.
Customers must review the DDR Service Agreement available on the Urban Rampage website and in the Urban Rampage stores when deciding whether to use this Product.
Urban Rampage stores are located in Katherine, Tennant Creek, Gove, Mount Isa, Alice Springs, Kununurra, Halls Creek, Derby, Broome and, South Hedland.
Target Market
We have identified the Target Market for the Product based on the Product’s key features and the intended customer objectives, financial situation, and needs. Below is a summary of the customer group that makes up the Target Market.
Class of customers
DDR has been designed for customers who:
- predominantly reside in remote Aboriginal communities
- may have limited access to buy basic household items for use by household members and need the ability to buy goods in bulk to bring back to their communities
- are low income or welfare recipients
- do not otherwise have access to retail credit
- have sufficient funds in their bank account to allow the direct debit deductions
- would like to be able to buy good/s now, receive the good/s immediately and pay later with no interest, late fees, or cancellation fees
- meet the eligibility criteria.
Excluded class of customers
The product may not be suitable for customers who:
- would like to buy goods that are not basic household items
- need long-term credit
- will be financially burdened by the direct debit deductions.
Eligibility criteria
To use the DDR, customers must meet the eligibility criteria. Customers must:
- be at least 18 years old
- not be under public trustee administration or a guardianship order
- be able to verify their identity
- have an Australian bank account with a BSB and account number in their name
- have the financial capacity to allow deductions (customers assessed to have less than $50 per fortnight of disposable income after applying CCDC’s credit assessment process will not meet the eligibility criteria)
- meet CCDC’s affordability assessment to determine the maximum spending limit
- use the product only to buy basic household items.
Customers who do not meet the eligibility criteria will not be able to buy goods using DDR.
Product attributes and consistency with target market
DDR has been designed to meet the needs of this class of customers. First-time customers start with a low spending limit and are required to satisfy their instalment payments before they can access a higher spending limit. The Product is suitable for people who would like access to credit with limited recourse, no fees and charges and who meet the eligibility criteria for the Product.
The product’s main features are:
| Main features | Suitability for target market |
| Limited spending credit | The amount of credit a customer is offered is assessed on a case-by-case basis based on each customer’s financial situation to allow the customer to buy basic household items and have payments made through direct debit from their bank account. |
| Customised repayments | Repayments are customised based on the customer’s financial situation |
| 4 fortnightly repayment schedule | Repayments are initially set to be paid off within 4 fortnightly instalments to ensure that customers do not find themselves in long-term debt. |
| Decrease or cancellation at any time | Allow flexibility in response to a change in the customer’s circumstances and accommodates a customer without putting them in financial distress. |
| Limited recourse against customers | CCDC does not enforce debts and does not participate in the credit reporting system. If customers do not comply with the terms of the direct debit deductions, CCDC will only decline customers from further credit to buy goods until the debt has been cleared. This is to make sure that the customer’s changing situation is accommodated without putting them in financial distress. |
| No interest is charged | Customers are protected from financial burden. |
| No fees, late fees, cancellation fees or other charges | Customers are protected from financial burden. |
| Limited to purchase of basic household items | Customers who travel from remote communities can buy basic household items in bulk and pay it off after returning to their communities. |
| No ‘discretionary pricing’ is applied on items purchased using the Product | CCDC does not inflate the price of goods if customers choose to use the Product to ensure that customers are protected from financial burden. |
Distribution conditions
The Product is designed to be distributed through CCDC’s Urban Rampage stores by CCDC staff members using the NAB Connect portal. DDR is a direct debit service available to customers using NAB Connect portal only.
The Product distribution conditions are as follows:
- Information will be obtained by having a Direct Debit Request form completed by the customer with the assistance of a CCDC staff member.
- The financial capacity of the customer will be determined by CCDC in accordance with CCDC’s credit assessment process (see below).
- The information in the Direct Debit Request form and the credit assessment process will be used to determine whether the customer is in the Target Market.
- Customers who do not meet the eligibility criteria from the information provided in the Direct Debit Request form and the credit assessment process will be excluded from the Target Market.
- CCDC staff members are trained to assess a customer’s eligibility criteria for the Product through on the job training by experienced staff. CCDC will conduct random shop audits to ensure staff are issuing the Product in accordance with this TMD and CCDC’s Store Operations Manual.
- Under CCDC’s credit assessment process, staff members will ask each customer to provide information on the following:
what Centrelink payments (if any) the customer receives
if there are any Centrepay deductions from the customer’s Centrelink payments
if there is other income the customer receives
how much the customer spends on essential expenses.
The information above will inform CCDC on whether a customer is eligible for the Product or is excluded from the target market.
- CCDC staff members are trained to administer and manage the deductions using NAB Connect portal in accordance with the Direct Debit Request form and the DDR Service Agreement.
- CCDC does not market the Product so customers who are not within the Target Market are not inadvertently targeted.
Reporting about the product
We will monitor the distribution of the Product and collect the following information:
| Information Type | Description | Reporting Period |
|---|---|---|
| Customer outcomes | Unexpected trends in customer outcomes that are not consistent with the Product’s intentions such as large volume of customers canceling their DDR arrangements or reporting financial difficulties. | As soon as practicable, and in any case within 10 business days after becoming aware |
| Complaints | Number of complaints | Every 3 months |
There are no regulated persons to whom this Product would compel reporting. Nevertheless, CCDC staff members who assist customers with the Product will be required to report the following information within the required timeframes:
| Information Type | Description | Time Frame for Reporting |
|---|---|---|
| Customer outcomes | Information about the number of complaints received, the nature and circumstances of the complaints, whether or not customers were harmed or suffered negative outcomes, and if so, what kind. | Every 3 months |
CCDC will endeavour to work co-operatively with third parties such as financial counsellors who provide advice to the Target Market and encourage them to provide CCDC with feedback on the Product.
Reviewing the TMD
We will undertake a review of the TMD as per the following:
| Initial review | At least every 12 months from the start date of this TMD |
| Review triggers or events | If we make a material change to the Product’s design or how it is distributed. For example, if we make a material change to the way we assess the financial capacity of a customer to use the Product or expand the list of goods that the product can be used for. If customers are allowed to use the Product to purchase goods that the Product is not intended for. For example, if customer have been allowed by our staff to use the Product to purchase non-basic household items. If we receive written complaints about this TMD from customers or customer’s advocates. For example, a complaint from a customer’s advocate advising of observed harmful customer outcomes as a result of using the Product. If there is a material increase in the proportion of customers of the Product not meeting their deduction schedule. If ASIC raises concerns about the product’s design or distribution. If the Australian Financial Complaints Authority or a court raises concerns about the Product’s design or distribution. If the Product’s design or distribution receive negative media coverage. If any other event happens indicating that this TMD may no longer be suitable. Where a review trigger or event occurs, we will review this TMD within 10 business days. |
Product Issuer: Coral Coast Distributors ABN 99 082 866 957