Spot TMD

This Agreement is effective: 30th September, 2024

Table of contents:

What is a Target Market Definition (TMD)?

A Target Market Determination (TMD) describes the cohort of customers that the product is targeted at (the Target Market) and any conditions around how the product is distributed to customers (the Distribution Conditions).

It also describes the events or circumstances where we are required to review the Target Market Determination for a financial product. (the Review Triggers).

Why does this Douugh product need to have Target Market Determinations?

We’re required to have Target Market Determinations under law. The purpose of the law is to make sure customers are at the center of our approach when designing and distributing our financial products. This document is not a substitute for the product’s terms and conditions or other disclosure documents.

When making a decision about this product, customers must refer to the relevant Product Disclosure Statement (PDS), Terms and Conditions or other disclosure documents.

Target Market

The table below matches the Product Attributes to the Objectives and Needs of the Target Market for this Product. Douugh has assessed that the Product, including its Key Attributes are likely to be consistent with the Objectives and Needs of the Target Market.

Product Description

The Douugh Spot Jar is a digital, mobile app only product which offers users the opportunity to obtain short term loans of up to $2000, a ‘Spot’, with the payment amount split over a number of instalments over 4 weeks. 

Upon the due date of each instalment, the instalment amount is automatically debited from their nominated funding source (i.e. a debit or credit card linked to a bank account). The first instalment is taken 1 week following their Spot amount being provided.

The Douugh Spot Jar, is part of a suite of services offered through the Douugh App. This TMD refers specifically to the Douugh Spot Jar, issued by INMO Capital Pty Ltd.  For information on the other services available within the Douugh App please see https://douugh.com/

Objectives and Needs

Product Attributes

Require the ability to ‘buy now pay later’ on any purchase

  • Customers can draw down on the credit limit and transfer funds to a nominated external bank account in their name

  • Spot Jar transactions will be re-paid in weekly interest free repayments.

  • Customers can have multiple Spots up to their awarded credit limit with repayment period on Pay Now or pay later in no more than 62 days.

  • Flat Establishment fee per Spot drawdown against the available credit limit of $9.99, charged each time a Drawdown is made.

  • The total fees charged over the first year does not exceed $200 and the total fees charged for any subsequent 12 month period does not exceed $125.

  • There are no late fees, or interest on the Product

  • Customers will have a credit limit, based on a credit assessment of the customer, and will not be able to borrow more than their current credit limit. 

  • The customer’s account will be blocked if they default in making scheduled instalment repayments and they will be unable to use the Spot facility further, until the account is returned to an up-to-date state.

  • INMO Capital has readily available assistance for customers in hardship which includes but is not limited to, extended payment plans.

Financial Situation

The Financial Situation of the Target Market are customers that: 

  • Meet Douugh’s credit assessment criteria which includes demonstrating the capacity to service the credit facility without substantial hardship; and 

  • Choose a credit limit of up to a maximum initial credit limit of $2000.

Douugh views that its processes in place, including assessing the customer’s ability to service the credit facility, will mean that the product will likely be consistent with the Financial Situation of the Target Market.

Issuer name

INMO Capital Pty Ltd

Issuer ABN

44 676 813 764

Regulatory status

This product is issued pursuant to the Continuous Credit Exemption Under section 6(1) of the National Credit Code.

 

Under section 12BAA of the Australian Securities and Investments Commission Act 2001 (Cth), the provision of credit pursuant to that exemption remains subject to the design and distribution requirements of the Corporations Act. 

Type of Customer

This product is designed for 

  • People who are seeking a product to assist them in providing short-term funding up to $2000 and:

  • Are looking for flexibility in cash flow management and to smooth payments over a period of time.

To hold this product, customers will need to satisfy certain eligibility criteria, including that customers must:

  • Are comfortable with the simplicity of a digital-only product. 

  • be individuals aged 18 years or older;

  • have an Australian residential address; and are either:

  • An Australian citizen; or

  • An Australian resident (visa subclass holder); or

  • A New Zealand citizen; or

  • An eligible non-resident visa holder.

  • will use the credit in their individual capacity for personal use. 

  • hold a valid and verifiable email address, mobile number and residential address.

  • meet INMO Capital's credit assessment criteria which focuses on the customer’s capacity to service and repay the credit facility which includes demonstrating the capacity to service the credit facility without substantial hardship

Excluded Customers

This product is not suitable for:

  • Applicants under 18 years of age. 

  • Do not have an Australian residential address; and are not:

    • An Australian citizen; or

    • An Australian permanent resident (permanent visa subclass holder); or

    • A New Zealand citizen; or

    • An eligible non-resident visa holder.

  • Applicants who are not individuals.

  • Applicants with a history of poor credit, as indicated by credit bureaus, or who do not meet the platform credit criteria.

  • Applicants who cannot be matched against a credit bureau record.

  • Applicants who cannot verify their identity to the satisfaction of Douugh, or INMO Capital. 

  • Applicants who do not have a valid and verifiable residential address, email address and Australian mobile number. 

  • Applicants who are not the holder of a valid and verified Australian-issued debit or credit card attached to a bank account. 

  • Applicants who are not able to access the product through digital means.

Target Market Appropriateness

INMO Capital considers that the product (including its key attributes) is likely to be consistent with the likely objectives, financial situation and needs of consumers as it provides the means for Consumers to access funds in the form of a short-term loan to facilitate their purchase requirements.

Distribution Conditions/Restrictions

The Douugh Spot Jar is distributed solely by Douugh Australia Pty Ltd ABN 76 617 000 138. Douugh may only market and promote the product through:

  1. advertising through media (including social media), physical marketing materials (such as banners, brochures or flyers) and any other marketing material available to the general public; and

  2. any other INMO Capital approved communication channels (including telephone, email and social media).

It has been determined that the distribution conditions and restrictions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed. The distribution conditions are appropriate and will direct distribution towards the target market for whom the product has been designed (for example consumers with digital experience given this product is distributed and administered online). These distribution conditions are supported by INMO Capital's application handling processes, which include checks to ensure the consumer is eligible for credit under the Douugh Spot Jar.

Review Triggers

If any of the below review triggers occur, or if an event or circumstance has occurred that would reasonably suggest that the TMD may no longer be appropriate, INMO Capital will undertake a review of this TMD:

Information Type

Description

Customer Outcomes

Unexpected trends in customer outcomes which are significantly inconsistent with the intended product performance, including:

• customers who are closing their account prior to usage 

• customers in hardship arrangements; and 

• customers who are consistently reaching the product late fee cap.

Significant or unexpectedly high numbers of missed repayments or bad debt rates being higher than our tolerance.

Complaints

Significant or unexpectedly high number of complaints (as defined in section 994A(1) of the Act) regarding product design, product availability or any distribution condition, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.

Incident Data

A material incident or significant number of incidents in relation to the product’s design or distribution that identify potential breaches of our legal or regulatory obligations.

Changes to the Product

Material change to key product attributes, terms and conditions, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.

Significant Dealings

Any significant dealing of the product to customers who are outside of the Target Market.

assa

The receipt of a product intervention power order from ASIC requiring Douugh to immediately cease retail product distribution conduct in respect of the product.

Product Intervention Powers

The use of Product Intervention Powers, regulator orders or directions in relation to the distribution of this product, where the product issuer considers this reasonably suggests that this TMD is no longer appropriate.

Design or distribution breach

A significant breach event relating to the design or distribution of this product, where the product issuer considers this would reasonably suggest that (i) this product is unsuitable for a particular cohort of customers or (ii) the TMD may no longer be appropriate.

The review period allows for the collection of data for 1 year, plus three months for the completion of the review.

Distributor Information Reporting Requirements

Regulated person(s)

Requirement

Reporting deadline

All distributors

To the extent a distributor is aware of dealings outside the target market these should be reported to the issuer, including reason why acquisition is outside of target market, and whether acquisition occurred under personal advice.

Quarterly *

All distributors

Complaints (as defined in section 994A(1) of the Act) where the nature of the complaints relate to product design, product availability and distribution conditions. The distributor should provide all the content of the complaint, having regard to privacy.

Quarterly *

All distributors

Significant dealing outside of the target market under section 994F(6) of the Act.

As soon as practicable but no later than 10 business days after the distributor becomes aware of the significant dealing.

* Quarterly reporting is due 10 business days after the end of the March, June, September and December quarters.

Other Information

INMO Capital reserves the right to amend the TMD at any time if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance or for any reason INMO Capital considers as a proper reason to amend the TMD. 

If you have any questions about our products or this TMD, please contact us on andy@stakk.tech

Legal Disclaimer

A Target Market Determination (TMD) is required under section 994B of the Corporations Act 2001 (Cth) (Corporations Act). It sets out the target market for the product, triggers to review the target market and certain other information. It forms part of INMO Capital's design and distribution framework for the product.

This document is not a product disclosure statement and is not a summary of the product features or terms of the product. This document does not consider any person’s individual objectives, financial situation or needs. Persons interested in acquiring this product should carefully read the terms and conditions at https://douugh.com/disclosures before deciding whether to buy this product.