Target Market Determination
Flash Money Pty Ltd
Warning about borrowing
Do you really need a loan today?
It can be expensive to borrow small amounts of money and borrowing may not solve your money problems. Check your options before you borrow:
- For information about other options for managing bills and debts, ring 1800 007 007 from anywhere in Australia to talk to a free and Independent financial counsellor
- Talk to your electricity, gas, phone or water provider to see if you can work out a payment plan
- If you are on government benefits, ask if you can receive an advance from Centrelink: Advance Payments
The Government’s MoneySmart website shows you how small amount loans work and suggests other options that may help you.
* This statement is an Australian Government requirement under the National Consumer Credit Protection Act 2009.

INTRODUCTION
This Target Market Determination (TMD) has been prepared by Flash Money Pty Ltd with Australian Credit Licence 508661.
This document is intended to comply with our obligations under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019, which requires the determination of a target market for our products, and associated purposes. It will give the consumer assistance in determining whether the product is aimed at them, whilst at the same time allowing us to gauge whether the products are meeting their intended market. This document is called the Target Market Determination, hereinafter referred to as “TMD.
This document aims to give consumers and, where appropriate, distributors, an understanding of the target consumer group for which the product is designed. It considers the objectives, needs, and financial situation of those within the target market.
This TMD is not intended to replace other documents related to our products that outline the terms and conditions upon which you should rely when deciding whether to apply for the product. This includes but is not limited to, the contract document that will be sent to you before you enter into an agreement with us.
PRODUCT
The product to which the TMD relates is the SMALL AMOUNT CREDIT CONTRACT (“SACC”) and the MEDIUM AMOUNT CREDIT CONTRACT (“MACC”) offered by us, as those terms are defined in section 5 of the National Consumer Credit Protection Act 2009, and schedule 1 of the National Consumer Credit Protection Act 2009 that is, loans in which:
For SACC:
- the amount borrowed is less than $2000, and
- the loan period is no longer than 1 year and
- the principal borrowed along with fixed credit charges – An establishment fee of 20% of the Amount Financed and a Monthly fee of 4% of the Amount Financed per month, are repaid in equal instalments.
For MACC:
- the amount borrowed is between $2,001 and $5,000 and
- the loan period is between 16 days and 2 years and
- a one-off establishment fee not exceeding $400 and a maximum annual interest rate of 48%
TARGET MARKET
SACCs and MACC’s have been designed for consumers who:
- need a loan of an amount between $300.00 and $5,000.00 for any legal personal purpose;
- have a regular income,
- have an acceptable credit history;
- need a rapid response to the loan application;
- are not in financial hardship,
- have the legal capacity to enter into a loan agreement, and
- have the financial capacity to make the principal repayments, fees and interest in instalments over the short term which is no longer than 12 months
These are regarded as the key attributes of the loan.
CONDITIONS AND RESTRICTIONS ON SUPPLY
We will not supply a SACC or a MACC to any consumer:
- who is not of legal capacity (either by age or mental or other disability);
- who is in financial hardship (or who in our opinion is likely to be so within the foreseeable future);
- who does not presently have the capacity to repay the loan within the expected loan length, or
- where the loan, if provided, would not meet the consumer’s requirements or objectives.
HOW WILL WE KNOW IF THE PRODUCT IS NOT MEETING THE TARGET?
Based on the description of the target market above, we believe it is unlikely that the product will fail to meet the target market. Nevertheless, we will monitor the consumers who access the loans to ensure that the majority fall within the target market. If they do not, we will review the product and adjust its key attributes to better align with the target market.
DISTRIBUTION
The method of distribution to consumers will be directly through us, the credit provider. Access to our products will primarily be available via our website or by direct contact with us. We do not use authorized representatives or agents for distribution purposes
REVIEW
We will review this TMD on the occurrence of any of the following triggering events
- on there being a relevant amendment to the National Consumer Credit Protection Act or any associated Act or Regulation which has the effect of significantly altering the rules relating to the provision of SACCs or MACCs
- on the occurrence of a “significant dealing”. We will consider whether there has been a significant dealing:
- where a significant proportion of consumers who take out a SACC or a MACC are not in the target market;
- there is actual or potential harm to those consumers who access to product and are not in the target market;
- the extent to which the income gained from those outside the target market is different to those within the target market
- the period of time over which those outside the target market took out SACCs or MACCs
- on the occurrence of any of the following events:
- the number of complaints to AFCA in relation to SACCs or MACCs exceeding 0.5% of the number of SACCs or MACCs entered into in any calendar month,
- the number of internal complaints made by consumers in relation to SACCs or MACCs exceeding 1% of the number of SACCs or MACCs entered into in any calendar month,
- the receipt of more than one letter from ASIC or any regulator in relation to the method of the provision of SACCs or MACCs in any calendar month.
- on or about the 31st October, being the yearly anniversary of the TMD
- if there is no other triggering event, each two years from the last review.
A triggering event will require the review to be undertaken within one month.
REPORTING
As noted above, we do not use distributors in the provision of SACCs or MACCs to consumers. As a result, whilst the law requires a TMD to set out what information must be provided by distributors to us, in our view, this is not necessary. The TMD will be revisited if we commence the distribution