Target Market Determination

Product: Pay As You Learn (PAYL) Product issued by EdFin Pty Ltd (ABN 15 627 221 292, Australian Credit Licence 549 660)

1. About this document

This document is not intended to provide financial advice, customers should refer to the Terms and Conditions and any supplementary documents when making a decision about this product.

This target market determination (TMD) seeks to offer distributors and staff with an understanding of the class of consumers for which this product has been designed, having regard to the likely objectives, financial situation and needs of the target market. 

This document is not to be treated as a full summary of the product’s terms and conditions and is not intended to provide financial advice. Consumers must refer to the relevant Terms and Conditions and other Supplementary Documents which outline the relevant terms and conditions under the product when making a decision about this product.

Terms and Conditions to which this target market determination applies

This TMD applies to the Pay As You Learn Product referred to in the following Terms and Conditions: 

  • Personal Loan Terms and Conditions
  • Information Statement
  • Credit Guide
  • Credit Proposal Disclosure Document

Date from which this target market determination is effective

21 February 2024

2. Class of consumers that fall within this target market

The information below summarises the overall class of consumers that fall within the target market for Pay As You Learn Product, based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet.  

This Pay As You Learn Product has been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the product (including the key attributes). Accordingly, The Pay As You Learn Product is for consumers who:  

  • Require an loan to assist with financing tertiary education studies because they are unable to pay  the upfront costs of those studies; and
  • require the flexibility of making additional repayments without penalty.

Product description and key attributes  

The key product attributes of the Pay As You Learn Product are:  

  • The amount that can be financed under this product is between $2,001 and $20,000;
  • The Pay As You Learn term in which the student can repay the amount borrowed can be between 4-12 Months;
  • Establishment Fee of $125 or $250 added to the amount advanced under the Pay As You Learn Product. The Establishment Fee is determined by EdFin based on the level of preparatory work required to advance the loan to the borrower;
  • Monthly Pay As You Learn Fee is $0.00 per month payable by the student;
  • Loan Variation Fee of $35 payable if you ask to vary any term of your loan and we agree to the variation.
  • Direct Debit Request Dishonour Fee $15 per dishonour Payable if we are unable to process a direct debit from your account.
  • Late Payment Fee $10 per late payment If we are unable to process a direct debt from your account and the payment remains outstanding, the fee is payable when the repayment is 5 days overdue, and again every 14 days thereafter, until arrears are cleared or a cap of $210 is reached. 
  • The Pay As You Learn Product charges interest of between 19% and 25% of the Pay As You Learn Loan Amount;
  • There are no early repayment penalties for paying out the Pay As You Learn Product early;
  • The student borrows to cover tuition and other education related costs to enable participate fully in their education;
  • The funds under the Pay As You Learn Product maybe advanced directly to the vendors or to the student nominated account;
  • The funds are released directly to the vendors to ensure the funds are used for the purpose in which they were intended; and
  • The student independently identifies the course of study that is right for them. 

The key eligibility requirements of this Pay As You Learn Product are that the applicant for the facility must:

  • Be 18 years of age or older;
  • Be an Australian Citizen or Permanent Resident or Temporary Resident;
  • Be enrolled at Australian tertiary education institution 
  • Be employed in a full-time, part-time, or casual job;
  • Demonstrate serviceability of the Pay As You Learn loan;
  • Have a valid mobile telephone number and email address;
  • Have good credit without any adverse listings;
  • Have positive bank account conduct in the last 90 days; and
  • Be able to provide 3 months of bank statements

Objectives, financial situation, and needs  

This product has been designed for individuals who:  

  • require an amount of credit to fund tertiary education studies of their choice with an accredited education providers;
  • wish to repay the Pay As You Learn loan over a 4–12-month period;
  • are able to provide EdFin with sufficient financial evidence of their ability to be able to service the Pay As You Learn loan;
  • Are able to pay the associated fees and charges; and
  • require a loan to finance tertiary studies, which will allow them to :
    • Increase their existing skill set in an area of study of interest to advance their career opportunities or advance their understanding in the chosen study area;
    • Learn new skill sets that are of interest to the student for further career development or advancement or to further strengthen their skills and interests in a specific area; and/or
    • Obtain the necessary credentials, skills and understanding to change their career direction, strengthen their career progression or explore potential education fields of interest.

Excluded class of consumers 

This product has NOT been designed for individuals who:  

  • Who are Bankrupt, or a participant in a Part IX or Part X Agreement;
  • Have bad credit or adverse credit behaviour;
  • Income source is solely government welfare;
  • Are unemployed;
  • Expect their financial circumstances to change in the future;
  • Are under the age of 18; or
  • Are not a resident of Australia. 

Consistency between target market and the product   

This product (including its key attributes) has been assessed as meeting the likely objectives, financial situation and needs of consumers in the target market because it provides them with access to tertiary studies with accredited education providers by financing the associated upfront costs and spreading it over a fixed term. 

3. How this product is to be distributed

Distribution channels

This product is designed to be distributed through the following means: 

  • Direct: By contacting EdFin Sales & Support Team via customer.service@edfin.com.au;
  • Digital Marketing: via our websites and social media channels; 
  • Physical Marketing: In person or poster marketing at accredited education providers premises; and 
  • Distributors: through entities such as accredited education providers, community organisations and student groups that are approved by EdFin

Distribution conditions and restrictions

This product should only be distributed under the following circumstances: 

  • To individuals who meet the eligibility criteria;
  • To individuals who have appropriate capacity to repay the Pay As You Learn repayments within the framework of our Responsible Lending Policy of EdFin;
  • To individuals who fall within the target market;
  • All applications must be submitted through the EdFin Application and Lending Platforms or via platforms provided to distributors by EdFin from time to time; 
  • This product is only available to consumers within the Education Sector;
  • Distributors other than EdFin as the Distributor must be accredited by EdFin; and
  • Accredited Distributors (Education Providers) who lose their accreditation for any reason are prohibited in providing any EdFin Product without the written consent of EdFin or its Representatives. 

Adequacy of distribution conditions and restrictions  

This product has been designed for a specific segment of consumers. Distributors following the Distribution Conditions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed for. 

The distribution channels are appropriate because:

  • our distributors have been adequately trained and have the necessary skills and knowledge to distribute this product in accordance with the TMD;
  • our application and approval process has controls in place to ensure all approved consumers meet our eligibility and lending requirements; and
  • We conduct upfront and ongoing review and monitoring of distributors and distribution conditions and restrictions.

4. Reviewing this target market determination 

We will review this target market determination in accordance with the below:

Where a review trigger has occurred, this target market determination will be reviewed within 10 business days. Meanwhile, we will cease to offer this product to our consumers until our review concludes and any necessary changes to the product or target market determination, including distribution methods, are made.

5. Reporting and monitoring this target market determination

The following information must be provided to EdFin by our distributors:

Type of InformationDescriptionReporting Period
ComplaintsDistributors will report all complaints in relation to the product(s) covered by this TMD on a Monthly basis. This will include written details of the complaints.As soon as practicable and in any case within 10 business days of receipt of complaint.
ComplaintsNumber of complaints.Every 3 months.
Significant dealingsAny significant dealing which is not consistent with this TMD.As soon as practicable, and in any case within 10 business days of becoming aware.
Other information requiredOther distribution information may be required from Distributors such as transaction data, outcomes from sales monitoring, notes and phone recordings relating to those dealings.Within 10 business days of a reporting period, when requested. 

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