Skip to content
Orange_key

Target Market Determination

This document is a target market determination (“TMD”) for the purposes of section 994B of the Corporations Act 2001 (Cth).

This TMD is made by Reaia Deposit Finance Pty Ltd ABN 76 107 973 544 Australian credit licence number 38 45 30 (the “Issuer”), the issuer of the product covered by this TMD (the “Product”).

This TMD was made or last updated on 28 March 2025.

1. Product

This section of the TMD describes the Product, including its key attributes.

Name of the Product

Reaia Deposit Pro

Type of the Product

Fixed term loan

Features of the Product
  • Funds can only be used towards the purchase of an approved residential property.
  • Loan amount is for the amount not covered by the principal loan obtained by the borrower to purchase the property.
  • Secured by a second mortgage over the property.
  • Loan terms ranging up to 360 months, aligning with the primary lender loan term.
  • Repayment type: monthly repayments which are either interest only or principal and interest.
  • Interest rate type: Fixed interest rate calculated on the outstanding deposit loan balance.
  • Fees and charges:
    • a settlement fee which is a percentage of the initial property value; and
    • statement fees, rescheduled settlement fees, late payment fee, direct debit dishonour fee, discharge fee. 
  • The customer is also required to enter into a separate contract (the “Services Contract”) under which the customer agrees to pay: 
    • a starter fee, the amount depending on the loan and property services required; and 
    • a deferred fixed fee per annum which is a percentage of the initial property value accrued monthly (and which is only payable when the loan is paid out).
  • The Services Contract is an agreement between the customer, the appointed credit representative of the Issuer, and the trustee for the investors who fund the loans.

2. Target market

This section of the TMD describes the retail clients that comprise the target market for the Product.

The retail clients who comprise the target market for the Product are persons who:

  • Are high income earning professionals with a gross annual income of $250,000 at an individual level or $400,000 at a household level.
  • Have at least one income earner in full time employment.
  • Are looking to buy a principal place of residence.
  • Do not have the necessary funds for a deposit of the amount required to buy a home in the price range that they desire.
  • Do not want to use lender’s mortgage insurance.
  • Are eligible for and can afford to make repayments on an 80% loan-to-value ratio (LVR) loan provided by a primary lender.
  • Are willing and in agreement that they can afford to pay the “deferred fixed fee” at the point of refinance or sale of the property.
  • Can afford to make fixed interest repayments over the term of the loan.

 

The likely objectives, financial situation and needs of consumers in the target market for the Product are as follows:

The Product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market for the following reasons:

Objectives

Finance to be able to buy a home without having their own funds for a deposit of up to 20%.

The Product will provide finance to enable qualifying customers to buy a home without having their own funds for a deposit.

Financial situation

High income (at least $250,000 per annum for individuals or $400,000 per household)

The Product will be offered to qualifying high income customers.

Needs

Finance to cover the amount of a deposit that the primary lender for a home purchase will not cover.

The Product will finance the amount of a deposit that the primary lender for a home purchase will not cover.

 

3. Retail Product Distribution Conduct

This section of the TMD specifies any conditions and restrictions on retail distribution of the Product (other than any imposed by the Corporations Act).
 

Channel

Additional conditions or restrictions

This product may be distributed directly to consumers by the in-house staff of the Issuer or its credit representatives (on-line, in person or by phone or video call) (“Reaia”)
  • The Product will only be sold by persons who understand the particular features and benefits of the Product and the target market.
  • Prospective applicants will be assisted to understand the Product so they are better able to assess for themselves its suitability or otherwise for their circumstances.
  • Only prospective retail clients who meet Reaia’s eligibility criteria are able to submit a full application and qualify as prospective customers.
  • This product can only be issued to prospective retail clients after Reaia has applied its affordability and suitability assessment.
  • Only authorised staff that have met Reaia’s qualification and training requirements are permitted to assist consumers with this product. Authorised staff have the necessary training, skills and knowledge to:
    • discuss the features, costs, benefits, and risks associated with the product;
    • assess whether the consumer is within the target market; and
    • comply with our regulatory obligations.

Third party accredited mortgage brokers subject to Best Interests Duty (BID) and related obligations (“Brokers”)
  • Accredited mortgage brokers are permitted to assist consumers with this product.
  • All applications referred by accredited mortgage brokers must comply with our policies and procedures issued to accredited brokers from time to time.
  • Accredited mortgage brokers are subject to a higher duty under the ‘best interests duty’ (BID) to ensure that the Product is in the best interests of the particular consumer.
 
 

4. When the TMD may no longer be appropriate

This section of the TMD specifies any events or circumstances that would reasonably suggest that the TMD is no longer appropriate.

The events or circumstances that would reasonably suggest that the TMD is no longer appropriate are:

  • Changes to the features or eligibility criteria for the Product.
  • An event or circumstance that would materially change a factor taken into account in making this TMD.
  • If the Product is not being distributed and purchased as envisaged by this TMD.
  • Feedback received from those who distribute or acquire the Product which suggests that the Product does not meet the objectives or needs of the target market.
  • The occurrence of a significant dealing that is not consistent with this TMD.

5. TMD review period

This section of the TMD specifies:

(a) the maximum period from the start of the day when the TMD is made to the start of the day when the first review of the TMD is to finish (the “Initial Review Period”); and

(b) the maximum period from the start of the day when a review of the TMD is finished to the start of the day when the next review of the TMD is to finish (each a “Following Review Period”).

The Initial Review Period is 12 months.

Each Following Review Period is 12 months.

 

6. Complaints reporting period

This section of the TMD specifies the reporting period for the reporting of information by distributors about the number of complaints about the Product (the “Complaints Reporting Period”).

The Complaints Reporting Period is monthly.

 

7. Information needed

This section of the TMD specifies:

(a) the kinds of information needed for the Issuer to identify promptly whether either of the following has occurred:
    (i) a review trigger for the TMD; or
    (ii) another event or circumstance that would reasonably suggest that the TMD is no longer appropriate;

(b) for each kind of information:
    (i) which distributors of the Product should provide those kinds of information; and
    (ii) reporting periods for when that information should be provided by the distributors to the Issuer.

The table below sets out the kinds of information needed for the Issuer to identify promptly whether a review trigger for the TMD has occurred, the distributors of the Product who should provide those kinds of information, and the reporting periods for when that information should be provided.

Information needed

Distributors who should provide this information

Reporting periods for when that information should be provided

Inquiries about the Product being received from persons who are not in the target market.

Reaia
Brokers

Monthly

Complaints about the Product from existing customers.

Reaia
Brokers

Monthly

Feedback from a distributor that the Product does not seem to be addressing the objectives, financial situation or needs of persons in the target market.

Reaia
Brokers

Monthly

A significant dealing in the Product that is not consistent with this TMD.

Reaia
Brokers

Monthly

The table below sets out the kinds of information needed for the Issuer to identify promptly whether another event or circumstance has occurred that would reasonably suggest that the TMD is no longer appropriate, the distributors of the Product who should provide those kinds of information, and the reporting periods for when that information should be provided.

Information needed

Distributors who should provide this information

Reporting periods for when that information should be provided

Information requested from the distributor by the Issuer.

Reaia
Brokers

Monthly