Terms

Credit Guide

CREDIT PROVIDER’S CREDIT GUIDE

As an intending borrower, we provide you with the following Credit Guide, which must be provided to you in writing, in accordance with Section 126 of the National Consumer Credit Protection Act 2009.

Licensee’s name (being a Credit Provider):	Kawana Pawnbrokers Pty Ltd, ABN: 52 100 857 127
Licensee’s trading office:	6/2 Premier Circuit, Warana, Queensland, 4575
Telephone:	07 5493 6133
Postal address:	PO Box 650, Mooloolaba, Qld 4557
Australian Credit Licence Number:	384040
Internal Dispute Resolution (IDR) Procedure: Should you have a complaint or concern in regard to your credit contract, including any unforseen financial difficulty, in the first instance, please contact the Suncoast Loans IDR Manager. The Manager will be pleased to assist in resolving your complaint or concern. There is no charge for this service.
IDR Manager: Paul McLachlan Phone: 07 5493 6133 Email: admin@suncoastloans.com.au
External Dispute Resolution (EDR) Procedure: Following contact with the IDR Manager, if you are not satisfied with the outcome of the attention given to your complaint or concern, you may contact the Australian Financial Complaints Authority (AFCA) with details of your complaint or concern. There is no charge for this service.
EDR Ombudsman: AFCA – Phone: 1800 931 678, or go to www.afca.org.au Postal address: GPO Box 3, Melbourne, VIC, 3001

Suitability of the Loan

We are required to assess the suitability of the loan you have requested, under Sections 128, 129 and 133 of the National Consumer Credit Protection Act 2009. These Sections are concerned with whether or not the loan you seek is “unsuitable”.

Under Section 131, we are obliged to advise you that we will not participate in the arrangement of a loan for you, if that loan would be unsuitable and under Sections 128 and 133, we are obliged to refuse an increase in your credit limit if that would also be deemed unsuitable.

Suitability or unsuitability is assessed in accordance with the following criteria:

Whether or not you will be able to comply with the financial obligations under the contract, without substantial hardship, if at all.
Whether or not the contract will meet your requirements and objectives.
Whether or not the contract meets requirements imposed by regulation, from time to time.
It involves us, as a Credit Provider, making enquiry about your financial circumstances.
According to whether or not we believe the information to be true.

In accordance with Section 132, if you are successful with your application and enter into a credit contract with us because the loan is not deemed unsuitable, you may request a copy of that assessment any time during the following 7 years. This will be provided at no charge to you.

If your copy is requested within 2 years, we will provide it within 7 days. If your request is received after the second year, we may take up to 21 days to provide you with a copy.

Privacy Policy

CREDIT INFORMATION (PRIVACY) MANAGEMENT POLICY
KAWANA PAWNBROKERS PTY LTD T/A SUNCOAST LOANS (hereafter referred to as Suncoast Loans) Australian Credit Licence No. 384040

Please read this document BEFORE you provide Suncoast Loans with ANY personal information in connection with applying for a loan from us. If you provide us with this personal information, we will assume that you have followed this instruction and that you have read and understood this Policy.

This policy has been developed to appropriately acknowledge the importance of, and assist in providing a framework for, the appropriate level of protection for consumer identification and credit information protection. The policy represents Suncoast Loans’ commitment to compliance with the privacy laws and privacy code obligations.

Concerning the collection, holding, use and disclosure of credit related personal information

We (Suncoast Loans) provide this policy in accordance with the Privacy Amendment (Enhancing Privacy Protection) Act 2012, hereafter referred to as the Privacy Act, detailing the lawful approach we take in the collection of information in our role as credit providers and in regard to the management and use of all information collected from our potential customers and actual customers, and all subsequent dealings with customer/consumer representatives, credit reporting bodies, and other entities listed in this policy.

Our collection of information may start with a credit suitability or affordability process to establish your credit status, or credit worthiness, and will include enquiries and reasonable steps to verify the identity and credit information we collect from you and from other sources. Enquiries may include obtaining a credit report about you from a credit reporting or reference body, such as Equifax, the body with which we have a contract. Verification will include seeking access to and reviewing bank statements.

Introduction

In the course of our business, we provide consumer credit, as defined in Section 6(1) of the Privacy Act. This credit being provided wholly or primarily for personal, family, or household purposes. From time to time we may also offer business loans.

In the course of our business we seek to establish your credit worthiness. That means:

your eligibility to be provided with credit;
your history in relation to credit; and
your capacity to repay an amount of credit.

The kinds of credit information we collect and hold

In accordance with the industry’s mandatory Credit Reporting Privacy Code, Obligation 5.1, we collect and hold credit reporting information, credit identification information, credit capacity information and personal information collected and held under Part 111A of the Privacy Act.

In accordance with Section 6 of the Privacy Act, we may collect and hold the following personal information that may be considered confidential:

identification information;
credit liability information;
repayment history information;
a statement that an information request has been made to a credit reporting body, by a credit provider, in relation to your application for credit;
the type of personal or commercial credit, and the amount of credit sought in an application that you have made to a credit provider, in connection with which that credit provider has made an information request concerning you;
overdue and default information concerning your current and/or previous personal and/or business loans;
payment information about you, including information concerning late payments;
information about new arrangements you may have made involving an existing credit contract;
court proceedings (civil) information about you;
personal insolvency information about you, as included on the National Personal Insolvency Index, which relates to bankruptcy, debt agreements, personal insolvency agreements and Sections 50 and/or 188 Bankruptcy Act directions and/or authorities;
insolvency information associated with your company or companies seeking loans;
publicly available information concerning your activities in Australia and your credit worthiness, including information recorded on the National Personal Insolvency Index;
any opinion that we might reach that you have committed a serious credit infringement in relation to consumer credit we have provided to you, with the circumstances specified on the file;
any opinion that we might reach that you have committed a serious credit infringement in relation to business or commercial credit we have provided to you, with the circumstances specified on the file;
unsolicited information that we may deem relevant to keep on file; and
other relevant information in the circumstances.

Explanation of some of the key elements listed above is as follows.

Identification information about you

During the credit suitability assessment process, required under Sections 128-131 of the National Consumer Credit Protection Act, to assist in protecting you against identity theft and to assist in reducing the opportunity for fraud, we may ask you for some or all of the following identification information:

your full name;
any alias or previous name/s;
date of birth;
sex;
current address;
2 previous addresses (if any);
name of current employer; or
name of last known employer; and
driver’s licence number.

To assist with business or commercial loan applications, we may ask you for:

a copy of the company’s Constitution and associated documentation;
a copy of documents identifying the company directors;
financial statements; and
other documents.

Consumer and business credit liability information

We collect and hold consumer and/or business credit liability information, including:

the name of the credit provider;
whether or not the credit provider holds an Australian Credit Licence;
the type of consumer credit;
the day on which the consumer credit was entered into;
the terms or conditions of the consumer credit which relate to the repayment of that credit and anything that may be prescribed by regulation;
the maximum amount available under the consumer credit; and
the day on which the consumer credit is terminated, or otherwise ceases to be in force.

Repayment history information

If and when we provide consumer credit to you, the following information about you as a consumer may be collected and held:

whether or not you have met monthly repayment obligations, including any defaults;
the date on which the monthly payment is due and payable; and
if you make payments after the due and payable day, the day on which you actually made the payment.

Thereafter this information may be provided to a credit reporting or reference body.

Overdue and Default information

We collect and hold information about any payment that is overdue and, under Section 88 of the National Credit Code, Regulation 86 of the National Consumer Credit Protection Regulations 2010 and Section 6Q of the Privacy Act, that:

you are overdue in making the payment;
you have received a written notice from us advising you of the overdue amount and requesting payment of the amount;
the Statute of Limitations does not prevent us from recovering the amount; and
where the amount overdue is $150 or more, it is sufficient to list on your file with a credit reporting body. Any amount will be listed on the file we maintain concerning your identification and credit information.

Court proceedings

We may collect and hold information that is given or made against you in civil court proceedings that relate to any credit that has been provided to you, or for which you have applied.

How we collect credit information

We collect credit information from 6 possible sources:

from you;
from the documentation we request and you provide;
from credit reporting bodies;
from people or organisations you permit us to contact, to verify your credit relevant details;
from other credit providers;
from the External Dispute Resolution scheme (AFCA); and
from information about you publicly available, including court and tribunal reports and decisions.

Please note, depending on circumstances, we may choose not to seek information from all these sources to assess your credit application.

How we hold credit information securely

In all circumstances, we take reasonable steps to protect your information from misuse, loss, interference, unauthorised access, modification or unauthorised disclosure. We choose not to provide further detail, for security reasons. Further protection detail can be provided to you verbally, on request.

The kinds of credit eligibility information that we hold

This is credit reporting information and information about you that may be disclosed to us by a credit reporting body, under Division 2 of Part 111A of the Privacy Act.

How we hold credit eligibility information

Hard copies are held in a locked environment, with other security protection after business hours and electronic copies are held in a secure environment, with the application of appropriate passwords and other computer and software security techniques.

The credit reporting body

We provide information to and request information from Equifax, a credit reporting body. You may contact Equifax if:

you believe that the information they have on their file about you needs amendment or correction; and/or
you want the body to hold off disclosing any information from the their file about you because, on reasonable grounds, you believe that you have been, or are likely to be, a victim of fraud; and/or
you do not want the body to use their credit reporting information for the purposes of pre-screening for direct marketing by a credit provider and/or
you would like a copy of Equifax’s privacy policy, which you may request from Equifax and which Equifax will provide by email or by mail, at no charge.

The contact details for Equifax are:

Telephone: 13 8332

Website: www.equifax.com.au.

Process when collecting information from a credit reporting body

To obtain a credit report of some kind about you, we are required to provide certain information which Equifax will note on your credit file, along with the fact that we made an enquiry.

In accordance with Equifax polices, this information will probably appear on your credit report and will be accessible by credit providers who are customers of Equifax, when you are applying for a loan at some time in the future.

This identity and credit information and these listings could adversely impact on your future applications for credit, if the relevant future credit provider’s application approval policies and processes include consideration of the number of past inquires as being indicative of something adverse or negative about you as a borrower.

We have no control over or input into Equifax’s policies with regard to the content of their credit reports. If you proceed to applying for a loan with us, you will be provided with a Privacy Consent Agreement which includes further detail from the company concerning privacy for borrowers. When you indicate your consent or acceptance of that agreement, you will be agreeing to the possibility that the current or future information on your credit report may prevent you from obtaining the loan you are currently seeking, or some future loan.

Information provided by credit reporting or reference bodies

Subject to conditions, Part 111A of the Privacy Act permits credit reporting bodies, such as Equifax, the company we use, to collect from us, other credit providers and from elsewhere, the following information about you which may be included on your credit file held by Equifax, This information will be available to us and to any other client of the credit reporting body who makes a credit inquiry, seeking a credit report of some sort from that body.

This information is limited to personal credit information, credit reporting information, credit ID information and credit capacity information, and includes:

identification information;
consumer credit liability information;
repayment history information;
a statement that an information request has been made by us, another credit provider, broker, mortgage insurer or trade insurer, or other client of the credit reporting body;
the type of consumer credit or commercial credit;
default information;
serious credit infringement information;
payment information;
new arrangement information, including changes in the terms and conditions of your credit contract;
court proceeding information;
personal insolvency information;
publicly available information as to your credit worthiness (subject to some exceptions); and/or
a credit provider’s opinion that you have committed a serious credit infringement in relation to the consumer credit which credit provider has provided to you; and/or
the total indebtedness and any accumulation of such due to defaults in payment and associated fees and interest charges before, during and after the issuing of the Privacy Act’s Section 6Q and Section 21D Notices.

Some of this information may be collected from us, some from other clients of the credit reporting body and some from other sources, as specifically indicated, or by implication indicated above.

Please note that the credit reporting body has discretion as to what it will include in a credit report about you and there is no opportunity under the Privacy Act, or Credit Reporting Privacy Code, to complain if the body chooses not to list certain information it holds about you, including information we have provided.

Should you have any issues with the information that the credit reporting body holds and uses in their reports about you, the complaint should be made direct to the credit reporting body, because that body is the only authorised or recognised entity that can make and implement the decision to change the information it holds. Please note that you will be required to fully, accurately and honestly explain the reasons you seek a change to the information on your credit file or credit report (whatever called).

You are invited to visit the Equifax website at www.equifax.com.au to view the following information:

How you can obtain Equifax’s privacy policies.
Your right to access and correct information Equifax holds about you.
How you may complain if you think Equifax has breached privacy and credit reporting laws that apply to you.
Your right to request that Equifax not use any information held about you for purposes of pre-screening, for any company to undertake direct marketing that involves you.
Your right to request that Equifax not use or provide to its clients any information about you if you believe that you are a victim of fraud.

Notifiable matters

This document contains all the notifiable matters, as specified in the Credit Reference Privacy Code, together with all matters specified in the Privacy Act that we are required to communicate to you. As such, it constitutes a Notifiable Matters Statement and a Credit Information (Privacy) Management Policy.

In this document and in the Privacy Consent Agreement, which you may receive later, we have chosen the option available by the wording in Code Obligations 4.2 of the Credit Reporting Privacy Code to present the information required in Code Obligations 4.1, as well as the information required for presentation under the Privacy Act in this document. This Credit Information (Privacy) Management Policy and the Privacy Consent Agreement, including the Notifiable Matters Statement, are provided with clear instructions to you to read both, before you make any attempt to provide us with personal information in conjunction with applying for a personal loan from us.

Transfer of information between us and Equifax, the credit reporting body

This information transfer is permitted under Division 2 of Part 111A of the Privacy Act. The information involved is the credit-related personal information that a credit reporting body may provide about you, to assist us to assess your credit worthiness. This information is relevant for use in establishing your eligibility for consumer credit.

Please note that the company may contract with Equifax to have part or all of this information provided, from time to time, in accordance with company policy. This information has been provided to Equifax by credit providers with whom you have had contact, and includes:

information about you after you turned 18, except identification information;
credit applied for and/or supplied in Australia;
your repayment history; and
any default information.

If we provide a loan to you and you fail to meet your repayment obligations, or commit a serious credit infringement, we may be entitled to disclose this to the credit reporting body and it will be included on the file they hold about you.

Regardless of any request from anywhere, including credit “repair” companies, we will not remove, or attempt to facilitate the removal of, this default information from either our files or Equifax’s files and credit reports, unless presented with clear and convincing evidence that the information is factually incorrect, the default has been repaired with full payment of the amount owing, or we have entered into a payment arrangement with the consumer that is the subject of an agreement between both parties.

Transfer of information between us and ASIC or AFCA

In accordance with our Australian Credit Licence conditions and a number of provisions in the Australian Securities and Investments, National Consumer Credit Protection and the Anti-Money Laundering and Counter Terrorism Finance (AUSTRAC) Acts, we may be required to give ASIC, AUSTRAC or AFCA copies of all or some part of your information.

The purposes for which we collect, hold, use and disclose credit information and credit eligibility information

The consumer credit-related purposes for which we collect, hold, use and disclose information are:

to assess your application to us for consumer credit; and
to collect payments that are overdue in relation to consumer credit we may have provided you; and
to collect payments that are overdue in relation to consumer credit provided by another credit provider, under a credit contract that has been assigned to us by that other credit provider [in accordance with Sub-sections 6K(2) and (3)].

In accordance with section 21M, we will disclose relevant and permitted information to debt collectors.

Use of credit eligibility information

In accordance with Section 21G, we use credit eligibility information for the following purposes:

credit related purposes involving you; or
permitted reporting of information to a credit reporting body; or
in connection with what we reasonably believe is a serious credit infringement that you may have committed; or
for a use prescribed by a court, or tribunal, or regulations.

We will disclose this information to:

credit bodies;
a company related to us;
a person responsible for processing your credit application; or
a person who manages our credit contracts; or
another credit provider, if we reasonably believe that you have committed a serious credit infringement; or
the Australian Financial Complaints Authority (AFCA); or
as authorised under Australian law, regulation, court or tribunal.

In accordance with Section 21N of the Privacy Act, we may disclose information to an approved entity seeking participation in an assignment of your debt, or purchase of our business. Should the transaction proceed, you will be informed in writing, in accordance with Obligation 13 in the Credit Reporting Privacy Code and all our rights will be transferred to the acquirer, in accordance with Section 6K of the Privacy Act.

How you may access credit eligibility information that we hold about you

First contact the company’s Privacy Compliance Manager on telephone: (07) 54 936133, or post to: PO Box 650 Mooloolaba, QLD, 4557, or email admin@suncoastloans.com.au.

In accordance with Section 21T and Code Obligation 19, at your request, we will:

give you access to any credit information we hold about you;
respond to your request within a reasonable period and provide the access within 30 days of your request;
provide the information in a clear manner and provide reasonable explanations and summaries of the information, to assist you to understand the impact of the information; and
deny access, only if such would be unlawful, required under Australian law, or by a court or tribunal, or would prejudice an official enforcement body investigation.

Following your successful request, access will be provided by the Privacy Compliance Manager, who will facilitate the provision of a print out of your information stored in the company’s Specialist Lending System. Any denial of access will be in writing, with the reason/s explained and details of the company’s internal disputes resolution process, AFCA and the Office of the Australian Information Commission, to which you may lodge a complaint if not satisfied with the company’s explanation.

Facilitating any changes to information previously provided to Equifax

Where we have previously provided factually incorrect information to Equifax, or any other entity, we will contact them and inform them of the corrected information.

Should no correction be necessary because, after careful review, the Privacy Compliance Manager has determined the information kept on file by us is accurate, up-to-date, complete, relevant and not misleading, you will be informed of this and we will not make any attempt to encourage Equifax to change any information on its files that correctly reflects our information.

You are advised that to do so would be aiding and abetting Equifax to commit an offence under Sections 14 and Section 16A(4) of Privacy Principle 7 in the Privacy Act, which attracts fines of at least 37,000 and up to $370,000. It would also be a serious breach of our contract with Equifax, attract offences under the Corporations Act and, arguably, the Crimes Act.

Should the Privacy Manager agree that some information held by us and provided to Equifax is inaccurate, not up-to-date, incomplete, irrelevant or misleading, but that other information including information about defaults in previous and current loan repayments held by us, provided to Equifax and included in their credit reports is accurate, up-to-date, complete, relevant or not misleading, only the information that needs correction will be amended, or sought to be amended or removed from Equifax’s file and credit reports, as is appropriate. The accurate information will also not be amended or removed from our files, nor will any correct notation that a credit enquiry has occurred.

How you may seek the correction of credit information and credit eligibility information that we hold

Once you have inspected the personal credit information we hold on file about you, you may inform our Privacy Compliance Manager if you have discovered any information that is inaccurate, out-of-date, incomplete, irrelevant or misleading.

The Privacy Compliance Manager will be pleased to amend the file within 30 days but, in most cases, will require appropriate evidence from you to support your request. Please note that, in the exercise of this correction duty, the Privacy Compliance Manager is lawfully entitled to consult with a credit reporting body and/or another credit provider. You, and any entity consulted in the process, will be informed in writing of any correction.

How you may complain about our failure to comply with this Division, or the relevant registered CR code

There are 3 ways you may complain:

Verbally, or in writing, to our Privacy Manager.
If you are not satisfied with the Privacy Manager’s response, you can complain verbally or in writing to our Internal Dispute Resolution Manager.
If you are not satisfied with the Internal Dispute Manager’s response you can lodge a complaint either with the Privacy Commissioner, at the Office of the Australian Information Commission.

Contact details –

Office of the Australian Information Commission
GPO Box 5218
Sydney NSW 2001
Phone: 02 9284 9753
Enquiries: 1300 363 992
Website: www.oaic.gov.au

With the external dispute resolution scheme of which we are a member, contact details:
Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678 (free call)
Email: info@afca.org.au
Website: www.afca.org.au
There is no charge for lodging a complaint.

How we will deal with such a complaint

We will write to you acknowledging receipt of the complaint. After appropriate investigation, the Privacy Manager will write to you as soon as practicable after a decision has been reached, outlining the decision and the reasons for reaching it.

Australian link

We do not disclose credit information, or credit eligibility information, to entities that do not have an Australian link.

Obtaining a copy of this policy

You can obtain an emailed or posted copy of this Credit Information (Privacy) Management Policy by contacting the Privacy Compliance Manager on (phone/email/post).

Information from Suncoast Loans

From time to time you may receive messages from Suncoast Loans and/or related, connected and associated companies that include news, or service and product information.

You may opt out of receiving them at any time, in accordance with Section 2.1, Schedule 3 of the Privacy Act. This advice and the process to do so will be included with every message sent.

Financial Difficulty

We understand that unexpected events and expenses can catch you by surprise. But getting support is important- and We’re here to help.

Certain events in your life may leave you needing help and support to get back on track financially. For example:

Changes to your income and expenses
Losing your job
A significant life event, such as a relationship breakdown or death in the family
Injury or illness
An emergency event or natural disaster

If you are experiencing challenges with your repayments, call us on 07 5493-6133, email us at admin@suncoastloans.com.au or complete the form below. Our customer care team can assist with flexible payment options.

Dispute Resolution Policy

Suncoast Loans is committed to resolving complaints quickly, fairly and honestly.In accordance with the good business practices adopted by Suncoast Loans and under our Australian Credit Licence conditions, in the unlikely event of a consumer having a concern or complaint, Suncoast Loans has a policy of allowing customers easy access to management and a friendly, efficient and fast approach to solving concerns and complaints.
You start by talking to the Suncoast Loans representative with whom you have been dealing. If you need to go further, we have an Internal Dispute Resolution process, with a policy to make every reasonable effort to resolve an issue on the day it comes to the specially trained Internal Dispute Resolution Manager’s attention, or as soon as possible thereafter.

Please contact us immediately if you have a concern regarding our products or services.

Suncoast Loans Contact details:-
Phone:07 5493 6133 (Mon –Fri 9.00AM – 5.00PM AEST)
Email: admin@suncoastloans.com.au

In the very, very unlikely event that you may want to go even further, Suncoast Loans belongs to an External Dispute Resolution scheme. This scheme can be contacted at:
Australian Financial Complaints Authority – (AFCA)
Phone: 1800 931 678
Web: www.afca.org.au
Postal address: GPO Box 3, Melbourne, VIC, 3001.
Always remember, if a customer has a concern or complaint, Suncoast Loans want to resolve the issue as quickly as possible. We respect and value our many customers and our business grows because our customers like the services we provide and like getting their loans from us. We want to retain that reputation. To obtain the best outcome with the least hassle, bring up your issue with the Suncoast Loans representative you have been dealing with as soon as you can, so your worries can be dealt with quickly.

Target Market Determination

What’s a Target Market Determination?

A Target Market Determination is a document that describes who a product is appropriate for (target market), and any conditions around how the product can be distributed to customers.

It also describes the events or circumstances where we may need to review the Target Market Determination for a financial product.

Medium Amount Credit Contracts (MACCs) – Personal Loans

This Target Market Determination (TMD) is published with the intention of helping consumers obtain an appropriate loan product.

It is prepared and published in acknowledgement of the requirements imposed on “issuer” (lending) companies involved in the provision of credit under the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 (DDO Act).

The loan product that is the subject of this TMD is a Medium Amount Credit Contract (MACC) (as defined in Section 204 and prescribed in Sections 32A and 32B of the National Credit Code) – a consumer loan product regulated by the National Consumer Credit Protection Act 2009 (Credit Act).

The company’s Medium Amount Credit Contracts have been designed with the key attributes as listed in this document, for consumers whose likely objectives, financial situation and needs are also detailed in this document. They must also meet the responsible lending criteria prescribed by the Credit Act and applied by Suncoast Loans.

Please note that this document is not a full summary of the credit contract issued by Suncoast Loans and its loan product terms and conditions. Nor is it intended to provide financial advice. Loan applicants must very carefully read not only this document, but also the credit contract Suncoast Loans may offer them.

Issuer (lender) of the product being a loan

Kawana Pawnbrokers Pty Ltd t/as Suncoast Loans, ABN: 52 100 857 127, Australian Credit Licence number: 384040.

Key attributes of the product

The key attributes of Suncoast Loans’ MACC are:

Loan amounts from $2,001 up to $5,000.
Loan terms up to and including 24 months.
Establishment fee – $400, as prescribed under the Credit Act.
Maximum annual percentage rate (annual cost rate, commonly referred to as ‘interest rate’) is 48% per annum, as prescribed under the Credit Act.
Fixed annual percentage rate for the term of the loan.
Clarity and full disclosure concerning unascertainable fees that may arise during the term of the loan, depending on (then) circumstances.
Flexible payment options to negotiate when applying for the loan.
Equal payments – weekly, fortnightly or monthly – reflecting the consumer’s income cycle.
Flexible terms according to affordability.
On the basis of the information collected by the Suncoast Loans at the time of the application and assessment, the discouragement of too large an amount being borrowed, to avoid unnecessary indebtedness.
Funding for non-regular purposes.
Loans may be unsecured for lower amounts, depending on the consumer’s credit history and financial circumstances and almost always secured for larger amounts (over an asset such as a motor vehicle owned by the consumer).
Joint loans available.
No balloon payments unless negotiated during the loan term.
A credit contract that is not complex, within the mandatory requirements of the Credit Act (Schedule 1 – National Credit Code).
A credit contract that is compliant with the National Credit Code.
A relatively easy to read credit contract.

The loan product’s Target Market

Consumers – individual or joint borrowers – who are in the general “class” (classification) of consumers with the following characteristics:

over 18 years of age;
with a proven source of income;
with an income amount received from all sources that is likely to be in excess of existing and projected commitments and the proposed loan, for the term of the proposed loan;
with an established credit history and at least reasonable credit checks;
who can provide at least 90 days of relevant bank statements presenting all income and living expenditure and demonstrating financial management without substantial hardship;
with a stable residence;
with security to offer if required by Suncoast Loans (e.g. motor vehicle registered in their name);
who meet lending criteria concerning the affordability of the loan;
who are permanent residents/Australian citizens; and
who satisfy Credit Act responsible lending requirements as to availability, content and verifiable financial information.

Consumers who are excluded from the Target Market

Consumers who are:

undischarged bankrupts;
currently in a Debt Agreement;
unlikely to have a stable and adequate source of income during the loan term;
have unpaid defaults on existing loans with no satisfactory explanation;
have a number of relatively recent direct debit dishonours;
present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances;
have bank account statements that reveal poor financial management and conduct;
are under the age of 18;
not either an Australian citizen, or a permanent resident;
are unable to provide the financial information required for verification during the application process; and
are unable to understand the nature of a credit contract.

Target market consumers’ likely objectives, financial situation and needs

As determined on the information reasonably available to an ordinary person, exercising reasonable due diligence in the position as an “issuer” (lender or credit provider) representative, at the time of the assessment of the loan application, by the issuer’s reasonable enquiries and reasonable steps to verify information received and the target market consumer’s level of knowledge, access to information and honesty, the consumer’s likely objectives, financial situation and needs include:

Consumer’s likely objectives (and requirements):

Seeking funds to support the acquisition, payment for and/or purchase of one or more of the following:

Boat purchases.
Car/vehicle costs.
Car/vehicle purchases. Vehicles must be under 15 years old, with an odometer reading under 250,000 kms.
Caravan purchases.
Education.
Debt consolidation.
Entertainment.
Family assistance – to other family members.
Funerals.
Fines.
Gifts.
Holidays.
Home renovations/repairs.
Legal expenses.
Major purchases e.g. whitegoods.
Medical/Dental expenses.
Motor bike purchases.
Motor bike repairs.
Rental bonds/moving costs.
Recreation/sport.
Travel expenses.
Vet expenses.
Weddings.

Consumers likely financial circumstances or situation:

This includes:

a fixed, stable or appropriate general level of income. Each situation is unique and we undertake a comprehensive individual assessment to determine affordability in each case;
employed – full time, part time and casual considered – and/or receiving Centrelink benefits, including single parents and Centrelink Family Tax Benefit recipients;
self-funded retirees;
established credit history. We will consider discharged bankrupts and Part IX debt agreement consumers;
acceptable credit check, indicating at least a reasonable credit performance;
policy on other loans – we are flexible according to affordability assessment;
manageable other debt, including buy now/pay later;
adequately managed and controlled expenditure on alcohol;
adequately managed and controlled expenditure on gambling;
recent bank statements demonstrating financial management, without experiencing substantial hardship;
income amount in excess of other existing and projected commitments and proposed loan repayments;
affordability recognising the number of dependants – allowance of a buffer for each family member;
income paid directly into bank account;
no current indication of adverse financial issues arising and negatively impacting on the ability to repay the new loan over the anticipated term; and
general stability of residence.

Consumer’s likely needs varying, but including:

Easy online and personal application.
Quick approval and other responses – assessment is completed the same day, once all documents and information has been received.
Establishment fee certainty.
Annual cost (‘interest’) rate certainty.
Unchanged (equal) periodic payments to fit within their budget.
Flexible payment options to initially choose from, to suit their income cycle.
Easily understood credit contracts.
Access to adequate information.
regulatory compliant contracts;
An appropriate level of explanation of the credit contract.
The opportunity to ask questions.
Ready access to the company during the term of the loan, if needed, in person, by phone, email and messenger.
Company fairness, understanding and compassion concerning hardship.
Loan funds consistently available to meet responsible lending and Product Design requirements.
Acceptable terms for loans (up to 2 years).
The ability to derive a benefit from taking out the loan product.

Why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the Target Market

The loan product is a relatively simple product, deliberately designed to avoid complexity and be complaint with the Credit Act.

The loan product’s features have been adopted to be consistent with the likely objectives, financial situation and needs of the consumers applying for Suncoast Loans’ loans.

The loan product has been fundamental to the Australian credit market since at least 2013. It does not have any unique features that would be unfamiliar to most consumers, many of whom having borrowed similar loans in the past.

Company loan performance data and feedback from all sources has not revealed any systematic inconsistencies between the design of the product and the loan Target Market’s requirements, financial circumstances and needs – up to and including the date this TMD was adopted.

Distribution method and conduct for the product

Suncoast Loans has adopted the following “distribution” (marketing) policies and procedures for the loan product that is the subject of this TMD.

Distribution includes in-house representatives and brokers (credit assistance providers) who, during the assessment of the loan application, will consider the content of this TMD.

Brokers are selected following a robust recruitment process that results in the broker signing an agreement with Suncoast Loans. In addition, they are informed of both theirs and Suncoast Loans’ responsibilities under the DDO Act and Credit Act.

Individuals may also refer potential consumers seeking a loan to the company.

Suncoast Loans has agreements, provides checklists/reference materials and from time to time reviews the performance of company representatives, brokers and referrers, to ensure proficiency in the recognition of product distribution conditions and restrictions. All parties have to monitor and report to Suncoast Loans management they deal with concerning the implementation of this TMD, complaints received and evidence of significant dealings.

The distribution communications methodologies adopted, or that could be adopted from time to time, include websites, emails, Australia Post, social media and traditional advertising media such as print, radio and television.

In accordance with the Credit Act, Suncoast Loans has the final decision on loan approval and supervises both in-house product distribution and brokers’ efforts, with close attention to the company’s obligations under the DDO Act.

Product distribution conditions and/or restrictions

Conditions and/or restrictions include:

No systematic ignoring or avoidance of Suncoast Loans’ TMDs.
Where brokers are the distributors, specification as to the communications media employed in reaching the Target Market.
Both company in-house representatives and brokers undertaking distribution roles must adhere to company policy concerning loan suitability for consumers.
Suncoast Loans never offers a “limited time only” product and encourages the consumer applicant to take their time in reaching a loan acceptance decision. In this context, while the company’s representatives are not in a position to act as a psychologist, or breach privacy principles, and must rely on the consumer’s knowledge, honesty and preparedness to communicate – on the information that is reasonably available to the company’s representative all reasonable and compassionate effort is employed to accommodate consumer decision fatigue, vulnerabilities and the avoidance of unsuitable distribution.

As with the outcome of reviews, the conditions or restrictions imposed are an attempt to eliminate, or at least minimise, the actual or potential degree of harm that an inappropriate or unsuitable loan might cause.

Why the distribution conditions and/or restrictions mean the product is not likely to be distributed to consumers outside the Target Market

These conditions are clearly communicated to all distributors and are incorporated in engagement agreements. They form part of the major terms and conditions of those agreements.

The company has regular reviews of company credit policy, procedures and processes.

Adoption of the recommendations from these reviews adds to the terms and conditions Suncoast Loans imposes on distributors. This controls their approach to distribution, under their written agreement with Suncoast Loans.

These recommendations are also added to the rules and criteria to which the company refers when making an assessment as to consumer suitability for any loan applied for, given Suncoast Loans makes the final decision as to whether or not an applicant consumer is within the Target Market definition.

Consumers are invited to carefully read this and any other relevant TMD before applying for a loan and/or before accepting the company’s loan offer.

Triggers indicating the product or TMD is no longer appropriate

These include, but may not be limited to, the following events and circumstances:

Changes in legislation affecting the product or TMD.
Reports from distributors and company representatives that a significant number of enquiries and applications are being received from potential consumers outside the defined Target Market.
Company reviews, both ad hoc and scheduled, that reveal an inconsistency or mismatch between the product features and the Target Market’s requirements, financial circumstances and/or needs. This causing, or likely to cause, identified material consumer financial or non-financial harm and being capable or incapable of elimination or minimisation by subsequent TMD action.
Material changes in the number and type of complaint, hardship applications, arrears and approval numbers.
Economic changes, however caused, impacting on Target Market financial circumstances.
Cultural changes and changes in traditions and fads impacting on borrowing habits, preferences and purchasing, and timing decisions using borrowed funds, all potentially leading to changes in Target Market requirements.
Socio-economic changes impacting on perceived and actual Target Market needs.
Significant dealings indicating a material inconsistency between the TMD and the delivered credit product and/or distributors and/or Target Market.
Distribution conditions found to be inadequate.
A need to materially change the loan product and/or its terms and conditions.
Decisions and feedback from the Australian Financial Complaints Authority.
Relevant industry comment, or policy changes adopted by ASIC.

If a review trigger appears, this TMD will be reviewed within 10 business days.

TMD Review Frequency

The first review will be scheduled to conclude 12 months and 10 days from commencement of the DDO – being the date of the first Determination (5 October 2021). Subsequent regular reviews will be conducted and completed a maximum of 2 years and 10 working days from the date the earlier review was completed, until the date the next or subsequent review is completed thereafter.

Where issues of concern in regard to inconsistency between the TMD and the credit product and/or target market arise, between these regular scheduled reviews, the company’s policy is to undertake a review and action the review’s findings within 10 business days of the adverse information being brought to the attention of the company’s TMD Manager, and with implementation of all recommendations.

Where deemed appropriate and material, complaints, if any, will be brought to ASIC’s attention by way of a “Significant Dealing Notification”, within 10 days of any relevant review being completed, in accordance with reportable breach regulation.

Significant dealing

Suncoast Loans will determine that there has been a significant dealing in the following circumstances (unless these are due to loan application fraud):

where there are material levels of interest or demand from consumers outside the Target Market;
if the product is distributed to consumers under 18 years of age;
if the product is distributed to consumers who are not Australian citizens or permanent residents; and
if the product is distributed in a manner that is otherwise materially inconsistent with company polices that adopt credit regulatory compliant practices, as may be determined from time to time.

Triggers for an earlier TMD review

Legislation changes affecting the product.
Significant and unexpected increase in default rates and bad debt write-offs, hardship rates or product complaint rates.
A significant increase in applications from consumers outside the Target Market.
Poor product performance or outcomes.
Distribution conditions found to be inadequate.
Poor distribution delivery.
Any other material inconsistency coming to the attention of the company from any information source, in regard to the TMD and/or the product design and/or the distribution and/or the Target Market.

Frequency required for distributors’ complaints reports to company management

Should they have anything to report, reporting from in-house representatives and third party distributors is scheduled monthly, but where numbers or type of complaint indicate a material significance, reporting will occur within 10 business days of that significance coming to the attention of the distributor.

In-house management and staff who are not representatives will also be encouraged to report at any time within 10 business days of becoming aware of a relevant reportable circumstance.

In addition, Suncoast Loans will welcome reports from other non-representatives and non-distributors at any time.

If the number and/or substance of the complaints reported is material consideration, with appropriate recommendation, will be given to both number and substance – with the options of doing nothing (highly unlikely), modifying the TMD, credit product or manner of distribution, or declaring the TMD obsolete.

Format and details required for distributor’s reports

If they ever have anything to report, distributors are to report by email to the Business Development Manager, in their role of TMD Manager.

Details to be reported include:

the number of complaints received;
the time period over which the complaints were received;
the name/s of the consumers;
what the problem was, with particular attention to Target Market requirements, financial circumstances and needs;
what the resolution was;
the time to resolve it; and
if there are any unresolved complaints.

Additional reporting required from distributors

In circumstances where there is no material level of complaint, or type of complaint but if, in their professional judgement a trend may be emerging, or the evolution of a more serious or material complaint could occur without attention to the causal issue existing at the time of the report, distributors may also lodge an additional report.

Effective Date

This Target Market Determination is effective from 5 October 2021 and applies only to products obtained on or after 5 October 2021.

All Other Contracts (AOCCs) – Personal Loans

This Target Market Determination (TMD) is published with the intention of helping consumers obtain an appropriate loan product.

The loan product that is the subject of this TMD is an All Other Credit Contract (AOCC) (as defined in Section 204 and prescribed in Sections 32A and 32B of the National Credit Code) – a consumer loan product regulated by the National Consumer Credit Protection Act 2009 (Credit Act).

The company’s All Other Credit Contracts have been designed with the key attributes as listed in this document, for consumers whose likely objectives, financial situation and needs are also detailed in this document. They must also meet the responsible lending criteria prescribed by the Credit Act and applied by Suncoast Loans.

Issuer (lender) of the product being a loan

Kawana Pawnbrokers Pty Ltd t/as Suncoast Loans, ABN: 52 100 857 127, Australian Credit Licence number: 384040.

Key attributes of the product

The key attributes of Suncoast Loans’ AOCC are:

Individual or joint borrowers.
Loan amounts $5,001 to $20,000.
Loan terms generally exceeding 24 months.
Competitive fees and charges.
Competitive annual percentage rate (annual cost rate, commonly referred to as ‘interest rate’) negotiated.
Fixed annual percentage rate for the term of the loan.
Clarity and full disclosure concerning unascertainable fees that may arise during the term of the loan, depending on (then) circumstances.
Flexible payment options to negotiate when applying for the loan.
Equal payments – weekly, fortnightly or monthly – reflecting the consumer’s income cycle.
Flexible terms according to affordability.
On the basis of the information collected by the Suncoast Loans at the time of the application and assessment, the discouragement of too large an amount being borrowed, to avoid unnecessary indebtedness.
Funding for non-regular purposes.
Loans secured on assets owned by the consumer and/or their consenting family members who also benefit from the loan.
No balloon payments unless negotiated during the loan term.
A credit contract that is not complex, within the mandatory requirements of the Credit Act (Schedule 1 – National Credit Code).
A credit contract that is compliant with the National Credit Code.
A relatively easy to read credit contract.

The loan product’s Target Market

Consumers – individual or joint borrowers – who are in the general “class” (classification) of consumers with the following characteristics:

over 18 years of age;
with a proven source of income;
with an income amount received from all sources that is likely to be in excess of existing and projected commitments and the proposed loan, for the term of the proposed loan;
with an established credit history and at least reasonable credit checks;
who can provide at least 90 days of relevant bank statements presenting all income and living expenditure and demonstrating financial management without substantial hardship;
with a stable residence;
with security to offer as required by Suncoast Loans (e.g. motor vehicle registered in their name);
who meet lending criteria concerning the affordability of the loan;
who are permanent residents/Australian citizens; and
who satisfy Credit Act responsible lending requirements as to availability, content and verifiable financial information.

Consumers who are excluded from the Target Market

Consumers who are:

undischarged bankrupts;
currently in a Debt Agreement;
unlikely to have a stable and adequate source of income during the loan term;
have unpaid defaults on existing loans with no satisfactory explanation;
have a number of relatively recent direct debit dishonours;
present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances;
have bank account statements that reveal poor financial management and conduct;
are under the age of 18;
not either an Australian citizen, or a permanent resident;
are unable to provide the financial information required for verification during the application process; and
are unable to understand the nature of a credit contract.

Target market consumers’ likely objectives, financial situation and needs

Consumer’s likely objectives (and requirements):

Seeking funds to support the acquisition, payment for and/or purchase of one or more of the following and involving loans for larger amounts and/or longer periods than a Medium Amount Credit Contract:

Boat purchases.
Car/vehicle costs.
Car/vehicle purchases. Vehicles must be under 15 years old, with an odometer reading under 250,000 kms.
Caravan purchases.
Education.
Debt consolidation.
Entertainment.
Family assistance – to other family members.
Funerals.
Fines.
Gifts.
Holidays.
Home renovations/repairs.
Legal expenses.
Major purchases e.g. whitegoods.
Medical/Dental expenses.
Motor bike purchases.
Motor bike repairs.
Rental bonds/moving costs.
Refinancing (in whole or part).
Recreation/sport.
Travel expenses.
Vet expenses.
Weddings.

Consumers likely financial circumstances or situation:

This includes:

a fixed, stable or appropriate general level of income. Each situation is unique and we undertake a comprehensive individual assessment to determine affordability in each case;
employed – full time, part time and casual considered – and/or receiving Centrelink benefits, including single parents and Centrelink Family Tax Benefit recipients;
self-funded retirees;
established credit history. We will consider discharged bankrupts and Part IX debt agreement consumers;
acceptable credit check, indicating at least a reasonable credit performance;
manageable other debt, including buy now/pay later;
adequately managed and controlled expenditure on alcohol;
adequately managed and controlled expenditure on gambling;
recent bank statements demonstrating financial management, without experiencing substantial hardship;
income amount in excess of other existing and projected commitments and proposed loan repayments;
affordability recognising the number of dependants – allowance of a buffer for each family member;
income paid directly into bank account;
no current indication of adverse financial issues arising and negatively impacting on the ability to repay the new loan over the anticipated term; and
general stability of residence.

Consumer’s likely needs varying, but including:

Easy online and personal application.
Quick approval and other responses – assessment is completed the same day, once all documents and information has been received.
Annual cost (‘interest’) rate certainty.
Unchanged (equal) periodic payments to fit within their budget.
Flexible payment options to initially choose from, to suit their income cycle.
Easily understood credit contracts.
Access to adequate information.
Regulatory compliant contracts.
An appropriate level of explanation of the credit contract.
The opportunity to ask questions.
Ready access to the company during the term of the loan, if needed, in person, by phone, email and messenger.
Company fairness, understanding and compassion concerning hardship.
Loan funds consistently available to meet responsible lending and Product Design requirements.
Acceptable terms for loans, up to 5 years.
The ability to derive a benefit from taking out the loan product.

Why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the Target Market

The loan product is a relatively simple product, deliberately designed to avoid complexity and be complaint with the Credit Act.

The loan product’s features have been adopted to be consistent with the likely objectives, financial situation and needs of the consumers applying for Suncoast Loans’ loans.

Distribution method and conduct for the product

Suncoast Loans has adopted the following “distribution” (marketing) policies and procedures for the loan product that is the subject of this TMD.

Distribution includes in-house representatives and brokers (credit assistance providers) who, during the assessment of the loan application, will consider the content of this TMD.

Individuals may also refer potential consumers seeking a loan to the company.

Product distribution conditions and/or restrictions

Conditions and/or restrictions include:

No systematic ignoring or avoidance of Suncoast Loans’ TMDs.
Where brokers are the distributors, specification as to the communications media employed in reaching the Target Market.
Both company in-house representatives and brokers undertaking distribution roles must adhere to company policy concerning loan suitability for consumers.
Suncoast Loans never offers a “limited time only” product and encourages the consumer applicant to take their time in reaching a loan acceptance decision. In this context, while the company’s representatives are not in a position to act as a psychologist, or breach privacy principles, and must rely on the consumer’s knowledge, honesty and preparedness to communicate – on the information that is reasonably available to the company’s representative all reasonable and compassionate effort is employed to accommodate consumer decision fatigue, vulnerabilities and the avoidance of unsuitable distribution.

Why the distribution conditions and/or restrictions mean the product is not likely to be distributed to consumers outside the Target Market

These conditions are clearly communicated to all distributors and are incorporated in engagement agreements. They form part of the major terms and conditions of those agreements.

The company has regular reviews of company credit policy, procedures and processes.

Consumers are invited to carefully read this and any other relevant TMD before applying for a loan and/or before accepting the company’s loan offer.

Triggers indicating the product or TMD is no longer appropriate

These include, but may not be limited to, the following events and circumstances:

Changes in legislation affecting the product or TMD.
Reports from distributors and company representatives that a significant number of enquiries and applications are being received from potential consumers outside the defined Target Market.
Company reviews, both ad hoc and scheduled, that reveal an inconsistency or mismatch between the product features and the Target Market’s requirements, financial circumstances and/or needs. This causing, or likely to cause, identified material consumer financial or non-financial harm and being capable or incapable of elimination or minimisation by subsequent TMD action.
Material changes in the number and type of complaint, hardship applications, arrears and approval numbers.
Economic changes, however caused, impacting on Target Market financial circumstances.
Cultural changes and changes in traditions and fads impacting on borrowing habits, preferences and purchasing, and timing decisions using borrowed funds, all potentially leading to changes in Target Market requirements.
Socio-economic changes impacting on perceived and actual Target Market needs.
Significant dealings indicating a material inconsistency between the TMD and the delivered credit product and/or distributors and/or Target Market.
Distribution conditions found to be inadequate.
A need to materially change the loan product and/or its terms and conditions.
Decisions and feedback from the Australian Financial Complaints Authority.
Relevant industry comment, or policy changes adopted by ASIC.

If a review trigger appears, this TMD will be reviewed within 10 business days.

TMD Review Frequency

Significant dealing

Suncoast Loans will determine that there has been a significant dealing in the following circumstances (unless these are due to loan application fraud):

where there are material levels of interest or demand from consumers outside the Target Market;
if the product is distributed to consumers under 18 years of age;
if the product is distributed to consumers who are not Australian citizens or permanent residents; and
if the product is distributed in a manner that is otherwise materially inconsistent with company polices that adopt credit regulatory compliant practices, as may be determined from time to time.

Triggers for an earlier TMD review

Legislation changes affecting the product.
Significant and unexpected increase in default rates and bad debt write-offs, hardship rates or product complaint rates.
A significant increase in applications from consumers outside the Target Market.
Poor product performance or outcomes.
Distribution conditions found to be inadequate.
Poor distribution delivery.
Any other material inconsistency coming to the attention of the company from any information source, in regard to the TMD and/or the product design and/or the distribution and/or the Target Market.

Frequency required for distributors’ complaints reports to company management

In-house management and staff who are not representatives will also be encouraged to report at any time within 10 business days of becoming aware of a relevant reportable circumstance.

In addition, Suncoast Loans will welcome reports from other non-representatives and non-distributors at any time.

Format and details required for distributor’s reports

If they ever have anything to report, distributors are to report by email to the Business Development Manager, in their role of TMD Manager.

Details to be reported include:

the number of complaints received;
the time period over which the complaints were received;
the name/s of the consumers;
what the problem was, with particular attention to Target Market requirements, financial circumstances and needs;
what the resolution was;
the time to resolve it; and
if there are any unresolved complaints.

Additional reporting required from distributors

Effective Date

This Target Market Determination is effective from 5 October 2021 and applies only to products obtained on or after 5 October 2021.

All Other Contracts (AOCCs) - Personal Loans - First and Second Mortgages

This Target Market Determination (TMD) is published with the intention of helping consumers obtain an appropriate loan product.

Issuer (lender) of the product being a loan

Kawana Pawnbrokers Pty Ltd t/as Suncoast Loans, ABN: 52 100 857 127, Australian Credit Licence number: 384040.

Key attributes of the product

The key attributes of Suncoast Loans’ AOCC are:

Individual or joint borrowers.
Loan amounts $5,001 to $50,000.
Loan terms generally exceeding 24 months.
Competitive fees and charges.
Competitive annual percentage rate (annual cost rate, commonly referred to as ‘interest rate’) negotiated.
Fixed annual percentage rate for the term of the loan.
Clarity and full disclosure concerning unascertainable fees that may arise during the term of the loan, depending on (then) circumstances.
Flexible payment options to negotiate when applying for the loan.
Equal payments – weekly, fortnightly or monthly – reflecting the consumer’s income cycle.
Flexible terms according to affordability.
On the basis of the information collected by the Suncoast Loans at the time of the application and assessment, the discouragement of too large an amount being borrowed, to avoid unnecessary indebtedness.
Funding for non-regular purposes.
Loans secured on assets owned by the consumer and/or their consenting family members who also benefit from the loan.
No balloon payments unless negotiated during the loan term.
A credit contract that is not complex, within the mandatory requirements of the Credit Act (Schedule 1 – National Credit Code).
A credit contract that is compliant with the National Credit Code.
A relatively easy to read credit contract.

The loan product’s Target Market

Consumers – individual or joint borrowers – who are in the general “class” (classification) of consumers with the following characteristics:

over 18 years of age;
with a proven source of income;
with an income amount received from all sources that is likely to be in excess of existing and projected commitments and the proposed loan, for the term of the proposed loan;
with an established credit history and at least reasonable credit checks;
who can provide at least 90 days of relevant bank statements presenting all income and living expenditure and demonstrating financial management without substantial hardship;
with a stable residence;
with security to offer as required by Suncoast Loans (e.g. motor vehicle registered in their name);
who meet lending criteria concerning the affordability of the loan;
who are permanent residents/Australian citizens; and
who satisfy Credit Act responsible lending requirements as to availability, content and verifiable financial information.

Consumers who are excluded from the Target Market

Consumers who are:

undischarged bankrupts;
currently in a Debt Agreement;
unlikely to have a stable and adequate source of income during the loan term;
have unpaid defaults on existing loans with no satisfactory explanation;
have a number of relatively recent direct debit dishonours;
present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances;
have bank account statements that reveal poor financial management and conduct;
are under the age of 18;
not either an Australian citizen, or a permanent resident;
are unable to provide the financial information required for verification during the application process; and
are unable to understand the nature of a credit contract.

Target market consumers’ likely objectives, financial situation and needs

Consumer’s likely objectives (and requirements):

Boat purchases.
Car/vehicle costs.
Car/vehicle purchases. Vehicles must be under 15 years old, with an odometer reading under 250,000 kms.
Caravan purchases.
Education.
Debt consolidation.
Entertainment.
Family assistance – to other family members.
Funerals.
Fines.
Gifts.
Holidays.
Home renovations/repairs.
Legal expenses.
Major purchases e.g. whitegoods.
Medical/Dental expenses.
Motor bike purchases.
Motor bike repairs.
Rental bonds/moving costs.
Refinancing (in whole or part).
Recreation/sport.
Travel expenses.
Vet expenses.
Weddings.

Consumers likely financial circumstances or situation:

This includes:

a fixed, stable or appropriate general level of income. Each situation is unique and we undertake a comprehensive individual assessment to determine affordability in each case;
employed – full time, part time and casual considered – and/or receiving Centrelink benefits, including single parents and Centrelink Family Tax Benefit recipients;
self-funded retirees;
established credit history. We will consider discharged bankrupts and Part IX debt agreement consumers;
acceptable credit check, indicating at least a reasonable credit performance;
manageable other debt, including buy now/pay later;
adequately managed and controlled expenditure on alcohol;
adequately managed and controlled expenditure on gambling;
recent bank statements demonstrating financial management, without experiencing substantial hardship;
income amount in excess of other existing and projected commitments and proposed loan repayments;
affordability recognising the number of dependants – allowance of a buffer for each family member;
income paid directly into bank account;
no current indication of adverse financial issues arising and negatively impacting on the ability to repay the new loan over the anticipated term; and
general stability of residence.

Consumer’s likely needs varying, but including:

Easy online and personal application.
Quick approval and other responses – assessment is completed the same day, once all documents and information has been received.
Annual cost (‘interest’) rate certainty.
Unchanged (equal) periodic payments to fit within their budget.
Flexible payment options to initially choose from, to suit their income cycle.
Easily understood credit contracts.
Access to adequate information.
Regulatory compliant contracts.
An appropriate level of explanation of the credit contract.
The opportunity to ask questions.
Ready access to the company during the term of the loan, if needed, in person, by phone, email and messenger.
Company fairness, understanding and compassion concerning hardship.
Loan funds consistently available to meet responsible lending and Product Design requirements.
Acceptable terms for loans, up to 10 years.
The ability to derive a benefit from taking out the loan product.

Why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the Target Market

The loan product is a relatively simple product, deliberately designed to avoid complexity and be complaint with the Credit Act.

The loan product’s features have been adopted to be consistent with the likely objectives, financial situation and needs of the consumers applying for Suncoast Loans’ loans.

Distribution method and conduct for the product

Suncoast Loans has adopted the following “distribution” (marketing) policies and procedures for the loan product that is the subject of this TMD.

Distribution includes in-house representatives and brokers (credit assistance providers) who, during the assessment of the loan application, will consider the content of this TMD.

Individuals may also refer potential consumers seeking a loan to the company.

Product distribution conditions and/or restrictions

Conditions and/or restrictions include:

No systematic ignoring or avoidance of Suncoast Loans’ TMDs.
Where brokers are the distributors, specification as to the communications media employed in reaching the Target Market.
Both company in-house representatives and brokers undertaking distribution roles must adhere to company policy concerning loan suitability for consumers.
Suncoast Loans never offers a “limited time only” product and encourages the consumer applicant to take their time in reaching a loan acceptance decision. In this context, while the company’s representatives are not in a position to act as a psychologist, or breach privacy principles, and must rely on the consumer’s knowledge, honesty and preparedness to communicate – on the information that is reasonably available to the company’s representative all reasonable and compassionate effort is employed to accommodate consumer decision fatigue, vulnerabilities and the avoidance of unsuitable distribution.

Why the distribution conditions and/or restrictions mean the product is not likely to be distributed to consumers outside the Target Market

These conditions are clearly communicated to all distributors and are incorporated in engagement agreements. They form part of the major terms and conditions of those agreements.

The company has regular reviews of company credit policy, procedures and processes.

Consumers are invited to carefully read this and any other relevant TMD before applying for a loan and/or before accepting the company’s loan offer.

Triggers indicating the product or TMD is no longer appropriate

These include, but may not be limited to, the following events and circumstances:

Changes in legislation affecting the product or TMD.
Reports from distributors and company representatives that a significant number of enquiries and applications are being received from potential consumers outside the defined Target Market.
Company reviews, both ad hoc and scheduled, that reveal an inconsistency or mismatch between the product features and the Target Market’s requirements, financial circumstances and/or needs. This causing, or likely to cause, identified material consumer financial or non-financial harm and being capable or incapable of elimination or minimisation by subsequent TMD action.
Material changes in the number and type of complaint, hardship applications, arrears and approval numbers.
Economic changes, however caused, impacting on Target Market financial circumstances.
Cultural changes and changes in traditions and fads impacting on borrowing habits, preferences and purchasing, and timing decisions using borrowed funds, all potentially leading to changes in Target Market requirements.
Socio-economic changes impacting on perceived and actual Target Market needs.
Significant dealings indicating a material inconsistency between the TMD and the delivered credit product and/or distributors and/or Target Market.
Distribution conditions found to be inadequate.
A need to materially change the loan product and/or its terms and conditions.
Decisions and feedback from the Australian Financial Complaints Authority.
Relevant industry comment, or policy changes adopted by ASIC.

If a review trigger appears, this TMD will be reviewed within 10 business days.

TMD Review Frequency

Significant dealing

Suncoast Loans will determine that there has been a significant dealing in the following circumstances (unless these are due to loan application fraud):

where there are material levels of interest or demand from consumers outside the Target Market;
if the product is distributed to consumers under 18 years of age;
if the product is distributed to consumers who are not Australian citizens or permanent residents; and
if the product is distributed in a manner that is otherwise materially inconsistent with company polices that adopt credit regulatory compliant practices, as may be determined from time to time.

Triggers for an earlier TMD review

Legislation changes affecting the product.
Significant and unexpected increase in default rates and bad debt write-offs, hardship rates or product complaint rates.
A significant increase in applications from consumers outside the Target Market.
Poor product performance or outcomes.
Distribution conditions found to be inadequate.
Poor distribution delivery.
Any other material inconsistency coming to the attention of the company from any information source, in regard to the TMD and/or the product design and/or the distribution and/or the Target Market.

Frequency required for distributors’ complaints reports to company management

In-house management and staff who are not representatives will also be encouraged to report at any time within 10 business days of becoming aware of a relevant reportable circumstance.

In addition, Suncoast Loans will welcome reports from other non-representatives and non-distributors at any time.

Format and details required for distributor’s reports

If they ever have anything to report, distributors are to report by email to the Business Development Manager, in their role of TMD Manager.

Details to be reported include:

the number of complaints received;
the time period over which the complaints were received;
the name/s of the consumers;
what the problem was, with particular attention to Target Market requirements, financial circumstances and needs;
what the resolution was;
the time to resolve it; and
if there are any unresolved complaints.

Additional reporting required from distributors

Effective Date

This Target Market Determination is effective from 5 October 2021 and applies only to products obtained on or after 5 October 2021.

Website Terms & Conditions

• Kawana Pawnbrokers PTY LTD ABN 52 100 857 127, trading as Suncoast Loans, provides access to this site free of charge to provide information about Suncoast Loans, its capabilities and the services it provides customers. The sole authorised use of the site is to obtain information about and apply for services supplied by Suncoast Loans and no other use is permitted.By accessing, viewing or otherwise using this website, or any material available on this website, you indicate that you accept these Terms of Use. As such, you should review these Terms of Use, as they are subject to change. If you do not accept these Terms of Use, you are not permitted to use this website or any of the material available on this website.

• This site is offered in the English language. The information, and the products and services that are made available through this website, are intended only for residents of Australia. The information and materials on this website are subject to change, or termination without prior notice.

• Suncoast Loans assumes no liability for the security of this site or your communications with the site. It is strictly prohibited to link third party websites with this site without Suncoast Loans prior written permission. We may permit some links from third party websites to this site, or otherwise include links to third party websites on this site, but Suncoast Loans takes no responsibility for, and excludes any and all liability associated with, such third party websites to which it is linked or for material posted to this site by anyone other than Suncoast Loans. We regularly review our website security measures, and take reasonable efforts to ensure that the most up-to-date encryption methods are used. However, we cannot guarantee that information that you transmit over the internet is entirely secure. When you submit information via this website, you accept that you do so at your own risk. We take all reasonable care to ensure that information that is received by us is secure in our systems, and we encrypt the data prior to transmitting it via the internet to third parties. However, we can never guarantee that the information received is secure. We do not guarantee that this website is virus free, or that access to this website will be free from interruption. By using this website, you accept that you do so at your own risk and you agree to provide true, accurate, current and complete information about yourself and any accounts that you hold or maintain elsewhere and you agree to not misrepresent your identity or your account information. You agree to keep your account information up to date and accurate.

• This website may include links to external websites, including websites that have software available for download. To the extent permitted by law, we do not accept responsibility or liability for, nor do we give any warranty in respect of, any third party websites, their contents, or any goods and services they offer. We may receive payments from the operators of third party websites in relation to goods or services they supply to you as a result of access to their website gained through a link on this website. Third party websites are not subject to our Privacy Policy. We suggest that you read the privacy policy relevant to each third party website that you access through this website.

• Suncoast Loans may collect and store personally identifiable information about persons who visit this site and voluntarily submit information in the course of contacting Suncoast Loans. We may also collect and store anonymous information about user contact with and use of the site (including through the use of cookies). We may use the information to contact you about our products and services from time to time. You may ask us to delete any information about you and cease further contact at any time by sending us a request marked “Privacy-Contact” to:admin@suncoastloans.com.au Further information about how Suncoast Loans handles personally identifiable information is set out in its Privacy Policy

• This website contains general information about our products and services. This information does not, unless we state otherwise, constitute an offer or inducement to enter into a credit contract, nor form part of any terms and conditions of any products or services offered

• It is strictly prohibited to use or contact this site to disrupt or damage the site, its contents or its security measures or to harass or disparage Suncoast Loans, its respective products or services or personnel. No unsolicited email (spam) may be directed to or through this site.

• While we have taken all reasonable steps to ensure that the information contained in this website is accurate and complete, we do not warrant that the information is free from error or omission. We do not warrant that the quality of the products or services made available on this website will meet your expectations.

• To the extent permitted by law, this site is offered without warranties of any kind and Suncoast Loans disclaims any implied warranties of merchantability and fitness for a specific purpose as well as title or non-infringement. We are not responsible for timeliness, accuracy, unavailability or interruptions in availability, viruses or other defects in the site or its contents. In no event shall Suncoast Loans be liable for any loss or damages suffered by users (whether to their computer systems or otherwise) or third parties, as a result of or in connection with accessing this site, even if Suncoast Loans has been informed of the possibility of such damage and without regard to negligence.

• Copyright in all material (including any compilation) on this site is owned by, or licenced to, Suncoast Loans Pty Ltd.Except to the extent prescribed by the Copyright Act 1968 (Cth). You are prohibited from reproducing, creating links to, framing, uploading to a third party or storing or transmitting any part of this website. All trade names, trademarks, service marks, logos and trade styles on this site are owned by Suncoast Loans Pty Ltd. Proper use is limited to use in connection with the products and services of the mark owner and its subsidiaries and no other use is permitted without the owner’s prior written permission

• Use of this site is subject to these terms and conditions which you as user accept by contacting and using this site. Suncoast Loans reserves the right to revise and update these terms and conditions at any time, effective on the date of posting to the site of the revised or updated terms and conditions.

Download Forms

Credit Guide

CREDIT PROVIDER’S CREDIT GUIDE

Licensee’s name (being a Credit Provider):

Kawana Pawnbrokers Pty Ltd, ABN: 52 100 857 127

Licensee’s trading office:

6/2 Premier Circuit, Warana, Queensland, 4575

Telephone:

07 5493 6133

Postal address:

PO Box 650, Mooloolaba, Qld 4557

Australian Credit Licence Number:

384040

Internal Dispute Resolution (IDR) Procedure:

IDR Manager:

Phone:

Email:

External Dispute Resolution (EDR) Procedure:

EDR Ombudsman:

Postal address:

Suitability of the Loan

Whether or not you will be able to comply with the financial obligations under the contract, without substantial hardship, if at all.

Whether or not the contract will meet your requirements and objectives.

Whether or not the contract meets requirements imposed by regulation, from time to time.

It involves us, as a Credit Provider, making enquiry about your financial circumstances.

According to whether or not we believe the information to be true.

Privacy Policy

Financial Difficulty

Privacy Consent Agreement

Dispute Resolution Policy

Target Market Determination

Medium Amount Credit Contracts (MACCs) – Personal Loans

All Other Contracts (AOCCs) – Personal Loans

All Other Contracts (AOCCs) - Personal Loans - First and Second Mortgages

Website Terms & Conditions

Download Forms

Application Form

ID Checklist

Credit Guide

Privacy Policy

Privacy Consent Agreement