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. |
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IDR Manager:Paul McLachlan Phone:07 5493 6133 Email:admin@suncoastloans.com.au |
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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. |
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EDR Ombudsman:AFCA – Phone: 1800 931 678, or go to www.afca.org.au Postal address:GPO Box 3, Melbourne, VIC, 3001 |
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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:
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Whether or not you will be able to comply with the financial obligations under the contract, without substantial hardship, if at all.
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Whether or not the contract will meet your requirements and objectives.
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Whether or not the contract meets requirements imposed by regulation, from time to time.
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It involves us, as a Credit Provider, making enquiry about your financial circumstances.
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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
Including Statement of Notifiable Matters, Credit Reporting
Disclosures and Privacy Information
Kawana Pawnbrokers Pty Ltd
Trading as Suncoast Loans
Australian Credit Licence 384040
ABN 52 100 857 127
(hereafter referred to as Suncoast Loans)
Version: March 2026
Review Date: March 2027
Approved by the Director of Kawana Pawnbrokers Pty Ltd- Paul McLachlan
Please read this Policy before providing Suncoast Loans with any personal information in connection with an enquiry, application for credit, existing loan account or any other dealings with us.
By providing personal information to Suncoast Loans, you acknowledge that you have had the opportunity to read this Policy and understand how we collect, hold, use, disclose, verify, store and manage your personal information, credit-related information and credit eligibility information.
This Policy explains how Suncoast Loans collects, holds, uses, discloses, verifies and manages personal information, credit-related information and credit eligibility information in accordance with:
- Privacy Act 1988 (Cth), as amended from time to time;
- Australian Privacy Principles (APPs);
- Privacy (Credit Reporting) Code 2025;
- National Consumer Credit Protection Act 2009 (Cth), including the National Credit Code;
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated AML/CTF Rules; and
- other applicable Commonwealth and State legislation, regulations and regulatory requirements
Concerning the Collection, Holding, Use and Disclosure of Personal Information, Credit Information and Credit Eligibility Information
Suncoast Loans collects, holds, uses, discloses, verifies and manages personal information, credit-related information and credit eligibility information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Privacy (Credit Reporting) Code 2025 and other applicable laws.
This Policy outlines the approach adopted by Suncoast Loans in relation to the collection, holding, use, disclosure and management of information obtained from prospective customers, applicants for credit, existing customers, co-borrowers, guarantors, authorised representatives, credit reporting bodies, government agencies and other entities referred to in this Policy.
The collection of information may commence when you make an enquiry, apply for credit, seek hardship assistance, make a complaint, request a variation to an existing credit contract, provide supporting documentation or otherwise engage with Suncoast Loans.
As part of our responsible lending obligations under the National Consumer Credit Protection Act 2009, fraud prevention measures and obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Suncoast Loans may undertake reasonable enquiries and verification procedures to assess:
- your identity;
- your financial circumstances;
- your credit history, Financial Position and Repayment Capacity
- your capacity to meet your obligations under a credit contract; and
- the suitability of any credit contract for your requirements and objectives.
These enquiries may include obtaining information from:
- credit reporting bodies;
- identity verification providers;
- financial institutions;
- government agencies;
- employers;
- accountants;
- referees;
- Centrelink (where authorised by you);
- vehicle dealers and introducers; and
- other sources permitted by law.
Verification procedures may include reviewing:
- identification documents;
- bank statements;
- income verification documents;
- credit reports;
- Centrelink Income Statements;
- employment information; and
- other information reasonably required to assess an application, manage a credit facility, comply with legal obligations or assist in preventing fraud, money laundering and other financial crime.
Suncoast Loans may use electronic verification systems, credit reporting information and other lawful verification methods to verify information supplied by you and to comply with responsible lending, fraud prevention, identity verification, anti-money laundering and counter-terrorism financing obligations.
Information collected by Suncoast Loans may be used for the purposes of assessing credit applications, administering loan accounts, assessing hardship requests, responding to complaints, complying with legal and regulatory obligations, undertaking ongoing customer due diligence where required by law and protecting against fraud, money laundering, terrorism financing and other financial crime.
Introduction
In the course of our business, Suncoast Loans provides consumer credit and, from time to time, business credit. Consumer credit is generally provided wholly or predominantly for personal, domestic or household purposes in accordance with the National Consumer Credit Protection Act 2009 (Cth) and the National Credit Code.
As part of our lending activities, Suncoast Loans collects, holds, uses, discloses, verifies and manages personal information, credit-related information and credit eligibility information for the purposes of assessing applications for credit, administering and managing credit facilities, assessing hardship requests, investigating complaints, complying with legal and regulatory obligations, protecting against fraud and financial crime, and providing customer assistance where required.
In the course of our business, Suncoast Loans may assess:
(a) your eligibility to be provided with credit;
(b) your credit history, repayment conduct, financial position and repayment capacity;
(c) your financial circumstances and repayment capacity;
(d) your requirements and objectives in relation to a credit product;
(e) your ability to meet your obligations under a credit contract; and
(f) information reasonably required to comply with our legal and regulatory obligations.
The Kinds of Credit Information We Collect and Hold
In accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Privacy (Credit Reporting) Code 2025, the National Consumer Credit Protection Act 2009 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and other applicable laws, Suncoast Loans may collect, hold, use and disclose personal information, credit-related information and credit eligibility information that is reasonably necessary for our business activities and legal obligations.
The types of information we may collect and hold include:
- identification information;
- contact details and personal particulars;
- credit liability information;
- repayment history information;
- information relating to applications for credit;
- information relating to the type and amount of credit sought or provided;
- overdue payment and default information;
- payment information and account conduct information;
- information relating to hardship requests, repayment arrangements, loan variations and other arrangements concerning an existing credit contract;
- court judgments, tribunal decisions and civil proceedings information;
- personal insolvency information, including information recorded on the National Personal Insolvency Index;
- company insolvency information relevant to business credit applications;
- publicly available information relevant to your identity, financial circumstances, credit history, financial position or repayment capacity;
- serious credit infringement information where permitted by law;
- information obtained from credit reporting bodies;
- information obtained through identity verification procedures;
- information obtained from financial institutions, employers, accountants, referees, government agencies, Centrelink (where authorised by you), brokers, introducers and other authorised sources;
- unsolicited information where permitted by law and considered reasonably necessary for our business activities;
- information reasonably required to assess, administer, manage or enforce a credit contract, assess hardship assistance, investigate complaints, comply with legal and regulatory obligations or protect against fraud, money laundering, terrorism financing and other financial crime; and
- information reasonably required to comply with the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025, the National Consumer Credit Protection Act 2009 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), court orders, regulatory requirements and other applicable laws.
Identification Information About You
To comply with responsible lending obligations, fraud prevention requirements, identity verification obligations and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), Suncoast Loans may collect, verify, hold, use and disclose identification information about you.
To assist in verifying your identity, assessing an application for credit, administering a credit facility and complying with legal and regulatory obligations, we may request some or all of the following information:
• your full name;
• any previous names, aliases or former names;
• date of birth;
• current residential address;
• previous residential addresses where reasonably required;
• contact details, including telephone number and email address;
• driver’s licence details;
• passport details;
• Medicare details where permitted by law;
• visa, citizenship or residency information where applicable;
• employment details, including current and previous employment information where reasonably required; and
• other identification information reasonably required to verify your identity, assess an application or comply with legal obligations.
Suncoast Loans may verify identification information using:
- original or certified identification documents;
- electronic identity verification systems where utilised by Suncoast Loans
- credit reporting bodies;
- government-issued identification records;
- financial institutions;
- independent data sources; and
- other lawful verification methods.
Where satisfactory identification cannot be obtained, Suncoast Loans may request additional information or documentation and may be unable to proceed with an application, provide credit, continue to provide services or otherwise deal with you until applicable identification and verification requirements have been satisfied.
Identification information may also be collected, verified, held, used and disclosed for the purposes of complying with responsible lending obligations, fraud prevention measures, anti-money laundering and counter-terrorism financing requirements, court orders, regulatory requirements and other applicable laws.
Consumer and Business Credit Liability Information
Suncoast Loans may collect, hold, use and disclose information relating to existing, previous or proposed consumer and business credit facilities for the purposes of assessing credit applications, administering credit facilities, complying with legal obligations and managing credit-related activities.
This information may include:
•the name of the credit provider;
• whether the credit provider holds an Australian Credit Licence or is otherwise authorised to provide credit;
• the type of credit applied for or provided;
• the date on which the credit facility commenced;
• the terms and conditions of the credit facility relevant to repayment obligations;
• the approved credit limit, loan amount or maximum amount available under the credit facility;
• details of repayment obligations;
• information relating to security held in connection with a credit facility;
• information relating to variations, hardship arrangements or repayment arrangements associated with a credit facility; and
• the date on which a credit facility is terminated, discharged, repaid or otherwise ceases to be in force.
Repayment History Information
Where Suncoast Loans provides credit to you, we may collect, hold, use and disclose repayment history information in accordance with applicable laws.
Repayment history information may include:
• whether repayments have been made when due;
• whether repayment obligations have been met in full;
• information relating to overdue payments;
• information relating to payment arrangements and hardship arrangements;
• information relating to defaults, arrears and enforcement action where permitted by law;
• the date on which repayments become due and payable;
• the date on which repayments are made; and
• other information relating to the conduct, performance and management of a credit facility
Where permitted or required by law, repayment history information may be disclosed to credit reporting bodies, regulators, government agencies and other authorised entities for purposes permitted under the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025 and other applicable legislation.
Overdue and Default Information
Suncoast Loans may collect, hold, use and disclose information relating to overdue payments, arrears, defaults, repayment arrangements, hardship arrangements, recovery action and enforcement activity in accordance with the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025, the National Consumer Credit Protection Act 2009 (Cth), the National Credit Code and other applicable laws.
Information collected and held may include:
- details of overdue payments;
- arrears balances;
- default information;
- payment arrangements;
- hardship arrangements;
- repayment conduct and repayment history information;
- recovery action;
- enforcement activity; and
- other information relating to the administration, management, recovery and enforcement of amounts owing under a credit contract.
Where permitted or required by law, Suncoast Loans may disclose information relating to overdue payments, arrears, repayment history information and defaults to credit reporting bodies, regulators, government agencies, courts, tribunals and other authorised entities.
Before default information is disclosed to a credit reporting body, Suncoast Loans will comply with all applicable legislative requirements, including any notice, disclosure and waiting period requirements prescribed by law.
Court Proceedings Information
Suncoast Loans may collect, hold, use and disclose information relating to court proceedings, tribunal proceedings, judgments, enforcement orders, insolvency proceedings and other legal proceedings that are relevant to:
- an application for credit;
- an existing credit facility;
- recovery of amounts owing;
- hardship assistance;
- insolvency matters;
- fraud prevention activities; or
- other matters relevant to the assessment, administration, management or enforcement of a credit facility.
Such information may be obtained from publicly available records, courts, tribunals, insolvency registers, government agencies and other lawful sources.
How We Collect Credit Information
Suncoast Loans may collect credit-related information, credit eligibility information and personal information from a variety of sources, including:
- directly from you;
- from information and documentation supplied by you;
- from credit reporting bodies;
- from identity verification providers;
- from financial institutions;
- from employers, accountants, referees and other persons authorised by you;
- from other credit providers;
- from brokers, introducers and authorised representatives;
- from AFCA and other dispute resolution processes where relevant;
- from government agencies;
- from publicly available information, including court and tribunal records, insolvency registers and public databases; and
- from other sources permitted or authorised by law.
Depending on the circumstances, Suncoast Loans may not require information from all available sources to assess an application, administer a credit facility, assess hardship assistance, investigate a complaint or otherwise manage its relationship with you.
Suncoast Loans may collect financial information, transaction data and bank account information through secure third-party data sharing, bank statement retrieval and Open Banking service providers where authorised by you. Information obtained through these services may be used to verify income, expenses, liabilities, account conduct, financial position and repayment capacity, and to assist Suncoast Loans in complying with responsible lending, fraud prevention, identity verification and AML/CTF obligations
How We Hold Credit Information Securely
Suncoast Loans takes reasonable steps to protect personal information, credit-related information and credit eligibility information from misuse, interference, loss, unauthorised access, modification and disclosure.
Security measures may include:• restricted staff access;
- password-protected systems and applications;
- secure electronic document management systems;
- secure storage of physical records;
- staff confidentiality obligations;
- secure destruction and disposal procedures;
- system monitoring and audit controls; and
- staff training and awareness programs.
Suncoast Loans regularly reviews its information security measures to assist in protecting personal information, credit-related information and credit eligibility information.
Data Breaches
Where an eligible data breach occurs, Suncoast Loans will comply with its obligations under the Privacy Act 1988 (Cth), including any applicable notification requirements under the Notifiable Data Breaches Scheme.
The Kinds of Credit Eligibility Information We Hold
Credit eligibility information includes credit-related information obtained from a credit reporting body and other information permitted to be disclosed to Suncoast Loans under the Privacy Act 1988 (Cth) and the Privacy (Credit Reporting) Code 2025.
Suncoast Loans may collect, hold, use and disclose credit eligibility information for purposes permitted by law, including:
- assessing applications for credit;
- administering and managing credit facilities;
- complying with responsible lending obligations;
- assessing hardship requests;
- investigating complaints;
- fraud prevention;
- complying with legal and regulatory obligations; and
- protecting against money laundering, terrorism financing and other financial crime.
How We Hold Credit Eligibility Information
Credit eligibility information is held in secure physical and electronic environments.
Physical records are stored in secure locations with controlled access.
Electronic records are protected through security controls which may include password protection, user access controls, secure networks, encryption technologies, system monitoring and other appropriate security measures designed to protect information from unauthorised access, misuse, loss, modification or disclosure.
Credit Reporting Bodies
Suncoast Loans may obtain information from, and disclose information to, credit reporting bodies in accordance with the Privacy Act 1988 (Cth) and the Privacy (Credit Reporting) Code 2025.
Credit reporting bodies used by Suncoast Loans may include:
- Equifax;
- illion;
- Experian; and
- other credit reporting bodies used by Suncoast Loans from time to time.
You may contact a credit reporting body if:
(a) you believe information held about you is inaccurate, incomplete, out of date, irrelevant or misleading and requires correction;
(b) you believe you have been, or may become, a victim of fraud or identity theft and wish to request a ban period or other protective measures;
(c) you do not wish your credit reporting information to be used for pre-screening of direct marketing offers by credit providers; or
(d) you wish to obtain a copy of the credit reporting body’s privacy policy.
Current contact details for Equifax are available from the Equifax website.
Website: https://www.equifax.com.au
Telephone: 13 8332
Information Obtained from Credit Reporting Bodies
Subject to the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025 and other applicable laws, Suncoast Loans may obtain credit-related information, credit reporting information and credit eligibility information from credit reporting bodies for purposes permitted by law.
Credit reporting bodies may collect, hold, use and disclose information obtained from Suncoast Loans, other credit providers and other sources authorised or permitted by law.
Information obtained from a credit reporting body may include:
- identification information;
- credit liability information;
- repayment history information;
- information relating to credit applications and credit enquiries;
- information relating to the type and amount of credit applied for or provided;
- overdue payment and default information;
- serious credit infringement information where permitted by law;
- payment information and repayment conduct information;
- information relating to repayment arrangements, hardship arrangements and variations to credit contracts;
- court judgments, tribunal decisions and civil proceedings information;
- personal insolvency information;
- publicly available information relevant to credit reporting purposes;
- information relevant to fraud prevention and identity verification processes; and
- other information permitted to be collected, held, used or disclosed under the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025 and other applicable laws.
Information obtained from a credit reporting body may be used by Suncoast Loans for purposes including:
- assessing applications for credit;
- complying with responsible lending obligations;
- verifying information supplied by applicants and customers;
- administering and managing credit facilities;
- assessing hardship requests;
- investigating complaints and disputes;
- fraud prevention and identity verification;
- complying with legal and regulatory obligations; and
- protecting against money laundering, terrorism financing and other financial crime.
Information held by a credit reporting body may be disclosed to credit providers and other entities permitted or authorised by law.
Suncoast Loans does not control the information held by a credit reporting body or the manner in which a credit reporting body collects, stores, uses, discloses or manages information.
If you believe information held by a credit reporting body is inaccurate, incomplete, out of date, irrelevant or misleading, you may request that the credit reporting body correct that information. You may also contact Suncoast Loans if you believe information we have provided to a credit reporting body is inaccurate and requires correction.
You may contact a credit reporting body to:
- obtain a copy of its privacy policy;
- request access to information held about you;
- request correction of information held about you;
- make a complaint regarding the handling of your information;
- request that your information not be used for direct marketing pre-screening purposes where permitted by law; or
- request a ban period or other protective measures if you believe you have been, or may become, a victim of fraud or identity theft.
Credit reporting bodies used by Suncoast Loans may include:
- Equifax;
- illion;
- Experian; and
- other credit reporting bodies used by Suncoast Loans from time to time.
Further information about a credit reporting body’s privacy practices can be obtained directly from the relevant credit reporting body’s website or privacy policy.
Current contact details for Equifax Australia are available from the Equifax website:
Website: https://www.equifax.com.au
Telephone: 13 8332
Notifiable Matters
This Credit Information (Privacy) Management Policy contains information that Suncoast Loans is required to provide to individuals under the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Privacy (Credit Reporting) Code 2025 and other applicable laws.
This Policy explains how Suncoast Loans collects, holds, uses, discloses and manages personal information, credit-related information and credit eligibility information and outlines your rights in relation to that information.
This Policy should be read together with any Privacy Consent Agreement, credit application documentation and other privacy notices provided by Suncoast Loans from time to time.
Disclosure of Information to Regulators and External Dispute Resolution Schemes
Suncoast Loans may disclose personal information, credit-related information and credit eligibility information to regulators, government agencies, courts, tribunals and external dispute resolution schemes where permitted or required by law.
This may include disclosure to:
• the Australian Financial Complaints Authority;
• the Australian Securities and Investments Commission;
• the Australian Transaction Reports and Analysis Centre;
• courts and tribunals;
• law enforcement agencies; and
• other government agencies and regulatory bodies.
Such disclosures may occur for purposes including:
- complying with legal and regulatory obligations;
- responding to complaints, disputes and investigations;
- complying with court orders, notices and lawful requests;
- investigating suspected fraud, financial crime or misconduct; and
- complying with anti-money laundering and counter-terrorism financing obligations.The Purposes for Which We Collect, Hold, Use and Disclose Credit Information and Credit Eligibility Information
Suncoast Loans may collect, hold, use and disclose personal information, credit-related information and credit eligibility information for purposes including:
- assessing applications for credit;
- complying with responsible lending obligations;
- verifying information supplied by applicants and customers;
- administering and managing credit facilities;
- collecting and recovering amounts owing under credit contracts;
- managing hardship requests, repayment arrangements and loan variations;
- investigating complaints, disputes and suspected fraud;
- complying with legal and regulatory obligations;
- undertaking identity verification and fraud prevention activities;
- undertaking customer identification, customer verification and ongoing customer due diligence activities where required by law;
- detecting, preventing and investigating suspected fraud, money laundering, terrorism financing and other financial crime;
- complying with anti-money laundering and counter-terrorism financing obligations;
- enforcing rights and obligations arising under credit contracts; and
- any other purpose permitted or required by law.
Where permitted by law, Suncoast Loans may disclose relevant information to debt collection agencies, legal representatives, mercantile agents, recovery agents and other authorised parties for the purpose of collecting amounts owing under a credit contract, enforcing legal rights or otherwise administering a credit facility.
Disclosure of Information to Third Parties
Suncoast Loans may disclose personal information, credit-related information and credit eligibility information to third parties where reasonably necessary for our business activities, to administer and manage credit facilities, to comply with legal and regulatory obligations, or where otherwise permitted or required by law.
Depending on the circumstances, information may be disclosed to:
• credit reporting bodies;
• identity verification providers;
• financial institutions and payment service providers;
• employers, accountants, referees and other persons authorised by you;
• brokers, introducers and authorised representatives;
• debt collection agencies, mercantile agents, repossession agents and recovery service providers;
• legal advisers, solicitors and professional advisers;
• insurers and insurance providers;
• Open Banking providers, bank statement retrieval providers and data aggregation service providers authorised by you.
• government agencies and regulators;
• courts, tribunals and law enforcement agencies;
• the Australian Financial Complaints Authority (AFCA);
• the Australian Securities and Investments Commission (ASIC);
• the Australian Transaction Reports and Analysis Centre (AUSTRAC);
• contractors, service providers and technology providers who assist Suncoast Loans in conducting its business activities;
• related entities and associated businesses where permitted by law; and
• other persons or organisations where disclosure is authorised by you or otherwise permitted or required by law.
Suncoast Loans takes reasonable steps to ensure that third parties receiving personal information from Suncoast Loans are required to handle that information in accordance with applicable privacy and confidentiality obligations.
Accessing and Correcting Information Held About You
You may request access to personal information, credit-related information and credit eligibility information held by Suncoast Loans.
Requests for access or correction should be directed to:
Privacy Officer
Suncoast Loans
PO Box 650, Mooloolaba QLD 4557
Telephone: (07) 5493 6133
Email: admin@suncoastloans.com.au
Suncoast Loans will respond to requests for access or correction within a reasonable period and in accordance with applicable laws.
Subject to any legal restrictions, you may request:
- access to information held about you;
- correction of information that is inaccurate, incomplete, out of date, irrelevant or misleading; and
- information about how your personal information, credit-related information and credit eligibility information has been handled.
Where access is granted, Suncoast Loans may provide the information in a form considered appropriate in the circumstances and may provide explanations to assist you in understanding the information.
Access may be refused where permitted or required by law, including where providing access would:
• be unlawful;
• prejudice law enforcement activities;
• reveal information relating to another person;
• breach a court order; or
• otherwise be restricted by law.
If access is refused, Suncoast Loans will provide written reasons for the refusal (where permitted by law) and information about available complaint and review processes.
Correction of Information
If you believe information held by Suncoast Loans is inaccurate, incomplete, out of date, irrelevant or misleading, you may request that the information be corrected.
Suncoast Loans will take reasonable steps to investigate and respond to correction requests and, where appropriate, correct the information held.
Where Suncoast Loans has previously disclosed information to a credit reporting body or another organisation and the information is subsequently found to be inaccurate, incomplete, out of date, irrelevant or misleading, Suncoast Loans may take reasonable steps to notify relevant parties of the correction where required by law.
Where Suncoast Loans determines that information held is accurate, complete, up to date, relevant and not misleading, the information may be retained and no correction may be made.
If you are dissatisfied with the outcome of a request for access or correction, you may lodge a complaint through Suncoast Loans’ Internal Dispute Resolution process and, if not satisfied, may refer the matter to:
- Australian Financial Complaints Authority; or Office of the Australian Information Commissioner,
subject to the jurisdiction and requirements of those organisations.
Complaints About Privacy and Credit Reporting Matters
Suncoast Loans is committed to resolving complaints relating to privacy, credit reporting and the handling of personal information fairly, efficiently and promptly.
If you wish to make a complaint regarding the collection, use, disclosure, storage, security, correction or handling of your personal information, credit-related information or credit eligibility information, you should first contact Suncoast Loans using the contact details provided in this Policy.
Complaints may be made verbally or in writing.
Suncoast Loans will acknowledge, investigate and respond to complaints in accordance with its Internal Dispute Resolution procedures and applicable legal requirements.
Suncoast Loans is a member of the Australian Financial Complaints Authority (AFCA).
Upon receiving a complaint, Suncoast Loans will acknowledge receipt of the complaint and undertake an appropriate investigation.
Following completion of the investigation, Suncoast Loans will provide a response outlining the outcome of the complaint and the reasons for the decision.
Complaints will be managed in accordance with Suncoast Loans’ Internal Dispute Resolution procedures and applicable legal and regulatory requirements.
If you are dissatisfied with the outcome of a complaint or Suncoast Loans’ Internal Dispute Resolution process, you may refer the matter to the Australian Financial Complaints Authority (AFCA), the Office of the Australian Information Commissioner (OAIC) or another relevant external dispute resolution body, subject to their jurisdictional requirements.
Office of the Australian Information Commissioner (OAIC)
Postal Address:
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Website: www.oaic.gov.au
Australian Financial Complaints Authority (AFCA)
Postal Address:
GPO Box 3
Melbourne VIC 3001
Telephone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au
There is no charge for lodging a complaint with AFCA.
Disclosure of Information Outside Australia
Suncoast Loans generally stores and manages personal information, credit-related information and credit eligibility information within Australia.
If Suncoast Loans proposes to disclose personal information, credit-related information or credit eligibility information to an overseas recipient, such disclosure will only occur where permitted by law and in accordance with the Privacy Act 1988 (Cth).
At the date of this Policy, Suncoast Loans does not generally disclose credit-related information or credit eligibility information to overseas recipients.
Obtaining a Copy of This Policy
You may obtain a copy of this Credit Information (Privacy) Management Policy free of charge by contacting the Privacy Officer using the contact details provided in this Policy.
Copies may be provided electronically or by post upon request.
Use of Website, Cookies and Online Applications
Suncoast Loans may collect information when you use our website, online forms or electronic application systems. This may include information submitted by you, device information, IP address information and cookies used to improve website functionality, security and customer experience.
Further information regarding the use of cookies may be available on the Suncoast Loans website.
Government Identifiers
Where Suncoast Loans collects government-related identifiers such as driver licence numbers, Medicare details, passport details or other identification numbers, we will only use or disclose those identifiers where permitted or required by law, including for identity verification, fraud prevention, responsible lending, AML/CTF compliance or account administration.
Sensitive Information
Suncoast Loans will only collect sensitive information where reasonably necessary and where permitted by law, including where you have consented or where the information is required to assess hardship assistance, complaints, legal obligations or other customer support matters.
Changes to This Policy
Suncoast Loans may update this Policy from time to time. The current version will be available on request and, where applicable, on our website.
Direct Marketing and Communications
From time to time, Suncoast Loans may provide information about products, services, promotions, updates, news and other matters that may be of interest to you.
Where required by law, Suncoast Loans will only send direct marketing communications with your consent or where otherwise permitted by law.
Suncoast Loans will comply with applicable privacy, consumer protection and electronic communications laws, including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and other applicable legislation in relation to direct marketing activities.
You may opt out of receiving direct marketing communications from Suncoast Loans at any time and Suncoast Loans will action such requests in accordance with applicable legal requirements.
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.
Privacy Consent Agreement
YOUR PRIVACY AND THE PROVISION OF CREDIT
KAWANA PAWNBROKERS PTY LTD (Hereafter referred to as Suncoast Loans)
Australian Credit Licence No. 384040
There are 4 SECTIONS included in this form.
Please read each Section carefully.
SECTION 1
PRIVACY CONSENT AGREEMENT
Also constituting a Statement of Notifiable Matters
By signing or otherwise consenting to this agreement, you consent to Suncoast Loans and other entities, including Loan Barn Pty Ltd collecting, holding, using and disclosing personal identification and credit information about you. If you do not provide us with this consent we will be unable to provide you with a loan. This policy contains detailed information concerning the company’s management and use of your information and constitutes a Statement of Notifiable Matters, with content in accordance with that prescribed by Clause 4.1 in the Credit Reporting Privacy Code.
As well as reading this document, you are strongly encouraged to read the Credit Information (Privacy) Management Policy on our website at www.suncoastloans.com.au and/or provided in hard or electronic copy as you may request, before you provide any personal information. In all our dealings with you, we will assume that you have done so.
The Commonwealth Privacy Act 1988, as amended, the Commonwealth Privacy Regulations 2013, and the Credit Reporting Privacy Code 2014 empower and regulate Suncoast Loans in accordance with the following.
Use of your Information – Australian Privacy Principle 6
In accordance with Sections 21G, 21H, 21J and 21 M of the Privacy Act, Suncoast Loans collects and holds your personal identification and credit information only for the following purposes:
- to verify your identity and other information provided;
- to assess any application you make for a loan;
- to assess your financial circumstances;
- to help us process your application for a loan in an efficient manner;
- to avoid the chance you may default on your payment obligations;
- to notify you of a default;
- to notify other lessors of a default;
- to facilitate the collection of overdue payments;
- to efficiently manage and administer the loan and any services we provide to you; and
- to introduce you to another lessor, when we act as a referrer.
Sources of information
By signing or otherwise consenting to this agreement, you give Suncoast Loans permission to collect information from a wide variety of sources. This information can include any information about your credit worthiness, credit standing, credit history, or credit capacity, that you, other credit providers or lessors and credit reporting bodies and their authorised agents are allowed to provide to Suncoast Loans under the Privacy Act and/or Credit Reporting Privacy Code. It may also include information provided by referees, relatives, your bank, real estate agents, landlord, payroll officer and employers (past and present), that may or may not be listed on your loan application, together with other credit providers, with lessors, and with government agencies and departments.
By agreeing to this Section, you authorise Suncoast Loans to contact any one or more of these sources, to provide any and all permitted relevant information they may have regarding you, including tenancy or employment history and bank account and other financial details.
Suncoast Loans may ask you for documents, including one or more of the following:
- 90 days of bank statements, to date of application;
- driver’s licence;
- Centrelink income statements;
- employment payslips;
- bills and invoices, showing current address and payment information;
- bank cards;
- passport;
- birth certificate;
- proof of age cards;
- copies of any lease agreements;
- copies of any credit contracts;
and the like.
This information is only accessed as required by Suncoast Loans’ employees, representatives, professional advisers, contractors and other service providers, to facilitate the above purposes and to satisfy the responsible lending requirements of the National Consumer Credit Protection Act. Suncoast Loans will not sell, rent or trade your personal information.
Suncoast Loans reasonably assumes that any referral to third parties that you may nominate, in order that Suncoast Loans may obtain or verify your personal and other information, will have been with the agreement and knowledge of the third parties involved and that you will have made them aware of the purposes and use of such information, prior to Suncoast Loans contacting them.
Your identity verification
Suncoast Loans may verify your identity by attempting to match information you have provided with that held by a verification company and/or a credit reporting body. This task may involve the disclosure of your name, date of birth and address, to verify whether or not the personal identity information you have provided to Suncoast Loans matches information held by that third party.
If we are unable to verify your identity by the above means, Suncoast Loans will inform you, so that you might contact the verification company or credit reporting body to update your information they hold, or you may ask Suncoast Loans to attempt to verify your identity by alternate means.
In accordance with Section 21D of the Privacy Act, Suncoast Loans has chosen to continue with the lawful negative credit reporting (privacy) regime. By consenting to this section, you specifically agree that the company may provide information to Equifax & Illion, the credit reporting bodies which Suncoast Loans uses. This disclosure will be for the following purposes only:
- to obtain identity verification information;
- to obtain a consumer credit report about you, and/or
- to allow the credit reporting body to create or maintain a credit information file, containing information about you.
When seeking a credit report about you, Suncoast Loans will disclose information you have provided to the credit reporting body. This may include, but not necessarily be limited to:
- your name;
- the type of credit you want;
- the amount;
- the role involved;
- a reference number;
- a relevant date; and
- that your application for a loan has been made with Suncoast Loans –
in accordance with Equifax & Illion policies.
Equifax & Illion’s privacy policies are posted on their company’s website.
Information disclosed to one or more credit reporting bodies
In our dealings with Equifax & Illion we may also disclose information about the history of your borrowing from Suncoast Loans, including
- identity particulars – your name, sex, address (and previous two addresses), date of birth, name of employer and driver’s licence number;
- your application for a loan;
- the fact that Suncoast Loans may provide, or has provided you with a loan;
- the fact that your loan has incurred overdue account status;
- the fact that your loan has incurred default status; and
- information that, in the reasonable opinion of Suncoast Loans you have committed a serious credit infringement (i.e. you have been fraudulent, or indicated an unwillingness to make your loan payments).
All of this information is used to assess your credit worthiness.
The credit reporting body and your information
You should assume that all the credit information we collect from you, or about your financial history and status, can be used in Equifax & Illion reports about your financial circumstances and made available to credit providers that use Equifax & Illion credit report services.
This could include a credit provider with whom you are applying for a loan, who may consider the number of loan applications you have made in the past, when undertaking an assessment of your suitability to be issued a loan. The number of applications and the types of loan for which you have previously applied may influence that credit provider’s application assessment policy.
Information disclosure to other entities
Under Part 111A of the Privacy Act, Suncoast Loans may disclose your personal information to:
- other credit providers;
- lessors;
- our external service providers and their agents who provide business services to us, on a confidential basis, only for the purpose of our business;
- the Australian Financial Complaints Authority (AFCA), to which a complaint relating to a particular service we provide to you can be referred. Telephone – 1300 565 562, email – info@afcs.org.au, postal address – GPO Box 3, Melbourne, Vic 3001, website – www.afca.org.au; and
- any court or tribunal as may be required by law.
Suncoast Loans may provide limited permitted information to real estate agents, employers, referees, government departments and authorities, and other third party entities that you may have listed in your loan application/assessment form, for identity and/or credit information verification purposes.
The names and contact details of the other credit providers and/or lessors with whom we have shared information, if any, will be provided on request, as they vary from time to time and for the particular consumer.
Referred information
The information we may provide to another credit provider, if acting as a referrer, will be limited to the following:
- your name;
- your contact details; and
- the purpose of your proposed loan.
Period to which this understanding applies
The information may be collected or disclosed before, during, or after the term of the provision of the loan.
Information disclosure in the event of a default of your payment obligations
In the event of the creation of an overdue account and/or default of the repayment conditions entered into in with Suncoast Loans, any information you have provided may be made available to personnel employed by solicitors and/or debt collection agencies authorised by Suncoast Loans to assist in the process of recovery of the overdue payments, plus all associated fees and charges (if any) and all relevant legal and reasonable administrative costs incurred.
In addition, in the event of a default in payment, a series of payments, or a serious credit infringement, Suncoast Loans may inform Equifax & Illion of the situation and that information will be held on file by Equifax & Illion and appear in your credit reports.
Access to your personal information
You have a right to contact Suncoast Loans and may request the opportunity to inspect the credit information we hold about you and to ask for correction of any matter you reasonably deem and justify to be incorrect, outdated, irrelevant, incomplete or misleading.
You can apply to Suncoast Loans to obtain access to your personal information by contacting the Privacy Compliance Manager by email at admin@suncoastloans.com.au, or post to PO Box 650, Mooloolaba, QLD, 4557.
You can also apply to access the personal information Equifax holds about you. They may be contacted on telephone no. 1300 762 207, and Illion on 1300 734 806 or through www.mycreditfile.com.au.
Direct marketing
By signing or otherwise consenting to this agreement, you consent to Suncoast Loans sending you direct marketing promotional information concerning Suncoast Loans’ products and/or credit activities.
Should you not wish to receive this direct marketing material, you may notify us at any time using the link provided at the bottom of any email message or the Opt Out facility provided in any SMS.
Concerns and complaints
If you have any privacy management concerns during the application process and term of the loan, please contact Suncoast Loans’ Privacy Compliance Manager.
You also have a right to ask the relevant credit reporting body not to use your information for pre-screening credit offers and/or not to use your information if you believe that you have been a victim of fraud.
Commercial credit Information
In order to assess an application for a loan, Suncoast Loans may obtain a report containing information about your commercial credit activities and/or credit worthiness from a credit reporting body. To the extent that any of this information could be regarded as personal, the provisions outlined in this section, in regard to personal information, apply.
SECTION 2
Information Disclosure and Communications Under the SPAM Act 2003
You are informed that Section 16 of the Spam Act provides that Suncoast Loans cannot communicate with you via a “commercial electronic message” (email, fax, SMS) without your consent.
As you would expect, for speed and convenience, where possible and with your permission, Suncoast Loans would prefer to communicate with you using such electronic means. Without your permission, written communications will have to be conveyed by Australia Post.
SECTION 3
The Electronic Transactions Act 1999
You are informed that the Electronic Transactions Act requires that, before Suncoast Loans can communicate with you electronically (email, fax, SMS), you also have to give permission under that Act for Suncoast Loans to communicate with you in that way.
We seek your permission to:
- electronically format and send you the information that we are obliged to provide under the National Consumer Credit Protection Act 2009 and associated Regulations;
- send you electronic messages, rather than providing paper copies.
You are informed that, in giving this permission, you are agreeing to:
- use the relevant computer programs and have sufficient internet capacity to interact with Suncoast Loans’ system;
- regularly check your email Inbox and/or fax machine and/or SMS Inbox;
- not blame Suncoast Loans if any properly sent electronic message does not reach you; and
- notify Suncoast Loans of any changes to your electronic addresses, and absolve Suncoast Loans from any liability if you fail to do so.
We remind you that you can withdraw your permission for the above at any time, provided you give Suncoast Loans 24 hours’ notice, confirming your current address and contact details.
SECTION 4
Information Disclosure Under the Commonwealth Anti-Money Laundering and Counter-Terrorism Legislation
You are informed that, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), there are provisions for the use of credit reporting information to assist in identity verification. By consenting to this section, you attest that Suncoast Loans has informed you of the following statutory provisions.
Under Section 35A(1), this can include the electronic provision of your name and/or address and/or date of birth, as you may have provided to us, to a credit reporting body. This information can and frequently has to be provided to credit reporting bodies by Suncoast Loans for a matching process entailing comparison with personal information about you they already have on their files.
If there is no satisfactory match found and/or the level of verification which we must seek, as part of both our AML/CTF responsibilities and our mandatory credit unsuitability/suitability assessment process under the National Consumer Credit Protection Act 2009 and associated Regulations, is not achieved, we must give you the opportunity to verify your identity by alternative means.
In these circumstances, if you choose not to attempt to verify your identity by contacting the credit reporting body yourself, or by alternative means, or your contact with the credit reporting body is unsuccessful, or we determine that the alternative has failed to provide adequate identity verification, we cannot provide you with a loan. To do so would threaten Suncoast Loans’ Australian Credit Licence.
Please note that we have to keep a record for 7 years regarding which credit reporting body we contacted, the personal information we provided and the assessment with which we were supplied.
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 (TMD)
A Target Market Determination (TMD) is a document that describes the type of consumers a financial product has been designed for (the target market), and any conditions or restrictions on how the product may be distributed.
The TMD also outlines the circumstances in which Suncoast Loans may review the Target Market Determination to ensure the product continues to be appropriate for consumers.
A TMD is not a full summary of the product terms and conditions and does not take into account your personal objectives, financial situation or needs.
Suncoast Loans will always undertake an individual responsible lending assessment before approving any loan.
You should read the Target Market Determination together with the loan contract and other relevant documents before deciding whether the product is suitable for you.
Target Market Determination-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.
Responsible Lending Assessment
Suncoast Loans does not rely solely on this Target Market Determination when assessing suitability and will always conduct an individual responsible lending assessment prior to approving any loan.
Approval of any loan remains subject to Suncoast Loans’ responsible lending obligations under the National Consumer Credit Protection Act 2009.
The Target Market Determination does not replace Suncoast Loans’ responsible lending obligations. Meeting the Target Market Determination alone does not mean a loan will be approved.
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.
Product suitability and approval discretion
Being within the Target Market does not guarantee approval. Suncoast Loans retains discretion to decline any application where the loan is assessed as unsuitable, unaffordable, or inconsistent with responsible lending obligations, even where the consumer falls within the Target Market.
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;
- Australian citizens, permanent residents or eligible Visa holders who meet Suncoast Loans’ responsible lending and product suitability criteria
- who satisfy Credit Act responsible lending requirements as to availability, content and verifiable financial information.
Where a loan is provided to a Visa holder, Suncoast Loans will ensure the loan term and structure remains appropriate having regard to the consumer’s residency status and repayment capacity.
Consumers who are excluded from the Target Market
Consumers who are:
- 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 with no satisfactory explanation
- Present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances.
- Are under the age of 18.
- Consumers who are not Australian citizens, permanent residents or eligible Visa holders
- Are unable to provide the financial information required for verification during the application process; and
- Are unable to understand the nature and obligations of a credit contract unless an authorised carer, guardian or trustee is involved in the application process.
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.
- Trailer Purchases
- Car/vehicle purchases.
- 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;
- reasonable management of discretionary spending including gambling and lifestyle expenses
- 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.
Where a consumer is a Visa holder, Suncoast Loans may consider additional factors including:
- Visa Type
- Visa expiry date
- Employment stability
- Time remaining in Australia relative to the loan term
- Ability to meet repayments if residency circumstances change.
Suncoast Loans may decline applications where these factors indicate unacceptable risk.
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.
Financial Hardship Awareness
Suncoast Loans recognises that a consumer’s financial circumstances may change after a loan is entered into. Customers experiencing financial difficulty are encouraged to contact Suncoast Loans as soon as possible so assistance options can be discussed in accordance with hardship obligations under the National Consumer Credit Protection Act.
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 compliant 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
Suncoast Loans will review this Target Market Determination:
• at least every two years from the date of the previous review;
• where a review trigger occurs;
• where internal monitoring identifies potential inconsistencies between the product and the Target Market; or
• following material changes to lending policy, product design or regulatory obligations.
Where a review trigger occurs, Suncoast Loans will review the TMD within 10 business days of the matter being identified and implement any required changes as soon as reasonably practicable to ensure the product remains appropriate for the Target Market.
Where required, Suncoast Loans will notify ASIC of any Significant Dealing as soon as practicable and no later than 10 business days after becoming aware of the significant dealing, in accordance with DDO reporting requirements.
Product monitoring
Suncoast Loans monitors product performance on an ongoing basis, including arrears levels, hardship applications, complaints, defaults and customer outcomes, to ensure the product continues to meet the needs, objectives and financial situation of the Target Market.
Where adverse trends are identified, Suncoast Loans may conduct an earlier review of this Target Market Determination.
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 or visa Holders
- 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 10th March 2026 and applies only to products obtained on or after 10th March 2026.
Target Market Determination-All Other Contracts (AOCC) – 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 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.
Responsible Lending Assessment
Suncoast Loans does not rely solely on this Target Market Determination when assessing suitability and will always conduct an individual responsible lending assessment prior to approving any loan.
Approval of any loan remains subject to Suncoast Loans’ responsible lending obligations under the National Consumer Credit Protection Act 2009.
The Target Market Determination does not replace Suncoast Loans’ responsible lending obligations.
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.
Meeting the Target Market Determination alone does not mean a loan will be approved.
Being within the Target Market does not guarantee approval. Suncoast Loans retains discretion to decline any application where the loan is assessed as unsuitable, unaffordable or inconsistent with responsible lending obligations.
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;
- Australian citizens, permanent residents and eligible Visa holders who meet Suncoast Loans’ responsible lending and product suitability criteria
- who satisfy Credit Act responsible lending requirements as to availability, content and verifiable financial information.
Where a loan is provided to a Visa holder, Suncoast Loans will ensure the loan term and structure remains appropriate having regard to the consumer’s residency status and repayment capacity.
Consumers who are excluded from the Target Market
Consumers who are:
- 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 with no satisfactory explanation.
- present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances;
- are under the age of 18;
- Consumers who are not Australian citizens, permanent residents or eligible Visa holders
- are unable to provide the financial information required for verification during the application process; and
- are unable to understand the nature and obligations of a credit contract unless they have an authorised carer, guardian or trustee assisting them during the application and assessment process
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 and involving loans for larger amounts and/or longer periods than a Medium Amount Credit Contract:
- Boat purchases.
- Car/vehicle costs.
- Trailer Purchases
- Car/vehicle purchases.
- 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.
Additional considerations for Visa holders
Where a consumer is a Visa holder, Suncoast Loans may consider additional factors including:
- Visa type
- Visa expiry date
- Employment stability
- Time remaining in Australia relative to the loan term
- Ability to meet repayments if residency circumstances change.
Suncoast Loans may decline applications where these factors indicate unacceptable risk.
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.
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
Suncoast Loans will review this Target Market Determination:
• at least every two years from the date of the previous review;
• where a review trigger occurs;
• where internal monitoring identifies potential inconsistencies between the product and the Target Market; or
• following material changes to lending policy, product design or regulatory obligations.
Where a review trigger occurs, Suncoast Loans will review the TMD within 10 business days of the matter being identified and implement any required changes as soon as reasonably practicable to ensure the product remains appropriate for the Target Market.
Where required, Suncoast Loans will notify ASIC of any Significant Dealing as soon as practicable and no later than 10 business days after becoming aware of the significant dealing, in accordance with DDO reporting requirements.
Product performance monitoring
Suncoast Loans monitors product performance on an ongoing basis including arrears trends, hardship requests, default rates, complaints, variations and customer outcomes to ensure the product continues to align with the Target Market and responsible lending obligations.
Where adverse trends are identified, Suncoast Loans may conduct an earlier review of this Target Market Determination.
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 or Visa Holders
- 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 10th March 2026 and applies only to products obtained on or after 10th March 2026.
Target Market Determination-All Other Contracts (AOCC) - Personal Loans - First and Second Mortgages
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 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.
Responsible Lending Assessment
Suncoast Loans does not rely solely on this Target Market Determination when assessing suitability and will always conduct an individual responsible lending assessment prior to approving any loan.
Approval of any loan remains subject to Suncoast Loans’ responsible lending obligations under the National Consumer Credit Protection Act 2009.
Meeting the Target Market Determination alone does not mean a loan will be approved.
The Target Market Determination does not replace Suncoast Loans’ responsible lending obligations.
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.
Being within the Target Market does not guarantee approval. Suncoast Loans retains discretion to decline any application where the loan is assessed as unsuitable, unaffordable or inconsistent with responsible lending obligations.
Product suitability and approval discretion
Being within the Target Market does not guarantee approval. Suncoast Loans retains discretion to decline any application where the loan is assessed as unsuitable, unaffordable, or inconsistent with responsible lending obligations, even where the consumer falls within the Target Market
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 $100,000.
- 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.
- Australian citizens, permanent residents and eligible Visa holders who meet Suncoast Loans’ responsible lending and product suitability criteria
- who satisfy responsible lending requirements under the National Consumer Credit Protection Act, including provision of verifiable financial information.
Where a loan is provided to a Visa holder, Suncoast Loans will ensure the loan term and structure remains appropriate having regard to the consumer’s residency status and repayment capacity.
Consumers who are excluded from the Target Market
Consumers who are:
- 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 with no satisfactory explanation.
- present with multiple current borrowing activity that indicates an unreasonable level of debt and financial obligation, in all the financial circumstances;
- are under the age of 18;
- not an Australian citizen, permanent resident or eligible Visa Holder
- are unable to provide the financial information required for verification during the application process; and
- are unable to understand the nature and obligations of a credit contract unless they have an authorised carer, guardian or trustee assisting them during the application and assessment process.
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 and involving loans for larger amounts and/or longer periods than a Medium Amount Credit Contract:
- Boat purchases.
- Car/vehicle costs.
- Trailer Purchase.
- Car/vehicle purchases.
- 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.
Additional considerations for Visa holders
Where a consumer is a Visa holder, Suncoast Loans may consider additional factors including:
- Visa type
- Visa expiry date
- employment stability
- time remaining in Australia relative to the loan term
- ability to meet repayments if residency circumstances change.
Suncoast Loans may decline applications where these factors indicate unacceptable risk.
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.
Financial hardship assistance
Suncoast Loans recognises that a consumer’s financial circumstances may change after a loan is entered into. Customers experiencing financial difficulty are encouraged to contact Suncoast Loans as soon as possible so assistance options can be discussed in accordance with hardship obligations under the National Consumer Credit Protection Act.
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
Suncoast Loans will review this Target Market Determination:
• at least every two years from the date of the previous review.
• where a review trigger occurs.
• where internal monitoring identifies potential inconsistencies between the product and the Target Market; or
• following material changes to lending policy, product design or regulatory obligations.
Where a review trigger occurs, Suncoast Loans will review the TMD within 10 business days of the matter being identified and implement any required changes as soon as reasonably practicable to ensure the product remains appropriate for the Target Market.
Where required, Suncoast Loans will notify ASIC of any Significant Dealing as soon as practicable and no later than 10 business days after becoming aware of the significant dealing, in accordance with DDO reporting requirements.
Product monitoring
Suncoast Loans monitors product performance on an ongoing basis, including arrears levels, hardship applications, complaints, defaults and customer outcomes, to ensure the product continues to meet the needs, objectives and financial situation of the Target Market.
Where adverse trends are identified, Suncoast Loans may conduct an earlier review of this Target Market Determination.
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 or visa Holders
- 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 10th March 2026 and applies only to products obtained on or after 10th March 2026.
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.