Product Design & Distribution Policy¶
| Code | CRE-008 |
| Domain | Credit Risk |
| Owner | Head of Product |
| Status | Draft |
| Applicability | Platform |
| Jurisdiction | AU |
| Business domain | BD04 |
| Review date | 2027-03-25 |
Regulations: ASIC RG 274¶
Purpose¶
Govern Target Market Determinations (TMDs) and distribution conditions for credit and lending products under the AU Design and Distribution Obligations (DDO) framework (ASIC RG 274), and align NZ product suitability obligations under the FMC Act. Ensures credit products are designed for and distributed to the customer segments for whom they are appropriate.
Scope¶
All credit and lending products offered to retail customers in AU (subject to the DDO regime) and NZ (subject to FMC Act fair conduct obligations). Covers the preparation, review, and distribution of TMDs, product outcome monitoring, and distribution channel compliance.
Policy statements¶
A Target Market Determination (TMD) SHALL be prepared for each credit or lending product before it is offered to retail customers in AU. The TMD SHALL specify: the class of consumers for whom the product is likely to be consistent with their likely objectives, financial situation, and needs; the distribution conditions including channels and types of distributors; and the review triggers.
Distribution of any AU retail credit product SHALL not occur through channels or to customer segments outside the TMD without a prior TMD update that expands the target market to include the relevant channel or segment.
Distributors of the platform's credit products SHALL be made aware of the TMD conditions applicable to each product. Distributor compliance with TMD conditions SHALL be monitored at least quarterly.
Outcome monitoring data — including complaints, defaults, hardship applications, and early repayment rates by product and customer segment — SHALL be collected and reviewed at least quarterly by the Head of Product against TMD appropriateness.
A TMD review SHALL be triggered where: a review trigger specified in the TMD is met; outcome monitoring data indicates a material proportion of customers are experiencing outcomes inconsistent with the product's target market; or a significant product or regulatory change occurs that may affect target market appropriateness.
Where a TMD review concludes that distribution outside the target market is occurring and causing consumer harm, distribution SHALL be suspended until the TMD is updated or distribution controls are corrected.
All TMDs SHALL be published on the platform's public website and lodged with ASIC on ASIC's design and distribution obligations register within the timeframe required.
For NZ operations, product design and distribution reviews SHALL assess product suitability against the fair conduct programme obligations under CON-001 and the FMC Act obligations under CON-004.
All TMD versions, distribution condition records, outcome monitoring results, and review records SHALL be retained for 7 years.
Satisfying modules¶
| Module | Name | Mode | Description |
|---|---|---|---|
| MOD-155 | Target Market Determination (AU DDO) | GATE |
No AU retail product can be distributed without an approved, current TMD on file — distribution is blocked at the product configuration layer; no bypass path. |
Part of Credit Risk · Governance overview
Compiled 2026-05-22 from source/entities/policies/CRE-008.yaml