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Consumer Secured Asset Loan
Target Market Determination

Product Name Consumer Secured Asset Loan
Product Issuer

Green Light Auto Group Pty Limited trading as Green Light Auto Finance. Australian Credit License 392 740, ABN 39 131 507 474 (“GLA”)

Product Class

Asset Loan

Purpose

This document is a prescribed document under the Corporations Act 2001 (Cth) to describe the class of person (the target market) for whom the product was designed. It is not advice.

Please contact us directly on 1300 081 488 or compliance@greenlightauto.finance if you have any questions related to our Target Market Determination page at greenlightauto.finance/tmd

Target Market

Target Market

The Consumer Secured Asset Loan is designed for individual or joint borrowers aged between 18 and 65 years who meet GLA’s credit policy, and who need from $6,000 to $45,000 for 3-5 years to purchase a motor vehicle or motorcycle to benefit the borrower(s). The borrower(s) may (optionally) want the flexibility to borrow more than the vehicle’s value to pay for the associated vehicle and fees such as but not limited to stamp duty, registration, origination costs, insurance, warranty and roadside without the need for a deposit.

Customer needs, objectives and financial situation

The Consumer Secured Asset Loan is designed for individuals who:

  • need to borrow between $6,000 to $45,000*;
  • need a fixed interest rate loan for between 3 to 5 years;
  • accept that since the interest rate is fixed, if they repay earlier, an early termination fee may be payable;
  • need a loan to buy a motor vehicle or motorcycle (certain other vehicles may be considered subject to being an acceptable security under GLA’s credit policy which is amended from time to time) from a motor dealer or private seller;
  • want to own the motor vehicle or motorcycle (rather than lease the motor vehicle or motorcycle);
  • agree to secure their loan with the financed asset in order access the product;
  • may optionally want to share the loan with a partner or spouse;
  • may optionally want to borrow more than the vehicle’s value to pay for associated vehicle and fees such as but not limited to stamp duty, registration, origination costs, insurance and warranty without the need for a deposit;
  • may optionally want to use a lender who offers credit risk-based pricing so that they can access a relatively better rate for having a better quality credit risk profile;
  • have an acceptable source of income*;
  • have a valid Australian driver’s licence or permit;
  • is an Australian citizen, permanent resident with a fixed Australian address; and
  • hold an Australian bank account;

 

*All loans are subject to GLA’s credit policy and responsible lending suitability assessment.

The Consumer Secured Asset Loan is not designed for persons seeking a loan, where the borrower(s) income consists solely of payments under the Social Security Act.

The Consumer Secured Asset Loan cannot be used by a business or trust.

Distribution Considerations

Conditions

Distributors must be an Australian Credit Licence (ACL) holder, an ACL representative, or authorised to engage in credit activity under a valid National Consumer Credit Act 2009 exemption or defence. They must comply with all existing laws in relation to credit assistance, and Design and Distribution Obligations applicable to their retail product distribution conduct.

Distributors must follow any reasonable DDO guidance issued by GLA from time to time, including in relation to complaint, significant dealing and TMD reporting.

All distributors are required to be accredited with GLA and operate in accordance with any agreements and or processes. All loan applications must be submitted using the systems provided by GLA.

How these conditions create alignment to the target market

These distribution conditions are essential to ensure that:

  • existing controls such as responsible lending are applied;
  • all distributors understand their obligations to ensure that each customer is within the product's target market before engaging in retail product distribution conduct; and
  • reporting and monitoring data can be collected efficiently.

 

Review Triggers

The following are review triggers that require the Issuer to review this TMD within 10 business days:

  • significant complaints, or significant numbers of complaints, indicating that the product did not meet the customer’s objectives, needs or financial situation;
  • significant numbers of hardship applications within 6 weeks of the loan being issued;
  • significant numbers of EDR negative findings indicating that the product didn’t meet the customer’s objectives, needs or financial situation;
  • material changes to the laws applicable to this product, the product features or terms or the distribution method; and
  • significant dealings outside target market, unless isolated to the conduct of a single distributor.

 

When subsequent reviews must occur

A maximum of 12 months from the previous review date.

Reporting periods for distributors to report complaints

The following information must be reported to GLA using standard reporting procedures:

 

Information about product complaints and distribution complaints

  • within 2 business days of receiving a complaint

Significant Dealings

  • within 2 business days following the identification of a potential significant dealing e.g. dealings that are potentially outside of this defined target market.

All other reporting information

  • Three months, unless reported earlier
Information that must be reported

Distributors must report the following to GLA using standard reporting procedures:

  • complaint information (product complaints and other distribution complaints);
  • potential significant dealings.

 

All other indicia are monitored directly by GLA using data collected within its origination systems.

Issue Date: 5th October 2021
Last Review Date: 31st January 2024
Next Reviewed Date: 31st March 2024