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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 who meet the following requirements:

  • Must be employed or self-employed (sole trader); and
  • Are between 18 and 65 years of age; and
  • Have a valid Australian driver's license or permit; and
  • Have a permanent residential address in Australia; and
  • Hold an Australian bank account

Customer objectives (purpose of obtaining credit)

The Consumer Secured Asset Loan is designed for individuals who:

  • Want a loan to buy or refinance a new or used motor vehicle or motorcycle* from a motor dealer or private seller
  • Want to own the motor vehicle or motorcycle (rather than lease it)
  • Agree to secure their loan with the financed asset
  • 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

* Certain other vehicles may be considered subject to being an acceptable security under GLA's credit policy which is amended from time to time

Customer needs (credit amount and term)

The Consumer Secured Asset Loan is designed for individuals who:

  • Want to borrow between $6,000 to $45,000^
  • Want a fixed interest rate loan
  • Want to repay the loan for a term ranging between 3 to 5 years
  • Want the certainty of repaying the borrowings through an agreed schedule of regular payments

Customer financial situation

  • Must be employed or self-employed (sole trader)
  • Must have an acceptable source of income
  • May have had within the last 90 days some missed repayments
  • May have within the last 90 days overdrawn their bank account
  • May have an imperfect credit file history
  • Must meet our credit assessment criteria which includes demonstrating the capacity to make the required payments under the contract without substantial hardship
  • May receive part of their income via payments under the Social Security Act; or
  • May be regular users of alternative financial products to supplement their income (such as Small Amount Credit Contracts, Buy Now Pay Later or Early Wage Access products)

The Consumer Secured Asset Loan is not designed for:

  • Customers whose income consists solely of payments under the Social Security Act
  • Customers with a current personal insolvency agreement ("Part X" arrangement)
  • The Consumer Secured Asset Loan cannot be used by a company or trust

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

Product Features

The Consumer Secured Asset Loan has the following key features:

  • Is available through online channels or through introducers such as brokers and/or motor dealers
  • Minimum loan amount of $6,000
  • Maximum loan amount of up to $45,000, subject to customer's credit risk profile
  • Minimum repayment term of 36 months (3 years)
  • Maximum repayment term of up to 60 months (5 years)
  • Interest rate ranges between 12.99% to 27.99% per annum, based on customer's credit risk profile and vehicle characteristics
  • Interest rate is fixed which means the repayments remain fixed for the duration of the loan
  • The loan is secured with the financed asset
  • Maximum vehicle age allowed is 12 years (at the start of loan term)
  • The loan can be used for any one of the listed customer's objectives
  • Early termination fees apply if loan is repaid in full before the agreed term
  • Upfront Application and Lender fees apply
  • Other fees and charges apply
Distribution Considerations

Conditions

Loans can be distributed directly by GLA or related party entities, or by motor dealers and accredited third-party brokers/introducers.

To ensure this product is likely to be provided to customers in the target market, the following conditions and restrictions apply;

All 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.

Our Consumer Secured Asset Loan can only be provided to customers after the process below has been completed:

  • An application must be received declaring the consumers needs and objectives, their sources of income and their essential living expenses
  • Bank statements must be provided covering the preceding 90 days for a suitability check to be undertaken and to verify their declared income and expenses
  • Consumers receiving government benefits must provide the income statement issued by Service Australia (Centrelink Income Statement)
  • Consumers must pass our ID verification process
  • A credit enquiry of the consumers credit file history is conducted to further verify their financial situation
  • Consumers must meet our credit assessment criteria which includes demonstrating the capacity to make the required payments under the contract without substantial hardship
  • The loan affordability assessment is only conducted by authorised staff

How these conditions create alignment to the target market

These distribution conditions are essential to ensure that:

  • GLA's reasonable steps have been followed;
  • Existing controls such as responsible lending are applied;
  • All distributors are informed of 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 increase (as referenced by an increase that is beyond normal historical patterns) in number of complaints, indicating that the product did not meet the customer’s objectives, needs or financial situation;
  • Significant increase (as referenced by an increase that is beyond normal historical patterns) in the number of hardship applications within 6 weeks of the loan being issued;
  • Significant increase (as referenced by an increase that is beyond normal historical patterns) in the number of missed repayments within 6 weeks of the loan being issued;
  • A systemic issue identified and reported by the Australian Financial Complaints Authority (AFCA);
  • 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: 27th March 2024
Next Reviewed Date: 31st March 2025