1. About this document
This Target Market Determination is made by PayAngel Pty Ltd under Part 7.8A of the Corporations Act 2001. It describes the class of consumers for whom the product has been designed, the conditions applying to its distribution, and the events and time periods that will cause PayAngel to review it.
This document is not a summary of the product’s terms and conditions and is not financial advice. It does not take into account any individual’s objectives, financial situation or needs. Consumers should read the product’s terms and conditions before deciding to use it.
2. The product to which this determination applies
International money transfer — a transfer of funds instructed by a customer in Australia and paid to a beneficiary in an approved destination country.
Key attributes
- The customer instructs each transfer individually, specifying the amount, the destination country and the beneficiary.
- Transfers are funded in Australian dollars from a payment card or bank account held in the customer’s own name.
- The exchange rate applied is the rate quoted to the customer at the time the transfer is confirmed.
- Fees, and the exchange rate that will apply, are disclosed to the customer before the transfer is confirmed.
- Transfer limits apply. Limits are set out in the product’s terms and conditions.
- Funds are made available to the beneficiary in local currency by a payout method available in the destination country.
- Approved destination countries at the date of this determination are Ethiopia, Ghana, India, Kenya, Nigeria, the Philippines, South Africa and the United Kingdom.
3. Target market
The product has been designed for individuals who:
- are aged 18 or over;
- reside in Australia and hold an Australian residential address;
- can be identified and verified by PayAngel from the information and documents they provide;
- are sending their own funds for personal, family or household purposes;
- are sending to a beneficiary located in an approved destination country;
- fund each transfer from a payment card or bank account held in their own name; and
- want each transfer priced and executed at the time they instruct it.
4. Likely objectives, financial situation and needs
Objectives. To send a specified sum of money to a person or organisation overseas — on a single occasion, or repeatedly where each transfer is separately instructed — typically to support family, or to meet a personal obligation such as school fees, medical costs or household bills.
Financial situation. Has access to funds in an Australian bank account or on an Australian payment card sufficient to cover the amount being sent together with any applicable fee, and does not need to borrow in order to make the transfer.
Needs. A transfer priced and confirmed at the point of instruction; the total cost disclosed before confirming; delivery to the beneficiary through a payout method available in the destination country; and access to the service online without attending a branch or agent.
5. Consumers outside the target market
The product has not been designed for consumers who:
- do not reside in Australia;
- are sending funds for business, commercial or investment purposes, or on behalf of a business, association or not-for-profit organisation;
- are sending funds that belong to another person, or are acting at another person’s direction;
- need to place funds with the provider and hold them, rather than send them;
- need to fund a transfer on credit or on deferred payment terms;
- need an exchange rate fixed in advance of instructing a transfer, or protection against exchange rate movement;
- need to fund a transfer in cash; or
- are sending to a country that is not an approved destination country.
6. How the product is distributed
PayAngel Pty Ltd is both the issuer and the only distributor of the product. It is offered directly to consumers through the PayAngel mobile application and website. It is not offered through agents, franchisees, brokers, referrers or any other third-party distributor.
Distribution conditions
- The product is offered only to consumers located in Australia.
- A consumer must complete PayAngel’s identification and verification process before their first transfer.
- A consumer must confirm, before a transfer proceeds, the purpose of the transfer and that they are sending their own funds.
- Transfers are accepted only to approved destination countries.
- Transfers are funded only from a payment card or bank account held in the consumer’s own name.
- Marketing is conducted only through channels operated or approved by PayAngel. Marketing partners must not accept funds from consumers and must not perform any part of the onboarding process.
- Comparative promotional claims are made only where PayAngel holds evidence substantiating them.
Why these conditions are appropriate
The conditions confine distribution to consumers located in Australia who are sending their own funds for their own purposes, to destinations PayAngel supports, through a channel PayAngel operates end to end. Because there is no third-party distribution, PayAngel controls every point at which a consumer can acquire the product. On that basis PayAngel considers it likely that consumers who acquire the product will be in the target market described in section 3.
7. Information PayAngel will monitor
As PayAngel is the only distributor of the product, no third party is required to report to it. PayAngel will record and review:
- complaints about the product — the number received and their substance — reviewed every six months;
- any dealing in the product that is not consistent with this determination, recorded as soon as practicable and in any event within 10 business days of PayAngel becoming aware of it;
- the number and value of transfers, by destination country;
- applications that do not complete identification and verification;
- transfers held, stopped, cancelled or refunded, and the reason; and
- consumer feedback indicating the product did not meet the consumer’s needs.
8. Review triggers
PayAngel will review this determination on becoming aware of any of the following:
- a material change to the product, to its fees, or to its transfer limits;
- the addition or removal of an approved destination country;
- a material change to how the product is funded or how funds are delivered to beneficiaries;
- a significant dealing in the product that is not consistent with this determination;
- a complaint, or a pattern of complaints, indicating that the target market described in this determination is not appropriate, or that the product is not performing as described;
- a determination by PayAngel that the design or distribution of the product has resulted in consumers outside the target market acquiring it;
- the exercise by ASIC of a power in relation to the product, including a stop order or a request for information;
- a change in law, regulatory guidance or an applicable industry code affecting the product or this determination; or
- a material failure in a system or arrangement on which PayAngel relies to deliver the product.
9. Review periods
Initial review: within six months of the effective date of this determination.
Periodic review: at least every 12 months from the date of the last review.
On a review trigger: within 10 business days of PayAngel becoming aware of the trigger.
10. Contact and complaints
If you have a complaint about the product, email PayAngel at complaints.au@payangel.com or write to 60 Martin Place, Sydney NSW 2000, Australia [TO CONFIRM]. PayAngel will acknowledge your complaint and respond to it in accordance with its complaints policy.
Open items to be completed before this determination is made and published:
The date of the determination and the date it takes effect; and confirmation of the postal address in section 10.
