Savings Account Target Market Determination

Last Updated 23 November, 2021

Issuer

Alex Bank Pty Ltd ABN 13 627 244 848, Australian Financial Services Licence and Australian Credit Licence 510805 (Alex, We, Us or Our).

1. Target Market

  1. This Target Market Determination (TMD) sets out the target market for our Savings Account product.
  2. Our product is 100% digital involving a simple online application process.
  3. The key features of this product include a variable interest rate and no monthly fees.[1]
  4. This product will be available via invitation only to family and friends of Alex staff. However, we will have a public waitlist available for other customers.
  5. Customers must satisfy the following criteria to be eligible to apply for this product:
    1. Be a person over 18 years of age at the date of application;
    2. Be an Australian Citizen or Australian Permanent Resident; and
    3. Be residing in Australia at the time of the application.
  6. This product is not suitable for those who are seeking a fixed interest rate, additional features (i.e. overdraft facility) or a joint savings account.
  7. The Alex Savings Account product is subject to our Savings Terms and Conditions.

2. Distribution Conditions

  1. We have placed conditions and restrictions on the distribution of the product to ensure it is distributed to customers in the target market.[2]
  2. Currently, this product will be distributed by invitation only.
  3. If we become aware that the distribution conditions are inadequate, where for example, significant distribution is occurring outside the target market, we will:
    1. amend the TMD to set out additional distribution conditions to ensure that such event does not occur; or
    2. cease distribution of the product.[3]

3. Review Triggers

  1. There may be events and circumstances (called ‘review triggers’) that would reasonably suggest that this TMD is no longer appropriate such as: [4]
    1. invitations are made to customers from outside the target market;
    2. we make a material change to the product;
    3. we introduce promotional features that materially changes the product;
    4. we receive a significant number of Risk Appetite Statement breaches;
    5. we receive a significant number of negative reviews via platforms such as Google, Facebook and Product Review;
    6. internal complaints or notice of complaints made to Australian Financial Complaints Authority;[5] and
    7. the nature of complaints and complaint trends.[6]
  2. We will review this TMD within 10 business days if we know or reasonably know, that a review trigger has occurred.[7]

4. Review Periods

  1. We will review this TMD on 5 April 2022 to ensure it remains appropriate. Subsequent periodic reviews will occur annually.[8]
  2. We will also review this TMD in response to any review triggers or other events or circumstances that would reasonably suggest that this TMD is no longer appropriate[9]
  3. Where we become aware of information that would reasonably suggest that this TMD is no longer appropriate, we will stop issuing the product until we have had the chance to review the product along with this TMD.[10]
  4. We will notify the Australian Securities and Investments Commission within 10 business days of us becoming aware of a significant dealing in the product that is not consistent with this TMD.[11]
  5. We will integrate the review process into our product governance arrangements, and controls will be put in place to ensure that meaningful reviews take place.[12] Possible outcomes from the review process include:
    1. no change to the way the product is distributed;[13]
    2. changing the product design, target market or distribution;[14] or
    3. ceasing to distribute the product.[15]

5. Distribution Information Reporting Requirements

  1. We understand complaints, events of defaults and general feedback about the product are useful indicators of whether this TMD is still appropriate.[16]
  1. RG 274.76 and RG 274.68(b) of the Product Design and Distribution Obligations.
  2. RG 274.96 of the Product Design and Distribution Obligations; Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 s 994B(5)(c).
  3. RG 274.99 of the Product Design and Distribution Obligations.
  4. RG 274.102 of the Product Design and Distribution Obligations; Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 s 994B(5)(d).
  5. RG 274.104(c) of the Product Design and Distribution Obligations.
  6. Derived from RG 274.107 (Example 6) of the Product Design and Distribution Obligations.
  7. Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 s 994C(3).
  8. RG 274.108 of the Product Design and Distribution Obligations.
  9. RG 274.148 of the Product Design and Distribution Obligations.
  10. RG 274.153 of the Product Design and Distribution Obligations.
  11. RG 274.157 of the Product Design and Distribution Obligations; Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019 s 994F(6); RG 274.159 contains the relevant factors that will assist Alex to determine whether a significant dealing has occurred.
  12. RG 274.150 of the Product Design and Distribution Obligations.
  13. RG 274.150(a) of the Product Design and Distribution Obligations.
  14. RG 274.150(b) of the Product Design and Distribution Obligations.
  15. RG 274.150(c) of the Product Design and Distribution Obligations.
  16. RG 274.117 of the Product Design and Distribution Obligations.