Enhanced Zeller Payment Services Target Market Determination
Introduction
Zeller Australia Pty Ltd ACN 649 001 383 (referred to as Zeller, us, our or we) are a product issuer and we issue non-cash payment facilities in the form of the Enhanced Zeller Payment Services (EZPS). We are authorised and regulated by the Australian Securities and Investments Commission (ASIC), with licence number 534281.
The design and distribution obligations set out in Part 7.8A of the Corporations Act 2001 (DD Obligations) apply to the issue and distribution of non-cash payment facilities to retail clients (Consumers). Non-cash payment products are products that allow Consumers to make payments, otherwise than through the physical delivery of Australian or foreign currency (e.g. prepaid cards).
The purpose of this target market determination (TMD) is to describe the target market of Consumers for our EZPS to which the DD Obligations apply. Terms that are used in this TMD and are defined in the Zeller Terms of Service have the meaning given to them in the Zeller Terms of Service.
If you are a retail client, you should refer to the relevant Product Disclosure Statement (PDS) before deciding whether to acquire or continue to hold the relevant product. You can get a copy of the relevant PDS from the website of the distributor of the product subject to this TMD.
You should not base any decision to transact on the contents of this TMD.
Product Information
Target Market
Class of Consumer
Likely objectives and needs
A Consumer who operates a business which uses a Zeller payment terminal to accept payment from customers for the sale of their goods and services and who may opt to use the EZPS to access funds acquired from the sale of their goods and services in order to purchase eligible goods and services.
Likely financial situation
A Consumer who has an active Zeller terminal and who has Australian dollars acquired from the sale of their goods and services using the Zeller terminal, which they wish to use to make payments using the EZPS and to pay any associated fees.
Product Description
A set of payment functionalities including:
A reloadable debit Mastercard with the following key attributes:
ability to purchase eligible goods and services electronically where Mastercard is accepted;
ability to load the Card to a digital wallet, allowing Cardholders to make purchases with eligible mobile devices; and
ability to transfer funds from the Card to an external bank account.
Direct Entry Payment functionality, enabling payments to third party bank accounts by way of electronic transfer;
New Payments Platform (NPP) payment functionality, enabling payments to third party bank accounts through the NPP
In general, it is only available to Consumers that have purchased a Zeller terminal as a means to acquire payments from customers of their business and who have activated and operate both the Zeller terminal and the EZPS.
Separately to the EZPS, Zeller also provides access to the Zeller Account which enables Consumers to receive payments through Direct Entry Payment functionality and NPP payment functionality.
The available balance in the EZPS is held in a client segregated monies account (Zeller Account) maintained by Zeller with an Australian authorised deposit-taking institution (ADI). Cuscal Limited ACN 087 822 455 (Cuscal) is the ADI where the Zeller Account is held and the Holder of Stored Value (as defined in the Payment Systems (Regulation) Act 1998 (Cth)) for the EZPS. Cuscal provides transaction processing and settlement services to EZPS customers in relation to the Zeller Account. Cuscal is not providing accounts to EZPS customers and does not have any contractual relationship with EZPS customers.
Zeller is responsible for the settlement of transactions using the Card but may outsource these functions to other service providers. Zeller holds the Available Balance on trust for its EZPS customers, in accordance with the PDS and the Terms and Conditions.
Appropriateness
Zeller considers that the product (including its key attributes) is likely to be consistent with the likely objectives, financial situation and needs of Consumers as it provides the means for Consumers to access funds acquired from the sale of their goods and services without the need to transfer funds to a Consumer’s bank account.
Distribution Conditions
Marketing and Promotion
A distributor must only market and promote the product through:
advertising through media (including social media), physical marketing materials (such as banners, brochures or flyers) and any other marketing material available to the general public; and
any other Zeller approved communication channels (including telephone, email and social media).
A distributor must not make any statement, implication or representation that contradicts, or is inconsistent with, the concept that Zeller holds the Available Balance on trust for its EZPS customers.
These conditions are appropriate as the target market for the Zeller terminal to which the product relates and is distributed in conjunction with is wide.
Retail Product Distribution Conduct
A distributor must only engage in retail product distribution conduct (other than general advice) through:
the distributor’s digital platform (such as their website or mobile app) and other Zeller approved third party digital platforms; and
any other Zeller approved communication channels (including telephone, email and social media).
This condition is appropriate as the target market for the Zeller terminal is wide and it is the most appropriate (and only) method for Consumers within the target market to obtain the product. Such conduct poses limited risk to Consumers.
Review Triggers
Zeller, and the distributor of this product, must cease retail product distribution conduct in respect of this product as soon as practicable, but no later than 10 business days after Zeller determines a material event or circumstance has occurred in relation to the following:
Reporting Information
A distributor that engages in retail product distribution conduct in respect of this product must provide the following information in writing to Zeller within 10 business days after the end of each reporting period unless indicated otherwise below:
Other information
Zeller reserves the right to amend the TMD at any time if such an amendment is needed as a result of any changes to the law or regulations, regulatory guidance or for any reason Zeller considers as a proper reason to amend the TMD.