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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

Product

Enhanced Zeller Payment Services

A non-cash payment facility comprising a debit Mastercard issued to a Consumer to purchase eligible goods and services where Mastercard is accepted, Direct Entry Payments and New Payments Platform Payments 

Issuer

Zeller Australia Pty Ltd

Start Date

15 November 2022

 

 

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:

  1. A reloadable debit Mastercard with the following key attributes:
    1. ability to purchase eligible goods and services electronically where Mastercard is accepted;
    2. ability to load the Card to a digital wallet, allowing Cardholders to make purchases with eligible mobile devices; and
    3. ability to transfer funds from the Card to an external bank account. 

 

  1. Direct Entry Payment functionality, enabling payments to third party bank accounts by way of electronic transfer; 
  2. 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:

  1. 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
  2. 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:

  1. the distributor’s digital platform (such as their website or mobile app) and other Zeller approved third party digital platforms; and
  2. 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:

Material Complaints

material complaints (in number or significance) received by Zeller or the distributor in relation to the terms of this product and / or the distribution conduct.

Product Performance

evidence, as determined by Zeller, of the performance of the product, in practice, that may suggest that the product is not appropriate for the target market.

Distributor Feedback

reporting from the distributor, or consistent feedback from the distributor on the target market which suggests that this TMD may no longer be appropriate.

Substantial Product Change

a substantial change to the product that is likely to result in this TMD no longer being appropriate for the target market.

Significant Dealing

a material pattern of dealings in the product or of distributor conduct that is not consistent with this TMD.

Notification from ASIC

a notification from ASIC requiring immediate cessation of product distribution or particular conduct in relation to the product.

Review Period

the first review, and each ongoing review, must be completed within each consecutive 12 month periods from the Start Date.

 

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:

Complaint Information

Information about complaints received in relation to the product during the reporting period, and if complaints were received, a description of the number of complaints and the nature of the complaints received and other complaint information set out in paragraph RG 271.182 of Regulatory Guide 271 Internal dispute resolution.

Distributor Feedback

Information discovered or held by the distributor that suggests that this TMD may no longer be appropriate.

Significant Dealing

Information about any significant dealing in the product that is not consistent with the target market determination of which the distributor becomes aware.


The distributor must provide the information as soon as practicable, or in any event, within 10 business days after becoming aware of the significant dealing.

Information Requested by Zeller

Information reasonably requested by Zeller.


The distributor must provide the information as soon as practicable and no later than the date specified by Zeller.

Reporting Period:

The reporting period for this TMD is every 6 months commencing from the Start Date.

 

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.