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Zeller Mastercard Target Market Determination

 

Introduction

EML Payment Solutions Limited (referred to as EML, us, our or we) are a product issuer and we issue non-cash payment facilities in the form of prepaid cards through the payment schemes (such as Mastercard and Visa). We are authorised and regulated by the Australian Securities and Investments Commission (ASIC), with licence number 404131 and registered office located at Level 12, 333 Ann Street Brisbane QLD 4000.

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 prepaid cards to which the DD Obligations apply.

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

Zeller prepaid Mastercard

A non-cash payment facility in the form of a reloadable prepaid Mastercard issued to a Consumer to purchase eligible goods and services where Mastercard is accepted.

Product Options

Zeller Mastercard

Issuer

EML Payment Solutions Limited

Start Date

5 October 2021

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 prepaid Mastercard provided with the Zeller payment terminal, which can be directly loaded with funds acquired from the sale of their goods and services in order to purchase eligible goods and services where Mastercard is accepted.

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 to preload the Card and to pay any associated fees.

 

Product Description

A reloadable prepaid Mastercard with the following key attributes:

  1. ability to purchase eligible goods and services electronically where Mastercard is accepted using value loaded onto the Card;

  2. ability to load the Card to a digital wallet, allowing Cardholders to make purchases with eligible mobile devices;

  3. ability to transfer funds from the Card to an external bank account; and

  4. a requirement to preload the Card and pay fees (including foreign exchange fees).

In general, it is only available to Consumers that who 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 prepaid Mastercard.

 

Appropriateness

EML 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 EML approved communication channels (including telephone, email and social media).

    This condition is 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):

  1. only to Consumers who acquire the Zeller payment terminal as a means to acquire funds from the sale of their goods and services; and

  2. only through:

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

EML, 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 EML determines a material event or circumstance has occurred in relation to the following:

Material Complaints

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

Product Performance

evidence, as determined by EML, 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 EML 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 EML

Information reasonably requested by EML.

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

Reporting Period:

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

 

Other information

EML reserves the right to amend the TMD at any time if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance or for any reason EML considers as a proper reason to amend the TMD.