Target Market Determination
Freedom Lend Variable Offset SMSF
SMSF – Investment Variable
Columbus Capital Pty Ltd ACN 119 531 252, Australian Financial Services Licence and Australian Credit Licence 337303 (Columbus)
5 October 2021
About the TMD
This Target Market Determination (TMD) document is not intended to provide financial advice. Please refer to our Terms and Conditions and Credit Guide before deciding product suitability. Our product terms and conditions will be provided to you upon request.
This TMD aims to provide an understanding of the class of customers we have designed this product for, being the target market. When considering the target market, we focused on our customers’ objectives, financial situation, and needs within this class of people we believe this product to be suitable.
• Description of target market
The features of this product have been assessed as meeting the likely objectives, financial situation and needs of consumers who:
- Trustee of a Self-Managed Super Fund;
- The SMSF Trustee must hold a beneficial interest in the security property and must have a right to acquire the property from the Property Trustee and is permitted to borrow in accordance with all relevant legislative requirements and any associated regulations; and
- The Property Trustee, which holds the legal interest in the security property on trust for the SMSF, must meet all relevant legislative requirements and any associated regulations.
- require a loan to purchase or refinance an investment property as part of a Self Managed Super Fund (SMSF);
- require the flexibility of a variable interest rate;
- require the ability to make additional extra repayments without penalty; and
- want an offset account;
- want the option of either principal and interest or interest only repayments.
- satisfy our eligibility criteria;
Although variable interest rates fluctuate, the product meets the likely objectives, financial situation and needs of consumers in the target market because it allows them to deposit SMSF funds into an offset account and/or make additional payments directly into the loan to reduce the amount of interest payable whilst maintaining the flexibility of transferring funds from the Offset account back to the SMSF Cash Management Account. This product also allows consumers to select interest only or principal and interest repayments to reduce their overall debt and build equity.
• Classes of consumers for who the product may not be suitable
This product may not be suitable for consumers who:
- do not meet the eligibility requirements;
- are seeking the certainty of fixed repayments over the term of the loan; or
- are looking to construct a property; or
• Description of the Product, including key attributes
- Variable interest rate;
- Repayment options:
- principle and interest; or
- interest only
- Minimum loan size: $50,000
- Maximum Loan Size: $2,000,000 (subject to LVR and postcode policy)
- Maximum LVR: 80%
- Application fee is payable
- Settlement fee is payable
- Valuation fee is payable
- Solicitors fee is payable
- Ongoing fee is payable
Distribution Conditions/ Restrictions
The following distribution channels and conditions have been assessed as being appropriate to direct the distribution of the product to the target market:
- By phone
- In person (e.g. branch, agency, or premises visit)
- Third party – Accredited mortgage brokers subject to Best Interests Duty (BID)
The distribution channels and conditions are appropriate because:
- the product has a wide target market;
- our staff have the necessary training, knowledge and accreditation (if required) to assess whether the consumer is within the target market. All of our staff must continually satisfy annual compliance reviews.
- we rely on existing distributors, methods, controls and supervision already in place;
- our approval system has checks and controls in place to flag applicants who may be outside the target market; and
- accredited mortgage brokers are subject to a higher duty under BID to ensure that the product is in the best interests of the particular consumer.
We will review this TMD as follows:
|Initial review||Within 12 months of the date of this TMD|
|Periodic review||Each year on the anniversary of this TMD.|
Specific events will prompt Columbus to review this TMD, which includes:
If a review trigger occurs, we will complete a review of the TMD within ten business days. Meanwhile, we will cease to offer this product to our customers until our TMD review concludes and any necessary changes to the product or TMD, including distribution methods, are made.
Monitoring and reporting of this TMD
The following data must be provided to us by any person who engages in retail product distribution conduct in relation to this product:
|Type of information||Description||Reporting period|
|Specific Complaints||Details of the complaint, including name and contact details of complainant and substance of the complaint.||As soon as practicable and within 10 business days of receipt of complaint.|
|Complaints||Number of complaints||Every 6 months|
|Significant dealing(s)||Date or date range of the significant dealing(s) and description of the significant dealing (eg, why it is not consistent with the TMD)||As soon as practicable, and in any case within 10 business days after becoming aware|
|Feedback||Details of any suggested feedback and improvements||As soon as practicable, and in any case within 10 business days after becoming aware|