Target Market Determination – SMSF

Product SMSF Variable Investment
Product Manager Columbus Capital Pty Ltd ACN 119 531 252, Australian Financial Services Licence and Australian Credit Licence 337303
Issuer This product will be issued by a Lender* which will be named in the loan agreement and these products are managed and serviced by the Product Manager.

The product could be issued by any of the Lenders* named below
(a) Perpetual Corporate Trust Limited (ACN 000 341 533), Australian Credit Licence 392673;
(b) Pioneer First Australia Pty Limited ACN 086 092 613;
(c) Origin Mortgages (Aus) Pty Ltd ACN 086 045 721;
(d) Origin Money Pty Ltd ACN 621 866 242;
(e) Origin Mortgages Pty Ltd ACN 629 566 794;
(f) SQL Funding Pty Ltd ACN 629 498 095; and
(g) Origin CF Pty Ltd ACN 621 866 304,
to be referred to as (Columbus/we/us).

Effective Date of TMD 20 February 2024
TMD Version 2024.1
Next review due At least every 12 months from the Effective Date of this Target Market Determination
Product Features SMSF Investment SMSF Commercial Investment
Interest Rate Type Variable Variable
Repayment Options Principal and Interest or Interest only for an agreed period. Principal and Interest or Interest only for a period.
Redraw Yes Yes
Minimum Loan Size $50,000 $50,000
Maximum Loan Size (Subject to LVR and postcode policy) $3,000,000 $3,000,000
Maximum LVR (Subject to postcode eligibility criteria) 80% 80%
Additional repayments without penalty Yes Yes
Offset facility Yes Yes
* Fees – Application fee is payable. Other fees like Settlement Fees, Valuation Fees, Offset Account Fees, Ongoing Fees, Late Payment Fees may also apply
Product designed for customers who: Key Product attributes appropriate for target Market
  • Seeking a property loan with a range of features including repayments that can vary over the life of the loan for any of the following purposes:
    • purchasing, refinancing, a residential, investment, NDIS or commercial investment property;
    • purchase of an investment house and land package and/or;
    • off the plan purchase as investors.
  • The property loan account has a variable interest rate, meaning that repayments will vary based on changes to the interest rate.
  • The loan amount can be used for any one or more of the listed purposes.
  • SMSF Investment & Commercial Investment loans offer:
    • Principal and Interest; or
    • Interest Only, is available for an agreed period.
  • SMSF NDIS Investment loans offer:
    • Principal and Interest
  • Fees, charges, and third-party costs will be payable.
  • Flexibility to make additional payments more than the required monthly repayment amount and switch between principal & interest, interest only repayments.
  • Unlimited additional repayments (including the ability to pay the loan out early) can be made without additional charge.
  • A customer can switch between principal & interest and interest only repayment methods (terms and conditions apply).
  • Option to link an Offset Account for the purposes of reducing the amount of interest payable under the loan.
  • Credit balances in the Offset Account will reduce the balance on which interest is charged.
  • Customers can deposit, withdraw, or transact on the account via a broad range of channels by using:
    • Online and Mobile Application access;
    • Direct Debit and BPAY repayment facility;
    • Staff assisted channels; and
To be eligible for this product the customer must meet certain eligibility criteria, including that the customer:
  • have a registered and compliant Australian Self-Managed Superannuation Fund (SMSF) and are:
    • the members and directors of the SMSF are an Australian Citizen or a Permanent Resident of Australia;
    • a SMSF has a Corporate Trustee;
    • must hold a beneficial interest in the security property;
    • must meet all relevant legislative & associated regulation requirements to acquire the property & borrow from the Property Trustee in accordance with the Superannuation Industry (Supervision) Act 1993; and
    • must hold the legal interest in the security property on trust for the SMSF;
      • meet our lending eligibility criteria;
      • provide sufficient security in accordance with our lending eligibility criteria; and/or
      • a guarantor who supports the loan also meets our lending eligibility criteria.
The financial situation of the Target Market are consumers that:
  • meet our lending eligibility and credit assessment criteria, which includes demonstrating serviceability of the loan;
  • demonstrate the capacity to make the required repayments and the ability to pay off the loan without substantial hardship;and
  • where determined by us to be required, (based on the customers’ deposit size, security, applicant, and loan attributes), will pay Lenders Mortgage Insurance or have an acceptable guarantor;

Upon application we will undertake an assessment to determine the consumer’s ability to service the loan, which is our process of determining that the product is consistent with the financial situation of the Target Market.

Distribution Channels Product Distribution
  • Staff assisted channels (e.g., via email or phone)
  • Our staff have the necessary training, knowledge, and accreditation (if required):
    • to understand and can discuss the features and rates of our products;
    • to understand and can discuss the key differences of our products;
    • to assess whether the consumer is within the Target Market;
    • to assess whether the consumer meets our lending eligibility lending criteria; and
    • have access to product resources such as borrowing and repayment calculators, stamp duty and upfront cost calculator, and pricing tools
  • Our staff are part of assurance programs, and we rely on existing distributors, methods, controls, and supervision already in place.
  • We have approval control systems and processes in place to check and flag applicants who may be outside the Target Market.
  • Online channels (e.g., website and the mobile app)
  • The product cannot be distributed through online channels however the application process may commence online.
  • Applications commenced through an online channel will be directed through to a staff assisted channel.
  • Third party – Mortgage Managers and Accredited mortgage brokers subject to their Best Interests Duty (BID) obligations
  • A distributor must:
    • hold an Australian Credit Licence or be a Credit Representative authorised to engage in credit activities on behalf of a credit
    • comply with the terms and conditions of any relevant distribution agreement or arrangement with the Product Manager; and;
    • comply with their legal obligations;
  • Third party brokers must also:
    • hold appropriate qualifications, industry membership and authorisations to engage in credit activities; and
    • comply with their obligation to act in the best interests of their client when providing credit assistance.
  • These conditions ensure distributors are appropriately authorised to provide the relevant regulated credit services and will comply with the commercial terms agreed between the distributor and Product Manager.

Columbus has outlined below its review triggers for this product (Review Triggers). This TMD will also be reviewed if an event or circumstance has occurred that would reasonably suggest that the TMD may no longer be appropriate. Our review triggers for this product are:

Review triggers Description
Customer outcomes
  • Unexpected trends in consumer outcomes which are significantly inconsistent with the intended product performance;
  • Unexpected early-stage arrears are detected;
  • A significant number of defaults occur;
  • A significant number of late repayments are being recorded; and
  • Evidence that the product or distributor conduct are significantly different to the Target Market.
  • A significant number of material complaints are received from consumers in relation to the product.
Incident Data
  • A material incident or significant number of incidents in relation to the product’s design or distribution that identify breaches of our legal or regulatory obligations.
Changes to the Product
  • The material alteration of the product or product terms and conditions (e.g., adding to, removing, or changing a key product attribute; significant change to distribution channel and distribution strategy).
Significant Dealings
  • A significant dealing of the product to consumers outside the Target Market occurs.
Notification from ASIC
  • The receipt of a product intervention power order from ASIC requiring us to immediately cease retail product distribution conduct in respect of the product.

If a review trigger occurs, Columbus will complete a review of the TMD within ten (10) business days. Meanwhile, it will cease to offer this product to our consumers until our TMD review concludes and any necessary changes to the product or TMD, including distribution methods, are made.

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
Complaints Number of complaints, details of the complaint, including name and contact details of complainant and substance of the complaint. Quarterly, and in any case no later than 10 business days from the end of the quarter.
Significant dealing(s) Number of complaints 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 15 business days after becoming aware.
Information requested Any other information requested by the Product Manager. As soon as practicable, and in any case within 10 business days after receiving such request
Version Effective Date Link
2022.1 2 June 2022 Link
2021.2 5 October 2021 Link