We have undertaken an assessment of the product and are of the view that the product attributes are likely to be consistent with the objectives, financial situation and needs of customers in the Target Market.

This product is not designed for and is outside the Target Market for customers who: 

• are individuals borrowing in their personal capacity, or entities that are not the trustee of a complying self managed superannuation fund;
• are seeking to enter into a new LRBA over residential real property on or after 10 August 2026. From 10 August 2026 an SMSF cannot enter into a limited recourse borrowing arrangement to acquire residential real property;
• SMSFs that do not have a corporate trustee, or where the legal interest in the security property is not held by a holding trustee on trust for the SMSF under a complying LRBA;
• SMSFs that cannot meet loan repayments, property outgoings and the fund’s other obligations from fund income, contributions and liquid assets without financial stress to the fund or substantial hardship;
• are seeking owner occupied or personal use finance, or funds for a purpose unrelated to the acquisition, refinance, repair or maintenance of the security property;
• are seeking certainty of repayments through a fixed interest rate. A separate TMD applies to the fixed rate product;
• customers seeking a redraw facility, cashout facility or Visa debit card.
• are seeking to acquire more than one asset under a single borrowing, or to use the loan to fund improvements to the security property;
• intend the security property to be occupied or leased by a member of the SMSF, a relative of a member, or any other related party of the fund, contrary to sections 66 and 71 of the SIS Act;
• customers that do not meet our credit, security or legal structure requirements.

To be eligible for this product the customer must meet certain eligibility criteria, including
that the customer:

• has a registered and compliant Australian Self-Managed Superannuation Fund (SMSF) and in relation to that SMSF:
  • all members and directors of the corporate trustee of the SMSF are Australian citizens or permanent residents of Australia;
  • the SMSF has a Corporate Trustee;
  • the SMSF holds the beneficial interest in the security property;
  • the SMSF meets all relevant legislative and associated regulatory requirements to acquire the property and borrow, in accordance with the SIS Act; and
    • a separate holding trustee (bare trustee) holds the legal title to the security property on trust for the SMSF and the SMSF has a right to acquire legal ownership of the property on making one or more payments, consistent with section 67A of the SIS Act;
    • the SMSF trust deed and the holding trust deed permit the borrowing and the acquisition of the security property and the rights of the lender on default are limited to the security property.
  • meets our lending eligibility criteria; and
  • has entered into and is maintaining, an LRBA that complies with sections 67A and 67B of the SIS Act and that was entered into before 10 August 2026; or, for a purchase, a binding contract for the acquisition of the security property was exchanged before 10 August 2026, in which case settlement, finance approval and entry into the LRBA may occur on or after that date; and
  • provide sufficient security in accordance with our lending eligibility criteria; and where a guarantor supports the loan, that guarantor also meets our lending eligibility criteria.

The financial situation of the Target Market are customers that:

• meet our lending eligibility and credit assessment criteria, which includes demonstrating serviceability of the loan;
• demonstrate the capacity of the SMSF to meet the required repayments, loan and property expenses and the fund’s benefit and pension obligations, from rental income, member contributions and other fund income, without relying on the sale of the security property;
• hold sufficient liquid assets within the SMSF to meet repayments and fund expenses, including an allowance for vacancy and interest rate increases; and
• where we determine it is required, having regard to the SMSF contribution, security, applicant and loan characteristics, Lenders Mortgage Insurance (LMI) must be obtained; and
• where we determine it to be required (based on the SMSF’s contribution, the security, the applicant and the loan attributes), provide additional credit support, which may include an acceptable guarantee. Any guarantee must be consistent with the limited recourse requirements of the SIS Act; and
• can contribute the required deposit or equity so that the loan is within the maximum LVR for this product.

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

Columbus Capital has oversight over how the product is promoted and issued. The following distribution channels and conditions have been assessed as being appropriate to direct the distribution of the product to the Target Market in accordance with our process requirements.

The distribution conditions above are appropriate because they require distributors to verify the key legal and financial features that determine whether an SMSF is within the target market. In particular, they require confirmation that the customers:

• meets the key eligibility criteria listed above;
• is seeking finance to buy or refinance a property in an SMSF and not for owner-occupied or construction purposes;
• has requested a loan size, LVR, term, interest rate type and repayment option that are within the product attributes; and
• has provided the SMSF trust deed and the property bare trust deed for review prior to loan approval.

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:

If a Review Trigger occurs, or any other event or circumstance occurs that would reasonably suggest this TMD is no longer appropriate, Columbus Capital will complete a review of the TMD as soon as practicable and in any case within ten (10) business days. During that period we will stop retail product distribution conduct in relation to the product until the review is complete and any necessary changes to the product, this TMD or our distribution arrangements have been made. Where we determine that this TMD is no longer appropriate, we will cease retail product distribution conduct in relation to the product until a revised TMD has been made and any necessary changes to the product or our distribution arrangements have been implemented.

All reporting required by this section must be provided to Columbus Capital at ddo@colcap.com.au in the format we specify from time to time. Where a distributor becomes aware of a significant dealing, it must notify us immediately by the same channel and must not wait until the end of the reporting period.

Accountable Owner – the accountable owner, Chief Product Officer, is the person responsible for ensuring the TMD remains appropriate, is reviewed when required, and that distribution monitoring occurs.

Approving Forum – Product Risk/Governance Committee.

Complaint – has the meaning given in ASIC Regulatory Guide 271 Internal dispute resolution.

Columbus will notify ASIC in writing within 10 business days of becoming aware of a significant dealing in the product that is not consistent with this TMD. Columbus and its distributors must keep complete and accurate records of the decisions, reviews and reasonable steps taken in relation to this TMD. Those records must be retained for at least seven years from the date the record is created. Distributor reporting under this TMD must be provided to the Product Manager at ddo@colcap.com.au.

Distributor reporting – including complaints, significant dealings and distribution-related incidents, is recorded and monitored through Protecht.

Retail product distribution conduct – dealing in the product with a customer, giving or providing a customer with the product’s terms and conditions or application form, or providing credit assistance or financial product advice in relation to the product.

Significant dealing – a dealing in the product with a customer who is not in the Target Market that is significant having regard to the proportion of customers who are not in the Target Market, the actual or potential harm to those customers, the nature and extent of any inconsistency between the dealing and this TMD and the time period over which the dealings occurred. A single dealing may be significant if it results, or is likely to result, in material harm to a customer.

System of Record for TMD Documents – Product SharePoint Product Governance Repository.