Target Market Determination (TMD)
ENAYBL Deposit Solutions Deposit Bond
This TMD describes:
- the product and its key attributes
- who this product is suitable for (the target market) and who it is unsuitable for (outside the target market)
- how this product must be distributed, including any conditions and restrictions
- reporting obligations for distributors
- when this TMD will be reviewed.
Product Description
Product: ENAYBL Deposit Solutions Deposit Bond
Target Market
Likely Needs, Objectives and Financial Situation of Customers in the Target Market and consistency with the product’s key attributes
Require a financial guarantee to cover the deposit amount in lieu of a cash payment to the vendor for the purchase of a property due to either:
- choosing not to use their own funds; or
- using equity with minimal liquidity (For example, awaiting funds from an existing sale),
to pay for the deposit amount.
Distribution
ENAYBL Pty Ltd (ABN 29 663 866 662), trading as ENAYBL Deposit Solutions. The product and the systems it is distributed through have been designed for a customer seeking a deposit bond through ENAYBL Deposit Solutions. ENAYBL Deposit Solutions has taken reasonable steps to understand the key product attributes and align distribution to customers in the target market.
ENAYBL Deposit Solutions Deposit Bond can only be sold to persons that are eligible for the product in accordance with the application criteria that has been approved in writing by Swiss Re and which complies with the law (Application Process).
The Application Process has been tailored to identify the target market described in this TMD, including by assessing the customer’s residency, the amount of the required deposit and whether the customer has sufficient established equity/assets or financing at the application date to meet the financial requirements applicable to the Deposit Bond duration. The use of this Application Process will make it more likely that the product will be acquired by persons within the target market.
The Application Process is comprised of the following:
- Application and underwriting procedures, with underwriting and eligibility controls, including the use of an Application Form and an assessment of financial capacity;
- Underwriting guidelines.
This product can only be sold via Swiss Re approved underwriting and eligibility processes and controls. Any quoting outside the approved underwriting and eligibility controls must always be referred to a Swiss Re authorised representative for approval.
This product can be sold to customers within the target market without the customer being provided with any financial product advice or, with either general or personal advice.
Swiss Re and the distributors of the Deposit Bond, Enaybl Deposit Solutions, must make this TMD available free of charge.
ENAYBL Deposit Solutions Property Deposit Bond can be sold via:
- online at https://www.enaybl.com.au/;
- via direct contact between the customer and Enaybl Deposit Solutions;
- via a third-party intermediary.
ENAYBL Deposit Solutions Deposit Bonds is not available for customers to purchase directly from Swiss Re.
Reporting Obligations
ENAYBL Deposit Solutions will report to Swiss Re if it becomes aware of a dealing outside of the target market that is inconsistent with the TMD and which Swiss Re has not already approved.
Swiss Re will report to the regulator any significant dealing outside the target market that is inconsistent with the TMD.
- The date (or date range) the dealing occurred;
- Details about the dealing(s);
- Any steps or actions taken to mitigate this dealing; and
- Any steps or actions taken to stop or prevent any further dealings outside the target market from occurring.
ENAYBL Deposit Solutions will report to Swiss Re complaints and feedback information received about the product.
Swiss Re will report any complaints or feedback information received about the product.
- The number of complaints received about this product during the reporting period; and
- A brief summary about the nature of every complaint received and any steps taken to address the complaint.
- Data reviewed;
- Data analysis outcomes; and
- Review outcome decisions
TMD Review
The events or circumstances that may trigger a review prior to a scheduled periodic review date include Swiss Re becoming aware of:
- the nature or number of complaints or feedback provided about the product’s design or distribution that indicate significant or systemic issues, reasonably suggesting the TMD is no longer appropriate;
- a material increase in the number of unsuccessful Deposit Bond applications or referrals to Swiss Re for quoting outside the approved underwriting and eligibility controls;
- a material change to the product (including the Application Process) or distribution conditions, or to the information or the assumptions which the target market is based on, which reasonably suggests the TMD is no longer appropriate;
- a material incident in relation to the product’s design and distribution which reasonably suggests the TMD is no longer appropriate;
- any:
- change of relevant legislation, regulations or regulatory guidance; or
- direction or order from a regulator or AFCA related to the design of the product or its distribution,
- a significant dealing outside the TMD occurring that reasonably suggests the TMD is no longer appropriate.