Legal
Target market determination
RelloPay, Deferred payment plans for property marketing and listing costs
Issuer: Rello Finance Pty Ltd, trading as “Rello” (ACN 633 994 859)
Issue Date: 1 October 2023
Revision Date: 1 September 2025
Next Review Date: 1 October 2026
Version: 3.0
1.0 This Target Market Determination
This target market determination (“TMD”) applies to Rello’s Deferred payment plans for property marketing and listing costs referred to as ‘RelloPay’ and has been prepared by the issuer in accordance with our obligations under the Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs).
This TMD contains a description of the product, including the key attributes and why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market. It also specifies any conditions and restrictions on the distribution of the product, details distributor reporting requirements and sets out review dates as well as the events or circumstances which will prompt us to review the TMD (Review Triggers).
This document is not intended to provide financial advice. It forms part of Rello’s design and distribution framework for the product. It does not replace our terms and conditions or other disclosure documents that we may provide to our customers.
1.2 Product details
Real estate agencies require vendors selling a home to pay listing, marketing and product presentation costs associated with selling their property at the time of entering into an exclusive agreement with a Listing Agent to sell their property. Rello provides the vendor the payment option to pay upfront or defer to settlement the payment of such marketing costs normally associated with listing and selling a property. In return for paying those expenses up front on behalf of the vendor, Rello receives a share of the sales proceeds.
1.3 Date from which this target market determination is effective
21 March 2024 (the Effective Date).
2.0 Product Description and Key Attributes
| Attribute | Detail |
|---|---|
| Purpose | Funding for property listing, marketing and property presentation costs associated with the sale of a property. |
| User | Owner of a residential property who has entered into an exclusive agreement to sell their property. |
| Exclusions | Commercial Property, vacant land, industrial property, and property developments. |
| Advance Amount | Up to a maximum of 2% of target selling price capped at $35,000. |
| Fees | A Service Fee is applicable and quoted as a percentage of the Advance Amount. |
| Repayment | The Vendor sells to Rello the right to receive Advance Amount and Service Fee from a share of the sale proceeds, which is paid at settlement of the sale of the property or on the release of the deposit, the date the property is withdrawn from sale or 180 days of payment of the Advance Amount, whichever is earliest. |
3. Target Market
3.1 Description of the Target Market for the Product
The product is designed for individuals who:
- own a residential investment property in Australia which they have committed to sell;
- want the ability to pay a fee in exchange for the option to defer upfront property listing, marketing and presentation costs until settlement of the sale of the property;
- require an online fulfilment experience.
This product is not designed for customers who are able and willing to pay property listing, marketing and presentation costs upfront or can access an alternate cheaper option to pay these costs.
3.2 The appropriateness of the product for customers
Rello has concluded that this product is consistent with the likely objectives, financial situation and needs of individuals in the Target Market because it provides residential property owners with the ability to make purchases of goods and services to list their property and defer the payment for these costs until property sale and settlement.
3.3 Product Eligibility
To be eligible for the product a customer must:
- be at least 18 years old;
- be a permanent resident or citizen of Australia;
- have verifiable mobile telephone number and a valid address in Australia;
- hold a valid ID with either a drivers licence or passport;
- have an Australian issued debit card or have agreed to a Direct Debit Service Agreement;
- own a residential property that is ready to list and sell; and
- can demonstrate commitment to sell their residential property by either signing an exclusive sales authority with a Listing Agent or have executed an agreement to list their property via an online marketplace.
4.0 How this product will be distributed
4.1 Distributor Onboarding
| Method of Distribution | Conditions |
|---|---|
| Direct to online | Only authorised staff are permitted to assist consumers with this product. Authorised staff have the necessary training, skills and knowledge to assess whether the consumer is within the target market. |
| Third party distributors | Distributors, namely real estate agencies that meet our KYC/AML onboarding criteria, can refer their clients to us when they have a signed agency agreement. Third party platforms and marketplaces that have a direct API integration with Rello and are the main supplier of technology to a real estate agency can refer consumers to us. All applications from consumers referred to us by third parties are assessed by us. |
5.0 Reviewing this TMD
The features of the product, and this Target Market Determination, will be reviewed no later than 12 months after the date of this Target Market Determination, and thereafter annually each October. Reviews will take into account:
- Quarterly review of the appropriateness of the product limits.
- Quarterly review of the performance of each distribution method, including the referral of any consumers outside the target market.
- Quarterly review of product and portfolio performance.
The following circumstances (review triggers) will trigger an earlier review:
- If overdue account balances exceed 10% of the total outstanding balances.
- If the ratio of complaints received to new payment plans issued exceeds 5% in any quarter.
- If there is a significant dealing in the product outside the target market.
- We identify that the product has caused, or may be likely to cause, consumer harm.
- There is a material change to the product or the terms and conditions.
- There is a material change in the law or Regulator expectations.
6.0 Reporting and Monitoring the TMD
Distributors must report all complaints they receive in relation to the product as they occur so that they can be resolved by us immediately. Each report must include the identity of the distributor, the product name, the customer’s name, and the exact details of the complaint.
Distributors must report any significant dealings in the product to consumers outside the target market to us within 10 business days of becoming aware of the significant dealing.
DepositPay, Early Deposit Access for Vendors
Issuer: Rello Finance Pty Ltd, trading as “Rello” (ACN 633 994 859)
Issue Date: 1 November 2022
Revision Date: 1 September 2025
Next Review Date: 1 October 2026
Version: 2.0
1.1 Introduction
This target market determination (“TMD”) applies to Rello’s Early Deposit Access for Vendors referred to as ‘DepositPay’ and has been prepared by the issuer in accordance with our obligations under the Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs).
This document is not intended to provide financial advice. It forms part of Rello’s design and distribution framework for the product. It does not replace our terms and conditions or other disclosure documents that we may provide to our customers.
1.2 Product details
Rello offers DepositPay to vendors when the sale of their domestic residential property is unconditional and a deposit for that sale had been received from the purchaser and is held in trust for the Vendor. Vendors generally must wait for settlement to take place (normally 30–90 days depending on which state the property is located) before they can access the deposit. Rello provides the Vendor with early access to the amount of the deposit ahead of settlement.
1.3 Date from which this TMD is effective
21 March 2024 (the Effective Date).
2. Product Description and Design
| Attribute | Detail |
|---|---|
| Purpose | Advance funding of deposits held in trust. |
| User | Vendor who enters into an unconditional exchange of contract to sell their residential property. |
| Exclusions | Commercial Property, off-the-plan sales and property developments. |
| Advance Amount | From $20,000 to $250,000 per exchanged contract. |
| Fees | A service fee is payable based on a percentage of the Advance amount which is payable on settlement. |
| Repayment | The Advance Amount and service fee are payable at settlement upon deposit release or on a prescribed date which is generally the settlement date under the contract of sale. Early repayments are possible without penalty. |
| Term | Payment periods will match the settlement date up to 120 days. |
3.1 Description of the Target Market for the product
This product is designed for individuals where:
- The individual owns a property which is residential and located in Australia;
- An unconditional contract of sale has been exchanged for the property, any cooling off period has expired and the deposit has been paid by the purchaser;
- The contract of sale gives the Vendor a right to retain the deposit if the purchaser fails to settle.
3.3 Product Eligibility
To be eligible to access DepositPay, a customer must:
- be at least 18 years old and have title to the property sold;
- be a permanent resident or citizen of Australia;
- have a verifiable mobile telephone number and a valid address in Australia;
- hold a valid driver’s licence or passport;
- have signed and confirmed an unconditional contract of sale to sell their property;
- can confirm deposit is received and held in trust.
The target market excludes sales from a deceased estate, off plan residential sales and commercial property sales.
4.1 Distribution
| Method of Distribution | Conditions |
|---|---|
| Direct to online | Only authorised staff are permitted to assist consumers with this product. |
| Third party distributors | Real estate agencies that meet our KYC/AML onboarding criteria, can refer their clients to us when a contract of sale has been exchanged and deposit has been paid. Conveyancers and lawyers (“Settlement Agents”) who support Vendors in facilitating complex and often multiple transactions. All applications from consumers referred to us by third parties are assessed by us. |
5.1 Review periods and review triggers
The features of the product, and this Target Market Determination, will be reviewed no later than 12 months after the date of this Target Market Determination, and thereafter annually each October.
The following circumstances will trigger an earlier review:
- If the ratio of complaints received to new DepositPay advances issued exceeds 5% in any quarter.
- If there is a significant dealing in the product outside the target market.
- We identify that the product has caused, or may be likely to cause, consumer harm.
- There is a material change to the product or the terms and conditions.
- There is a material change in the law or Regulator expectations.
6. Reporting and Monitoring the TMD
Distributors must report all complaints they receive in relation to the product as they occur. Each report must include the identity of the distributor, the product name, the customer’s name, and the exact details of the complaint.
Distributors must report any significant dealings in the product to consumers outside the target market to us within 10 business days of becoming aware of the significant dealing.