TARGET MARKET DETERMINATION
This Target Market Determination (TMD) is issued on 24 March 2022 by Flash Partners Pty Ltd - ACN 607 885 941 - AFSL 480834 (“Flash Payments").
What is Target Market Determination (TMD)?
The Target Market Determination (TMD) is a written document prepared and made available before engaging in 'retail product distribution’. Please note a TMD is not a Product Disclosure Statement and is not intended to provide Financial Advice. Any advice provided in this document is general advice only and the information in this Target Market Determination does not take into account the investment objectives, financial situation and needs of any particular person. As issuer and distributor, Flash Payments must provide the target market determination to retail clients in advance of them entering into selling or providing a service on the product.
Purpose and Contents of this Target Market Determination (TMD)
ASIC guidance states the purpose of these arrangements is to assist in avoiding similar outcomes to those identified in the FSI and Royal Commission, and to assist in the management of non-financial risk.
The obligations require Flash Payments as issuers and distributors of financial products to consider the design of the product, including its key attributes, and to determine the appropriate target market for the product. That is, whether there is a class of consumers for whom the product would likely be consistent with their likely objectives, financial situation and needs.
Flash Payments is required to:
implement and maintain robust and effective product governance arrangements to ensure compliance with design and distribution obligations
Prepare a target market determination for financial products. The determination must be documented and meet content requirements as set out in the Corporations Act 2001 (Cth) (Corporations Act).
Make the target market determination publicly available.
Take reasonable steps that will, or are reasonably likely to, result in a distribution being consistent with the most recent target market determination.
Review the target market determination within 10 business days if we know or ought reasonably to know that the determination is no longer appropriate.
Keep records of the number of complaints received about a product in the target market determination.
Notify ASIC of any significant dealing in a product that is not consistent with the target market determination.
Keep records of all decisions made in relation to its target market determinations and reviews, and any distribution activities engaged in.
This TMD applies to the Foreign Exchange contracts offered by Flash Payments, detailed below, and this gives prospective retail clients an understanding of the class of consumer for which this product has been designed and intended. It should be read in conjunction with the Product Disclosure Statement (PDS) for this product, which is also available on our website at https://help.flash-payments.com/en/articles/1333181-product-disclosure-statement-pds
The TMD is based on our assessment of information available to us currently, of the likely needs, financial circumstances and objectives that generally describe our intended retail client market for this product.
This document does not provide personal advice, and does not take into account the needs, circumstances and objectives of any individual client (or prospective client) in any respect. As always, we recommend that you obtain advice from a licensed professional to ascertain whether this product is appropriate for your explicit needs.
Key Attributes of our foreign exchange products
The following details the significant characteristics and features of the products covered by this TMD, that you need to comprehend when you contemplate utilising our foreign exchange (FX) products. FX products enable the simultaneous purchase of one currency and sale of another currency at an agreed exchange rate. Foreign exchange contracts are not exchange traded and are customised to each individual transaction.
Where a client wants to transfer money immediately, then they will need to enter into a Spot Contract with Flash Payments. A Spot Contract is an agreement to exchange one currency for another at an agreed exchange rate within 2 days of the transfer being booked.
For example, when you make a purchase overseas in a foreign currency, you may have to pay the purchase price straight away. In those circumstances, your only consideration will be the exchange rate at the time of the purchase and booking the transfer. Prior to confirming a transfer and booking the Spot Contract, Flash Payments will provide a quote using the Spot Rate. Spot Rate means the exchange rate for settlement within 2 business days from the date the transfer is booked including the Flash Payments margin.
When a Foreign Currency is purchased from us, the Flash Payments Spot Rate is calculated by deducting a margin from the interbank rate which Flash Payments receives from its banking counterparties. Conversely, when a Foreign Currency is sold to us the Spot Rate is calculated by adding a margin to the interbank rate.
The underlying features of a Spot Contract mean that it is an uncomplicated product to serve a predetermined need to make a payment. All Spot Contracts are fully deliverable with the cost of the transfer, including the exchange rate, being locked in at the time of booking the transfer. Payment to fulfil the Spot Contract is required straight away (T + 2) and settlement times vary depending on currency and country of the recipient.
Where there is a need for a transfer to be made at a date beyond 2 business days, then subject to approval from Flash Payments, a Forward Exchange Contract could be established.
A Forward Exchange Contract allows customers to lock in a rate today for settlement and payment at an agreed date in the future. Usually up to 12 months time. This allows our customers to mitigate the risk of any adverse currency movements between now and the settlement date.
It does however prevent our customers taking advantage of any favourable currency moves as the rate is locked in today for a fixed settlement date in the future.
The rate for a Forward Exchange Contract is determined by taking the above spot rate and adjusting the rate by the interest rate differentials between the currencies involved in the transaction. The rate may therefore be better or worse than the Spot Rate depending on the interest rate differentials at the time.
It may be necessary to make an initial deposit on entering into the Forward Exchange Contract. Forward Exchange Contracts are not offered through the Flash Payments platform and can only be entered into over the phone.
Flash Payments does not provide personal financial advice and will not take into account the investment objectives, financial situation and/or needs of any particular person. The client has full discretion over the value of the Spot Contract and the timing of booking the transfer.
Likely financial objectives, needs and circumstances of retail clients in our Target Market
Flash Payments has determined that this product is suitable for customers who have an obligation or wish to transfer money overseas. There are a wide range of clients whose needs, objectives and circumstances require the facilitation of foreign currency payments and/or the management of foreign currency risk.
The products are suitable for any client who meets either or both of those categories, and is able to immediately fund the amount they are seeking to transfer overseas.
Our FX products are not offered as an investment or speculation service. We do not recommend for our products to be utilised by those who wish to bet on currency movement, given the high volatility of FX markets, and the related risk of loss. Our FX products are intended purely to provide foreign currency exchange and remittance services for clients that need to send funds worldwide.
The class of retail clients who are within the Target Market of this product/these products
Flash Payments has framed a set of criteria to assist retail clients in determining whether our FX contracts may be suitable for their financial needs, circumstances and/or objectives. We have designated key eligibility criteria to ensure that only retail clients who meet these, will utilise our products. Some examples of this criteria are listed in the below table.
Eligibility threshold This product IS appropriate for: This product is NOT
This product/s is appropriate for:
NOT appropriate for:
· Satisfaction of customer identification and verification requirements;
· Provision of an appropriate reason or need for remitting the funds to another country;
· The ability to provide cleared funds in order to meet their settlement obligations.
· Students who need to access funds in their country of origin to fund their tuition;
· Persons wishing to buy or sell property or assets in another country (whether for investment or migration purposes);
· Persons operating a business which involves the import or export of goods or services that must be funded in a different country / currency;
· Persons who wish to repatriate salary or investment income earned in a different country;
· Persons who are looking to receive inheritance or similar legal entitlement deemed for their remittance.
· Persons who wish to remit or receive ad hoc or ongoing financial support to family members in a different country;
· Persons who do have a
legitimate reason or need
to transfer funds
· Persons who wish to
speculate on the
movement of exchange
· Persons who have
insufficient funds to
settle their order.
Flash Payments has considered that the product, including its key attributes, is appropriate for the target market identified herein, including the likely objectives, financial situation and needs of consumers in the target markets.
This product can only be obtained by contacting Flash Payments through our office, via our website https://flash-payments.com/ or our APP.
Flash Payments does not have any Authorised Representatives, nor any third-party distribution agreements in place at the current time. Accordingly, there are no distribution conditions or reporting to disclose in this TMD.
All Flash Payments employees/representatives who sell FX contracts are required to meet relevant minimum educational, experience and training requirements, and comply with our operational and compliance processes and procedures in relation to all aspects of providing this service.
Please note that this TMD will be reviewed in the following circumstances:
Initial Review within 1 year of the date of issue of this TMD
Periodic review annually on, or prior to, the anniversary of this TMD
Review triggers or events:
As soon as practicable upon the occurrence of one of the following;
o material changes in the design, key attributes or distribution of the product;
o material changes in the legal/regulatory/economic environment impacting the efficacy or operation of the product;
o an alteration to the eligibility criteria determined for the product;
o the identification of any systemic issue materially impacting the likely success or appropriateness of the product;
o evidence that customer usage is significantly different from our expectations or that there have been substantial sales outside of our Target Market;
o the occurrence of a significant dealing and/or receipt of an ASIC notification to cease the product; and
o the receipt of material feedback or complaints from clients regarding the success, appropriateness, design or operation of the product.
Contact us if you have any questions about this TMD
Level 26, 1 Bligh Street
Sydney NSW 2000