Target Market Determination (TMD)
TARGET MARKET DETERMINATION – MUCHBETTER WALLET
Issuer | MIR MUCHBETTER AUSTRALIA Pty Limited ACN 658 003 804 (MIR AU, we, us or our) (Australian financial service licence (AFSL) no. 540851) |
Product | MuchBetter e-wallet (Wallet) |
Effective Date | 01 JANUARY 2024 |
This Target Market Determination (TMD) seeks to offer an understanding of the class of customers for which this product has been designed, the distribution conditions, and how it is reviewed and monitored for ongoing appropriateness. This TMD is specifically in place to meet our Design and Distribution Obligations (DDO) as required under s 994B in Part 7.8A of the Corporations Act 2001 (Cth) (Corporations Act).
MIR AU is authorised under its AFSL to offer the digital Wallet (a non-cash payment facility) to both retail and wholesale clients. For the avoidance of doubt, this TMD only applies to retail clients and any reference to the ‘client(s)’ within this document is a reference to retail clients only.
The information contained within this TMD is not financial advice and does not take into account any customer’s individual objectives, financial situation or needs.
1. Product Overview
· The Wallet, available through the MIR AU mobile application (App), allows clients to:
(a) hold electronic money in a digital wallet;
(b) store, deposit and spend electronic money safely and rapidly, including with a variety of licensed online gambling / gambling brands and various online merchants;
(c) send to, and/or receive e-money from, P2P transfers via other MuchBetter Group e-wallet users (including Wallet users) domestically or overseas;
(d) facilitate currency exchange by allowing clients to make a transaction (i.e. deposit, withdrawal or payment) in a currency other than the currency denominated in the Wallet; and
(e) view information about, and manage, the Wallet.
· Customers can choose their Wallet currency from the available MuchBetter Wallet currencies.
· The Wallet can be funded from a variety of different methods including, debit card or directly from a bank account.
· The App is available from both the Apple Store and Google Play.
2. Key Eligibility Criteria
· To be eligible for the Wallet, clients will need to satisfy certain eligibility criteria, including:
(a) be an individual aged 18 years and above;
(b) have a residential address in Australia and be an Australian citizen, temporary or permanent Australian resident (limited exceptions may apply subject to conditions);
(c) have an eligible MIR AU account to which the Wallet will be linked;
(d) not suffering a vulnerability (for instance, mental illness, cognitive impairment, disability or gambling addiction or other financial hardship) or is undischarged bankrupt; and
(e) satisfactorily pass all required identity, security and verification checks,
(together, the Key Eligibility Criteria).
· Clients who do not meet the Key Eligibility Criteria are expressly excluded from the target market for the Wallet.
3. Target Market and Product Attributes
· In the table in this section, we set out:
(a) the likely objectives, financial situation and needs of consumers in the Wallet target market; and
(b) describing how the Wallet product attributes and features correspond to the likely objectives, financial situation and needs of consumers in the Wallet target market.
· In order for a consumer to be in the target market for the Wallet, the consumer must possess at least four (4) or more of the target market characteristics described in the table below and meet the Key Eligibility Criteria.
Item | Target Market Characteristic | Product Attributes / Features |
Customer Objectives and Needs | ||
1 | Seeking an account to store e-money and make rapid payments / transfers (domestically or internationally) to online suppliers of products and/or services. | · Customers can store e-money in the digital Wallet and then make seamless payments to variety of online merchants and online gambling brands. |
2 | Has an interest in licensed and regulated gambling / gaming platforms, including (but not necessarily) has an account with a licensed gambling / gaming platform | · The Wallet is specifically designed to enable rapid and secure transfer of funds to licensed and regulated gaming / gambling platforms affiliated with MIR AU. |
3 | Is comfortable making and receiving online e-money transactions | · The Wallet is specifically designed to allow for sending funds to, and/or receiving funds from, other persons using the MuchBetter Wallet domestically or overseas |
4 | Is affiliated with other persons (e.g. a family member) using the Wallet in the MuchBetter Group and is seeking the ability to transfer funds to that person. | · The Wallet is specifically designed to allow for sending funds to, and/or receiving funds from, other persons using the MuchBetter Wallet domestically or overseas. |
5 | Is comfortable with and/or is interested in accessing their account (including Wallet) through digital channels. | · Accounts can only be accessed through the MIR AU APP. |
6 | Seeking an account which allows for foreign currency exchange between the following currency: AUD, USD, GBP, EUR, CAD. | · The Wallet allows for foreign currency exchange between: AUD, USD, GBP, EUR, CAD. |
7 | Allows for payments from the Wallet to overseas merchants (including gambling / gaming platforms) in Wallet currencies | · Depending on the specific gambling / gaming platform, the Wallet allows for payments to overseas merchants in one or more of the following foreign currencies: USD, GBP, EUR, CAD. |
Customer Financial Situation | ||
8 | Requires a low-cost mechanism to pay funds to, and receive funds from, online gaming / gambling brands.
| · Depending on the payment method of choice by the customer, fees can vary from 0% p.a. to a fixed fee of $1 plus a percentage of the value loaded in the Wallet. |
9 | Requires a relatively low cost mechanism to convert currency (compared with other foreign exchange providers). | · % fee of the value of a foreign exchange transaction, up to date information on fees page of Website. |
10 | Requires a competitively priced mechanism for effecting e-money transactions | · Depending on the payment method of choice by the customer, fees can vary from being free of charge, or charging a % of the value or a fixed fee or both |
4. Distribution Conditions
· Any distribution of the Wallet will be in accordance with procedures that we determine are reasonably likely to ensure that our products are offered to customers who are reasonably likely to fall within our target market.
· MIR AU applies the following conditions on the distribution of the Wallet so as to best ensure that it is likely to be provided to customers in the target market.
Condition | Rationale |
Online and No Third-Party Distributors The Wallet can only be distributed by MIR AU following the completion of an online application through either of the following channels: · MIR AU’s website; and · mobile applications on the Apple Store and Google Play. No third-party distributors are engaged to distribute the Wallet. | MIR AU’s digital distribution model aligns to the target market’s preference to use digital channels. This also ensures that MIR AU controls distribution and does not have any third-parties inappropriately distributing the product outside the specified target market. |
Marketing MIR AU implements reasonable steps to ensure that our marketing strategy is only targeting customers within our target market and adhering to all applicable laws and regulations. For example, a marketing campaign for the Wallet may specifically highlight that a customer can: a) make payments to specified gambling merchants; b) can transfer funds between Wallet users; and c) allow for foreign currency exchange. Regular reviews of marketing materials and campaigns are also undertaken to identify and address any potential issues promptly.
| Ensuring that MIR AU’s marketing activities are directed at the target market will assist in ensuring that only persons within the target market approach MIR AU for the Wallet. |
Key Eligibility Requirements All distribution channels must ask a standard set of questions to ensure that the Key Eligibility Requirements have been met. | The completion of these checks and data collection during the digital sign-up process enables MIR AU to confirm that the customer is eligible for the product (and therefore part of the target market). |
5. Review of this TMD
· This TMD will be reviewed on a minimum two (2) year basis unless a particular event or circumstance occurs that may materially change the information contained in this TMD or suggest that it is no longer appropriate.
Reviewing the TMD | |
Initial Review | The initial review of this TMD will occur no later than 6 months from the commencement date of this TMD. |
Periodic Review | Subsequent reviews of the TMD will occur every 6 months, or more frequently if a review trigger occurs. |
External Review | MIR AU will implement legal review of the controls and processes in this TMD every 12 months. |
Review Triggers | MIR AU will review this TMD within 10 business days if we know, or ought to reasonably know, that an event or circumstance that reasonably suggests that the TMD is no longer appropriate, has occurred (Review Trigger). These Review Triggers include (but is not limited to): · receipt of more than 8 customer complaints that indicate issues related to the distribution of the Wallet client suitability and/or understanding to the distribution of the Products, within any 2-month period either through our internal dispute resolution (IDR) channel or external dispute resolution (EDR) channel; · there is an over 25% increase of complaint rate in a single calendar month, compared to the average monthly rate of complaints of the three preceding calendar months; · any customer complaint that is of a serious nature or with a substantial monetary value, regardless of the number of these customer complaints; · there are material changes to the Wallet (or new products offerings for customers); · there is a material change with respect to the PDS, General Advice Warning or T&Cs; · there is a material change with respect to the Distribution Conditions for the Wallet; · there are material changes to laws and regulatory guidance affecting the Wallet; · legal or regulatory action commenced against MIR AU concerning the Wallet offered under this TMD; · MIR AU becomes aware of significant dealings of the Wallet outside the Target Market; · adverse findings arising from an external auditor or independent review in relation to the Wallet covered by this TMD; or · another event or circumstance that could materially change a factor taken into account in making this TMD. Unless the TMD has been reviewed and if necessary, a new TMD issued within 10 business days of a review trigger having occurred or when another event or circumstance suggesting that the TMD is no longer appropriate, MIR AU must remove the product from the market and direct the distributors to stop distributing the product as soon as practically within that 10 business days. |
6. Reporting and Monitoring
· The following schedule sets out the information which we require to be reported to us in respect of the Wallet.
· Unless expressly stated to the contrary, the first reporting period commences on the commencement date this TMD is made and each subsequent reporting period commences at the end of the prior reporting period.
Information required to be reported | Personnel required to report | Reporting frequency | Form of report |
Number of: · IDR; and · EDR complaints received in relation to the Product during the reporting period relating to the suitability of the Product | MIR AU Compliance | Recurring every 2 months | By email to the Head of Compliance (Group). Head of Compliance (Group will then report to Legal Director and/or Board of Directors
|
Material change(s) made to any of the following: · Products; · PDS; · General Advice Warning; · MIR AU T&Cs; or · Distribution Conditions Any other Review Triggers specified in section 5 above apply. | As soon as is reasonably practicable considering the nature and extent of the change |
Revision Management
Date | Action | Current version | Approved by | Additional comments |
01/01/2025 | TMD Created | 1.0 | SUB | CM |