Target Market Determination

A. About this TMD 

Afmoom Trading Pty Ltd t/as Bless Payments ACN 663 026 846 AFSL No. 549100 (Bless, us, we, our) is the issuer of the non-cash payment product and foreign exchange product described in this TMD.  

Bless provides a mobile application that offers you a sophisticated overseas payment solution via your Bless Account (Account). The Account is comprised of the non-cash payment product and foreign exchange product referred to in this TMD. 

This TMD is effective from 5 December 20223 and relates to the non-cash payment facility and foreign exchange product issued by Bless. 

This TMD describes: 

  • the class of customers that comprise the target market for the Account;  
  • any conditions or restrictions on how the Account  may be issued; and 
  • events or circumstances which will cause us to review the TMD. 

The TMD is not a replacement for the terms and disclosure documents which govern the Account. We encourage you to read and consider the Combined Financial Services Guide & Product Disclosure Statement and Terms & Conditions, which are both available on our website (www.blesspayments.com.au), before deciding whether the Account is appropriate for you.  

 

B. Product Description 

The Account has been designed to provide users with an easy to use solution to send money to overseas recipients. It is an out-bound service only. The Account is only available digitally through our mobile application, which can be downloaded from Apple’s App Store or the Google Play Store.  

By logging into the Account users can access the following services:

  • deposit AUD to the Account in anticipation of making current or future overseas transfers; 
  • convert AUD to another currency (“destination currency”). Destination currencies available are listed on our website and may be updated from time to time; and 
  • make payments to a recipient overseas in the destination currency. Payments can be made to any country listed on our website. The country list may be updated from time to time. 

 

C. Attributes and Target Market

The TMD is required to disclose the key attributes of the Account and when they are likely to be consistent with the identified target market for the Account, which is based on the likely objectives, financial situation and needs of customers.  

Needs, objectives and financial situation of customers within the target market  Product attributes
A person who is technologically literate and prefers to use digital-only channels and does not require face-to-face assistance to use the product. Customers can only access the Account by downloading the Bless mobile application, which is available on the Apple App Store or Google Play Store. 
A person who wishes to send money to recipients overseas for non-business purposes.The Account only facilitates ‘out-bound’ remittance transfers. Customers cannot receive funds. 

The Account is only available to individual customers. It cannot be used for business purposes.
A person who wishes to convert AUD to the relevant destination currency for the purposes of making an overseas remittance transfer.  Customers can convert AUD to any destination currency as part of making an overseas payment. Customers cannot withdraw destination currencies from the Account or otherwise speculate on foreign currencies. 

 

D. Distribution Conditions 

We apply the following distribution conditions so that the Account is likely to be provided to customers in the target market: 

Condition   Reason
The Account is only distributed by Bless through its mobile application. This distribution model is consistent with the target market’s preference to use digital-only channels. 
The Account is only distributed to individual customers who are over the age of 18. The Account is intended to be used for personal and domestic purposes. It is not intended for business use. 
The Account will not be distributed to customers who are wanting multi-currency or foreign exchange trading or withdrawal functionalities. The foreign exchange functionality is simply intended to facilitate payments overseas in the appropriate destination currency. The Account is not intended to be used to trade or speculate on foreign currencies. 
The Account can only be used to make overseas transfers once the customer completes an application form and passes our onboarding procedures. These procedures are intended to confirm that the customer meets the eligibility conditions which apply to the Account. 
The Account will primarily be promoted through digital channels, including social media and paid ad platforms. A focus on digital marketing aligns with the target market’s preference to use digital-only channels. 

 

E. Review 

We will review this TMD on an annual basis, or earlier if other circumstances require a review of the TMD. 

A review will be undertaken immediately upon the occurrence of a review trigger, which is: 

  • the introduction of new products or major features;  
  • any material change to existing products or major features;  
  • a change to any law, regulatory guidance or industry code which has a material effect on the terms of the Account;   
  • a significant number of complaints with respect to the Account;  
  • where there are significant dealings in the Account which are not consistent with the identified target market or this TMD; or  
  • where our reporting and monitoring procedures identify a need to review the TMD. 

 

F. Reporting 

We will collect and analyse information about the Account on an ongoing basis to determine whether the TMD remains appropriate. The type of information we will collect includes: 

  • product performance data which may include numbers of new sign-ups, cancellation rates and dormant accounts; 
  • customer feedback and complaints on product experience, including the volume and category of complaints received; 
  • general feedback from other sources, such as regulators, third-party suppliers and other stakeholders; and  
  • information or data which may suggest that there are significant dealings in the distribution of the Account.