This Target Market Determination (TMD) document describes the class of consumers that Columbus has designed this product for, being the target market and the conditions (if any) around how the product is distributed to consumers. When considering the target market, Columbus focused on our consumer target market’s objectives and needs.

This TMD is not intended to provide you with financial advice nor is it a substitute for the product’s terms and conditions or other disclosure documents. Please refer to our Terms and Conditions and Credit Guide before deciding product suitability. Our product terms and conditions will be provided to you upon request.

The features of this product have been assessed as meeting the likely objectives, financial situation and needs of consumers who:

• are:
  • Trustee of a Self-Managed Super Fund;
  • The SMSF Trustee must hold a beneficial interest in the security property and must have a right to acquire the property from the Property Trustee and is permitted to borrow in accordance with all relevant legislative requirements and any associated regulations; and
  • The Property Trustee, which holds the legal interest in the security property on trust for the SMSF, must meet all relevant legislative requirements and any associated regulations.
• require a loan to purchase or refinance an investment property as part of a Self Managed Super Fund (SMSF);
• require the flexibility of a variable interest rate;
• require the ability to make additional extra repayments without penalty; and
• want the option of either principal and interest or interest only repayments.
• satisfy our eligibility criteria;

Although variable interest rates fluctuate, the product meets the likely objectives, financial situation and needs of consumers in the target market because it allows them to deposit SMSF funds into an offset account and/or make additional payments directly into the loan to reduce the amount of interest payable whilst maintaining the flexibility of transferring funds from the Offset account back to the SMSF Cash Management Account. This product also allows consumers to select interest only or principal and interest repayments to reduce their overall debt and build equity.

This product may not be suitable for consumers who:

• do not meet the eligibility requirements;
• are seeking the certainty of fixed repayments over the term of the loan; or
• are looking to construct a property; or

Columbus has oversight over how the product is promoted and issued. The following distribution channels and conditions have been assessed as being appropriate to direct the distribution of the product to the target market:

• Direct
  • Online
  • By phone
  • In person (e.g. branch, agency, or premises visit)
• Third party – Accredited mortgage brokers subject to their Best Interests Duty (BID) obligations

The distribution channels and conditions are appropriate because:

• the product has a wide target market;
• our staff have the necessary training, knowledge and accreditation (if required) to assess whether the consumer is within the target market. All of our staff must continually satisfy annual compliance reviews.
• we rely on existing distributors, methods, controls and supervision already in place;
• our approval system has checks and controls in place to flag applicants who may be outside the target market; and
• accredited mortgage brokers are subject to BID to ensure that the product is in the best interests of the particular consumer.

A distributor must:

• Hold an Australian Credit Licence or be a Credit Representative authorised to engage in credit activities on behalf of a credit licensee; and
• Comply with the terms and conditions of any relevant distribution agreement or arrangement with the Product Manager.

This condition ensures distributors are appropriately authorised to provide the relevant regulated financial services and will comply with the commercial terms agreed between the distributor and Product Manager.

This condition applies to all conduct by the distributor.

Specific events will prompt Columbus to review this TMD, which includes:

• A significant dealing of the product to consumers outside the target market occurs;
• Unexpected trends in consumer outcomes which are significantly inconsistent with the intended product performance;
• A significant number of material complaints are received from consumers in relation to the product;
• Unexpected early stage arrears are detected;
• A significant number of defaults occur;
• A significant breach has occurred in connection with the issuing and distribution of this product;
• A significant number of late repayments are being recorded;
• A material change is made to this product;
• Evidence that the product or distributor conduct are significantly different to the target market; or
• The receipt of a product intervention power order from ASIC requiring us to immediately cease retail product distribution conduct in respect of the product.

If a review trigger occurs, we will complete a review of the TMD within ten business days. Meanwhile, we will cease to offer this product to our customers until our TMD review concludes and any necessary changes to the product or TMD, including distribution methods, are made.