Mulga Money — e-bike finance, plain and fair

TARGET MARKET DETERMINATION — MULGA MONEY E-BIKE LEASE-TO-OWN [LEGAL REVIEW REQUIRED — draft for counsel; bracketed items must be resolved and approval recorded in the admin console before publication.] Mulga Finance Pty Ltd (trading as Mulga Money) · ABN 18 689 117 995 · Australian credit licence 573780 Version 1.0 — DRAFT FOR LEGAL REVIEW · Effective date: [TO BE SET ON COUNSEL APPROVAL] This Target Market Determination (TMD) is made under s 994B of the Corporations Act 2001 (Cth) for the design and distribution obligations (DDO). It describes who this product is designed for, how it may be distributed, and when this TMD will be reviewed. It is not a summary of the product's terms and is not financial advice. 1. Product and issuer Product: Mulga Money e-bike lease-to-own — a regulated consumer lease of an electric bicycle. Key attributes: lease value $2,100; fixed term of 21 weeks; fixed weekly payment of $100; no interest; establishment fee $150 (once); late payment fee $30 (only if a payment is missed, at most one per month, subject to statutory caps); no other fees; ownership transfers to the customer automatically at no extra cost when the final payment clears; early payout permitted at any time with no early-exit fee. Issuer: Mulga Finance Pty Ltd (ABN 18 689 117 995), Australian credit licence 573780. TMD version 1.0. Effective date: [TO BE SET]. 2. Target market This product is designed for consumers who meet all of the following: - Objectives: want to acquire a commuter e-bike for personal transport, and prefer to spread the cost over a short, fixed term with certainty about the total payable. - Needs: a fixed weekly payment, no interest, a short commitment (about five months), and automatic ownership at the end. - Financial situation: aged 18 or over, residing in Australia, with regular verifiable income and the capacity to meet a $100 weekly payment after their existing expenses and commitments without substantial hardship. 3. Consumers outside the target market The product is not designed for consumers who: cannot meet the weekly payment without substantial hardship; are currently subject to a hardship arrangement, bankruptcy or debt agreement [LEGAL REVIEW: confirm exclusion drafting]; need cash or credit for essential living expenses (this product supplies a specific good, not funds); are under 18 or not residing in Australia; or want a long-term or interest-bearing credit facility. 4. Distribution conditions - The product is distributed only (a) directly through the Mulga Money website and platform, and (b) via application invitations issued by approved partner retailers. - Retailer staff may only describe the product factually and issue an application invitation. They must not provide credit assistance or advice, must not collect or see financial information, and cannot influence or view credit decisions — the platform enforces this structurally. - Every application is individually assessed by a trained Mulga assessor against the consumer's stated and verified financial position; the assessment software cannot approve an application, and no lease is entered without a human decision recorded with written reasons. - Marketing must not represent that approval is guaranteed, automatic or instant. These conditions make it likely that consumers who acquire the product are within the target market, because acquisition always passes through an individual affordability and suitability assessment. 5. Review triggers We will review this TMD promptly if any of the following occurs: a material increase in hardship notices, arrears or defaults on this product [LEGAL REVIEW: set numeric thresholds, e.g. hardship notices exceeding 10% of active accounts in a quarter]; complaint volumes or the nature of complaints indicating the product is reaching consumers outside the target market; a significant dealing outside the target market as defined in s 994F(6); an adverse AFCA determination or regulator feedback concerning this product; or any material change to the product's fees, term or distribution. 6. Review periods First review: within 12 months of the effective date. Subsequent reviews: at least every 2 years, or sooner if a review trigger occurs. 7. Distributor reporting and records Partner retailers must tell us about any complaint they receive relating to this product within 10 business days of becoming aware of it, including sufficient detail for us to assess it, and must report any significant dealing outside the target market as soon as practicable and within 10 business days. We keep records of decisions on this TMD, reviews, triggers and distributor reports for 7 years.