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Target Market Determination

Retail individual

October 2024

Issued by Hay Limited ABN 34 629 037 403 

Australian Financial Services Licence No. 515459 

Sydney HQ 22–24 Hutchinson St. Surry Hills NSW 2010 AustraliaLondon 2 Minster Court London EC3R 7BB United KingdomIssued by Hay Limited ABN 34 629 037 403Australian Financial Services Licence No. 515459 Hay® is a registered trademark. shaype.com

Financial Services Guide
Issued by Shaype | Hay Ltd

1. TMD for non-cash payment product 

Target Market Determination

Product: KttiPay Account and KttiPay Visa Debit Card
  Non-cash payment product
Issuer Hay Limited ABN 34 629 037 403, AFSL 515459 (Hay)
Start Date: February 2022 – the date the determination was first made
This TMD issue date: October 2024
Review Date: October 2025
Target Market:
Class of retail individuals that comprise the target market for the product.
Retail Individual
Description:
This describes retail individuals in the target market.
Eligibility criteria for the product
Retail Individuals will need to satisfy specific eligibility criteria to maintain this product. To
qualify, the Retail Individual must:
● Be an individual person; and
● Be aged 18 years or older; and
● Have a valid Australian residential address.
Objectives & Needs
This product is targeted at Retail Individuals with
the likely objectives, financial situation and
needs of wanting:
● Access to a debit card to make purchases
with an internationally branded scheme such
as Visa
● To store money in an account without the
ability to access interest on their balance.

Financial Situation
● At the time of application, the Retail
Individual has the right to open a Non-Cash
Payment product and has access and the
ability to transfer funds in Australian dollars
to preload the facility and pay fees.

Product Description:

This describes the
non-cash payment
product.

● A Non-Cash Payment Product issued by Hay
Limited is a fully digital transaction account
that allows the Retail Individual to access
their funds on demand.
● Access is only possible through card, app,
BSB and Account number and does not
have a physical presence. Retail Individuals
cannot make cash deposits or other
withdrawals from the account via a physical
branch except by using a card at an ATM
where Visa Debit cards are accepted.
● No interest can be earned on the funds
deposited in the account.
● Overdrawing the account is not permitted.
● There are spend control and merchant category code limitations:
o The card program prohibits spending at
unsuitable or inappropriate merchants to
reduce harm.
o The card program has limits in place for
the account balance and daily spending.
Appropriateness
Statement:
This explains why
the product is consistent with the
target market’s likely objectives, financial situation, and needs.
Hay has considered that the product is likely to
be consistent with the possible objectives,
financial situation and needs of the Target
Market as:
● Retail Individuals can fund the account to
store and or spend those funds through a
Debit card accessing the Visa network, or
● Through a BSB and Account number via
Direct Entry or NPP.
Category Description
Distribution Conditions:
The conditions and restrictions on the distribution of the product
Marketing and Promotion

This condition applies to marketing and promotional materials that describe the product
Condition 1
The authorised distribution partner must only
market and promote the product as a reloadable Non-Cash Payment Product in Australia.
This condition is suitable as the issuer has distributed this product using these methods, with limited risk to Retail Individuals.
  Retail Product Distribution
Conduct (other than
Marketing)

This condition applies to
all conduct (other than
marketing), such as
issuing, arranging, and
providing disclosure
material.
Condition 2
The authorised distribution partner must only
engage in arranging, distribution and
providing factual product information:
● through the KttiPay App;
● to prospective Retail Individuals who meet
Hay’s eligibility criteria for the product; and
● to arrange for the issue of the Non-Cash
Payment Product to retail individuals after
applying for and completing the application process.
This condition is suitable as the issuer has
distributed this product using these methods,
with limited risk to retail individuals.
Review Triggers:
The events and circumstances
that would reasonably suggest the determination is no longer appropriate
The issuer, and any distributor of this product, must cease retail product distribution conduct in respect of this product when the issuer determines a material event or circumstance has occurred concerning:
Material Complaints Material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.
Product Performance Evidence, as determined by the issuer, of the product’s performance, in practice, may suggest that the product is not appropriate for the target market.
Distributor Feedback Reporting from distributors, or consistent feedback from distributors on the target
market, suggesting that the determination may no longer be appropriate.
Substantial Product
Change
A significant change to the product features outlined in the product description will likely
make the determination no longer appropriate for the target market.
A significant change to the product because of
regulatory, legislative or code changes will likely result in the determination no longer being appropriate for the target market.
Significant Dealing A material pattern of dealings in the product or distributor conduct is inconsistent with the
determination.
Annual Product Review As a result of Hay conducting their annual product review and the product is found to be inconsistent with the target market.
Notification from a Court or relevant regulatory authority A notification is received by the Issuer from a Court or relevant regulatory authority requiring
immediate cessation of product distribution or conduct concerning the product.
Review Trigger Information Reporting requirements The distributor of this product must provide the following information to Hay Limited within the below timeframes.
  Product Complaints data Information relating to complaints received, including the number and complaint summary details by the distributor of this product and
provided quarterly within ten days of the end of the Quarter.
  Significant Dealings Any significant dealings of the product to retail individuals who are outside the target market.
This must be provided as soon as practicable and no later than 10 business days after the distributor becomes aware of such dealings.