As a payments business, we issue non-cash payment facility products, which includes the ability for Consumers to maintain a balance of stored value.
Non-cash payment facility, and non-cash payment facility combined with a stored value facility.
Non-cash payment products are products that allow Consumers to make payments, otherwise than through the physical delivery of Australian or foreign currency (e.g. electronic cash and debit services).
We issue a standard non-cash payment facility product (the Zai payment facility), and a non-cash payment facility product with a stored value component (the Zai Stored Value Wallet). The stored value component of the product allows Consumers to store value in a wallet account and to make payments from the funds stored in that wallet account.
This TMD applies to the product.
are in the target market for our products.
Further details regarding the target market for our product are set out below.
| Criteria | Non-cash payment products (which includes the ability to store value) |
| Client type | Retail clients, as that term is defined in chapter 7 of the Corporations Act 2001 (Cth). This target market determination does not apply to wholesale clients, including sophisticated investors and professional investors. |
| Ability to bear losses | Consumers (Businesses) who are prepared to: • accept risks associated with payment delays and losses associated with political instability, war, suspension of financial markets and catastrophic events • accept risks associated with stored value facilities • be exposed to counterparty risk. |
| Client needs | Our products and their key attributes are likely to be consistent with the likely objectives, financial situation and needs of those Consumers who: • wish to make and receive non-cash payments • wish to maintain a wallet account to hold funds, and from which they can send and receive non-cash payments. Our product is likely to be consistent with the likely objectives, financial situation and needs of those Consumers, because the product provides these Consumers with the ability to make and receive such payments and store value in their wallet account where required. |
(a) Subject to (c) below, Consumers who meet each of the client needs for the relevant products as set out in the table above, are likely to be in the target market for those products.
Our products are generally unsuitable for the following classes of Consumers:
Consumers who are in any of the categories above are not in the target market for the product.
Our product is distributed by us.
We will take reasonable steps to ensure that we distribute the financial products to the identified target market.
To ensure that the distribution strategy is consistent with the identified target market, we have several processes in place to ensure that the Businesses who are potential clients fall within the identified target market. This includes Zai providing appropriate guidance about the products, including its purpose and risks, to staff who promote the product to Businesses.
We will also take reasonable steps to ensure that our marketing strategy is targeting potential clients who fall within the identified target market for our products. For example, as above, any new marketing campaign is reviewed and approved by Zai as the product issuer prior to its publication, to ensure that we are not seeking to attract potential clients outside of the intended target market.
The first review of this TMD will occur in September 2025.
Subsequent reviews of the TMD will occur on each anniversary of the first review date.
Zai will also review the TMD where the following review triggers occur:
Our product is distributed by Zai. However, if this changes, we will monitor and review the TMD to determine whether it is still appropriate.
If a Distributor is appointed, each Distributor must provide the following to us on a quarterly basis (subject to where no reporting is required, based on the particular reporting requirements and conditions set out below), within 10 business days of the end of each calendar quarter – 31 March, 30 June, 30 September and 31 December, each year:
(but only where the Distributor received complaints in relation to the product during the reporting period).
Each Distributor must report any significant dealing outside the TMD, as soon as practicable and in any event within 10 business days of such dealing.
No party may engage in the distribution of one of our products unless they have entered into an agreement with Zai.
Please contact us for further information and for a copy of our prescribed reporting template if you wish to become a Distributor of our product.
We reserve the right to amend the TMD at any time if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance, or for any reason we consider as a proper reason to amend the TMD.
For more information about your Target Market Determination - Payments, please email us at helpdesk@hellozai.com or contact us by post at:
Zai Management, Level 22, 120 Spencer St, Melbourne VIC 3000.