Bano Account – Target Market Determination (“TMD”)
A. ABOUT THIS TMD
Bano Pty Ltd (Bano, us, we, our) is the issuer of the non-cash payment product described in this TMD.
Bano provides a mobile application that offers you a sophisticated payment solution via your Bano Account. The Bano Account includes access to the non-cash payment product referred to in this TMD.
Bano does not hold its own Australian Financial Services Licence. However it is authorised to issue non-cash payment facilities under an exemption provided by the Corporations (FinTech Sandbox Australian Financial Services Licence Exemption) Regulations 2020 (Cth) (Regulations or ERS).
This TMD is effective from 1 December 2022 and relates to the Bano non-cash payment facility issued by Bano.
This TMD describes:
the class of customers that comprise the target market for the Bano Account;
any conditions or restrictions on how the Bano 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 Product Disclosure Statement (“PDS”) and Terms & Conditions (“T&Cs”), which are available on our website, before deciding whether the Account is appropriate for you.
B. PRODUCT DESCRIPTION
The Bano Account has been designed to be a ‘super-app’ where customers can manage their money and financial affairs through an easy-to-use and safe mobile application. 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 Bano Account consumers can access the following services:
receive funds from a bank account held in your name with an Australian ADI;
receive funds from a bank account held in your name with an overseas bank through the SWIFT network;
receive funds from a third party’s bank account held with an Australian ADI or another institution;
receive funds from a third party’s account held with Bano;
convert funds from one currency to another currency;
make payments to a bank account held in your name with an Australian ADI;
make payments to a third party’s bank account held with an Australian ADI or another institution;
make payments to a third party’s account held with Bano;
make payments to a third party bank account held with an overseas bank through the SWIFT network; and
make payments to merchants from your Bano account with a Visa prepaid card.
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 consumers.
|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 Bano mobile application, which is available on the Apple App Store or Google Play Store.|
|A person who requires a transaction account to hold money, receive funds and make payments domestically.||Customers can receive and make payments from their Account. <br>Customers are provided with a physical and virtual prepaid VISA card, which is linked to their Account. The VISA card can be used to transact in-person and online.|
|A person who wishes to hold foreign currency for savings purposes or to make or receive payments in foreign currency.||Customers can use the currency exchange service to convert AUD to other supported currencies (and vice versa). <br>Customers can hold AUD and other supported currencies* in their Account.<br>Customers can receive and make payments in supported currencies. <br>*A list of supported currencies is available from our website.|
D. DISTRIBUTION CONDITIONS
We apply the following distribution conditions so that the Account is likely to be provided to customers in the target market:
|The Account is only distributed by Bano through its mobile application.||This distribution model is consistent with the target market’s preference to use digital-only channels.|
|The Account will only be issued 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.|
|Both traditional and digital media channels may be used to promote the Account. However, digital media channels will generally be preferred to promote the Account.||A focus on digital marketing aligns with the target market’s preference to use digital-only channels.|
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.
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.