Target Market Determination

Target Market Determination
Prepared for: Finmo’s non-cash payment facility (Finmo Account)

Purpose of the document

For the purposes of this TMD, references to retail clients are limited to business customers within the meaning of section 761G of the Corporations Act.
This Target Market Determination (TMD) has been prepared by Paynow Technology Pty Ltd (trading as Finmo Tech) (referred to in this TMD as, Finmo, we, us or our) in accordance with the framework established by Part 7.8A of the Corporations Act 2001 (Cth) and ASIC Regulatory Guide 274 (Product Design and Distribution Obligations).

Finmo holds an Australian Financial Services Licence (AFSL 535371) and is a member of the Australian Financial Complaints Authority (AFCA). Finmo provides financial services under this AFSL. Finmo is not an authorised deposit-taking institution (ADI) and is not regulated by APRA. The Financial Claims Scheme does not apply to the Finmo Account. The Finmo Account is designed for use by business customers for business payment and
treasury purposes.

This TMD describes: the class of retail clients that comprise the target market for the Finmo non-cash payment facility (Finmo Account); the conditions and restrictions on how the Finmo Account may be distributed to retail clients; the review triggers that may require Finmo to review this TMD; and Finmo’s reporting and record-keeping obligations. This TMD must be read together with the Product Disclosure Statement (PDS) for the Finmo Account and the Financial Services Guide (FSG). This TMD is not a summary of the product and does not replace the PDS.

Table of content

1. Product Description and Key Attributes
2. Target Market
3. Clients Likely Outside the Target Market
4. Distribution Conditions and Restrictions
5. Distribution Channel Suitability
6. Review Triggers and Review Period
7. Reporting Obligations
8. Record-Keeping
9. Regulatory Basis and Acknowledgements
10. Definitions

1. Product Description and Key Attributes

1.1 Product name and type

Product name: Finmo Account (a non-cash payment facility)

Product type
The Finmo Account is a non-cash payment facility designed exclusively for businesses. It enables eligible companies, trusts, partnerships or sole traders to send and receive domestic and international payments, hold and manage funds in multiple supported currencies,
perform foreign-exchange conversions and centralise payment and treasury operations. It is not a bank account, pays no interest and is not covered by the Financial Claims Scheme.
For detailed information on features and risks, please see the Product Disclosure Statement (PDS).

1.2 Key product attributes

• Multi-currency account: Business customers can hold transactional value in multiple supported currencies in their Finmo Account in connection with business payment operations, and convert between currencies via the Finmo Platform. Balances held in the account represent transactional funds awaiting payment or conversion and do not constitute a savings or deposit product.
• Payin functionality: Business customers can receive payments into the account by bank transfer or other supported methods.
• Payout functionality: Business customers can transfer money from their Finmo Account to beneficiaries in Australia or other jurisdictions approved by Finmo in connection with business payment operations.
• Foreign exchange: Finmo bases its FX quotes on the live interbank FX rate and applies a transparent, mutually agreed-upon FX markup.
• No interest: Balances in the account do not earn interest and the facility is not a bank account.
• Business use only: The Finmo Account is designed exclusively for eligible business customers using the facility for business payment, collections, payouts, FX conversion, and treasury centralisation purposes. It is not designed for personal, domestic or household use.
• Treasury centralisation: The Finmo Account supports payment operations
  centralisation, multi-currency holdings, and treasury visibility for business
  customers operating across multiple jurisdictions and currencies.
• Fees: Transaction fees apply to Payin and Payout transactions; additional fees may apply for currency conversion, failed transactions or other services.

1.3 Key risks

Transactions may be delayed, declined or restricted due to operational issues, regulatory requirements or counterparty failures. Funds held in the Finmo Account are not protected by any government deposit scheme. Customers must be able to tolerate these payment and operational risks and should refer to the PDS for full risk disclosures.

1.4 External Risks

• Cyber and account compromise risk: phishing, malware, compromised APIs, SIM swap and credential compromise can result in unauthorised transfers.

2. Target Market

This section identifies the class of retail clients for whom the Finmo Account (a non-cash payment facility) is likely to be consistent with their objectives, financial situation and needs.

2.1 Target market description

The Finmo Account is designed for eligible business customers acquiring and using the facility for genuine business payment, collection, foreign exchange and treasury purposes.
The target market consists of clients within the meaning of Chapter 7 of the Corporations Act who have a real operational need for one or more of those use cases and who meet the following criteria:

• Business customer type: The customer is a business entity (including a company, trust, partnership, or sole trader) acquiring and using the Finmo Account for business payment or treasury purposes, and not for personal, domestic or household use.
• Authorised representative: Any individual completing onboarding or giving
  instructions on behalf of the customer must be at least 18 years of age and duly authorised to act for that business entity.
• Business purpose: The customer has a genuine need for one or more of the following: domestic collections, domestic payouts, cross-border payments, multi-currency holdings, FX conversion, or payment operations and treasury centralisation.
• Digital capability: The customer is willing and able to operate the Finmo Account via digital onboarding, dashboard and/or API workflows.
• Product understanding: The customer understands that the Finmo Account is not a bank account, does not pay interest, and is not protected by the Financial Claims Scheme or any government deposit guarantee.
• Risk capacity: The customer can bear operational, fraud, counterparty, compliance-hold and access-delay risks associated with a non-cash payment facility used for business payments.
• Residency: The customer is located in a jurisdiction where Finmo services are available, subject to Finmo's Terms and Conditions.

2.2 Appropriateness and assessment

Finmo has assessed the Finmo Account, including its key attributes, functionality and risks, and has determined that the product is likely to be consistent with the likely objectives, financial situation and needs of business customers in the target market described in Section 2.1. This assessment is based on the product's characteristics as a non-cash payment facility designed for business payment and treasury purposes, its operational structure, and the risks outlined in Sections 1.3 and 1.4.

The product is likely to be appropriate for retail clients who:

• are business entities (companies, trusts, partnerships or sole traders) using the account for business payment and treasury purposes;
• need to make domestic or cross-border payments or hold multiple currencies;
• are willing and able to onboard and operate the account via digital channels (dashboard or API);
• understand that the Finmo Account is not a bank account, pays no interest and is not government-guaranteed; and
• can tolerate payment delays and counterparty/operational risks.

Finmo has also determined that distribution in accordance with this TMD is
reasonably likely to result in the product being distributed to business customers within the target market and consistent with their likely objectives, financial situation and needs.

3. Clients Likely Outside the Target Market

The Finmo Account is not appropriate for clients who:

• intend to use it for personal, domestic or household purposes;
• seek interest, investment returns or capital protection;
• rely on government deposit guarantees;
• are not operating as or on behalf of a business; or
• are under 18 years of age.

4. Distribution Conditions and Restrictions

Finmo must ensure the following conditions and restrictions apply when distributing the Finmo Account to retail clients.

4.1 Distribution conditions

The Finmo Account is distributed through Finmo’s digital platform and approved partners. Distribution is limited to business customers who meet eligibility requirements, complete appropriate verification and screening, make a business-use declaration, provide onboarding information sufficient to assess business eligibility and intended use, and satisfy applicable jurisdictional and KYB/KYC controls. Applicants must receive the current PDS and Financial Services Guide (FSG) before acquiring the product, and distribution channels must ensure the product is offered only to customers within the target market.

4.2 Distribution restrictions

Target Market Determination Paynow Technology Pty Ltd ABN 66 642 442 215
The Finmo Account must not be offered or distributed to:

• individuals or entities seeking to use the facility for personal, domestic or household purposes;
• individuals or entities whose onboarding responses indicate a use case inconsistent with business payments or treasury operations;
• persons under 18 years of age completing onboarding or giving instructions;
• persons in jurisdictions where Finmo is restricted or prohibited; or
• persons who have not completed the required KYB/KYC verification.

4.3 Disclosure requirements

This TMD is publicly available and can be accessed at www.finmo.net. Finmo will ensure the TMD is easy to locate on its website and will not limit its availability to upon-request access only. The PDS and FSG are available at www.finmo.net.

4.4 Risk warnings

Distributors must ensure that retail clients are provided with, or have access to, the risk disclosures contained in the PDS and must not represent the facility as risk-free, government-protected or comparable to a bank account or suitable for all users.

4.5 Partner and third-party distribution channels

If any third party (including referral partners, embedded finance partners, or white-label partners) distributes the Finmo Account to retail clients in Australia, Finmo will ensure:

• each such party is identified as a distributor for the purposes of this TMD;
• channel-specific distribution conditions are documented and agreed with each distributor;
• each distributor collects business identity data and applies business-use controls consistent with Sections 4.1 and 4.2 before offering the product to any applicant;
• channels that do not allow for the collection of sufficient business-use and eligibility data, or the application of business eligibility controls, are not used to distribute the Finmo Account; and
• each distributor is subject to the reporting obligations in Section 7.
  Where Finmo does not currently use third-party distribution channels in Australia, it will update this TMD prior to engaging any such channel.

5. Distribution Channel Suitability

Finmo distributes the account only through digital channels consistent with its nature as an online payment facility; the digital onboarding flow includes the verification, disclosure and data-capture steps necessary to assess target market fit before issue.
Target Market Determination Paynow Technology Pty Ltd ABN 66 642 442 215
Finmo does not distribute the Finmo Account through unsolicited outbound sales or through channels that do not allow applicants to review the PDS prior to acquiring the facility.

6. Review Triggers and Review Period

6.1 Periodic review

Finmo will review this TMD at least annually, and sooner if there are significant dealings inconsistent with the TMD, a material increase in complaints or adverse customer outcomes, or a material change to the product, its features, distribution strategy or applicable laws.

6.2 Actions following a review

Following a review, Finmo will update this TMD as necessary, provide updated copies to distributors and comply with its obligations to notify ASIC of significant dealings and other reportable matters under the Corporations Act. If a significant dealing inconsistent with the TMD has occurred, Finmo will take reasonable steps to address the issue, including updating distribution conditions or ceasing distribution through non-compliant channels.

7. Reporting Obligations

7.1 Finmo and any distributors must monitor distribution outcomes, including complaints and feedback, and promptly provide any information suggesting that the target market description or distribution conditions may be inappropriate. Finmo will report significant dealings outside the target market to ASIC as required by law.

7.2 Finmo’s reporting to ASIC
Finmo is required to report to ASIC any significant dealings within the non-cash payment facility that are inconsistent with this TMD. This is consistent with the approach in section 994F of the Corporations Act. Finmo will maintain records of all reports made to ASIC.

8. Record-Keeping

Finmo will maintain records of TMD versions, the basis for reviews, information provided by distributors, distribution metrics, complaints received, significant dealing assessments, and any remediation or distribution changes made following a review, as required under the Corporations Act.

9. Regulatory Basis and Acknowledgements

This TMD has been prepared in accordance with:

• Part 7.8A of the Corporations Act 2001 (Cth);
• ASIC Regulatory Guide 274 (Product design and distribution obligations); and Target Market Determination Paynow Technology Pty Ltd ABN 66 642 442 215
• Finmo’s obligations under its Australian Financial Services Licence (AFSL 535371).

Finmo acknowledges that this TMD applies to its non-cash payment facility only and does not constitute a TMD for any particular currency or digital asset used within the facility.
This TMD is not personal financial advice. Retail clients should consider the PDS and FSG and obtain independent advice before acquiring or using the facility.

10. Definitions