
Our Commitment To You As A Responsible Lender
We always act in the best interests of our customers. We make sure that every loan we offer is affordable for our customers, and every loan meets their needs, objectives, and requirements.
Responsible Lending
We are committed to responsible lending practices and follow the following guiding principles:
We always make reasonable inquiries about the customer’s financial situation, and their requirements and objectives.
We always take reasonable steps to verify the customer’s financial situation.
We always review the last 90 days of your bank transaction history.
We always independently check your income and expenses.
We always enquire as to the purpose of your loan in order to make a final assessment (as the credit provider) about whether the credit contract is ‘not unsuitable’ for the customer. Based on the enquiries and verifications that we’ve made, we won’t offer you a loan if we believe it’s unsuitable for you.
We always encourage our customers to notify us if they find themselves in financial difficulty.
We may refer you to the government’s website www.moneysmart.gov.au if we believe that you might benefit from their sound financial guidance.
Credit Licence Information
Oz Cash Loans is part of Swift Loans Australia Pty Ltd which holds an Australian Credit Licence (ACL 461533). We comply with the responsible lending conduct obligations in Chapter 3 of the National Consumer Credit Protection Act 2009, including ensuring that we always lend responsibly.
Oz Cash Loans via Swift Loans Australia Pty Ltd is a member of Australian Financial Complaints Authority
DISPUTE RESOLUTION
Business relationships are built through trust, openness, honesty, integrity, consistency and respect towards others. Sometimes, though, there may be differences of opinion, particularly when things don’t quite work out the way you intended when you took out the credit contract. We recognise communication is the key to solving these difficulties and the steps below will assist both of us quickly get our relationship back on track.
Step 1: If you are dissatisfied with something we’ve done, we encourage you to phone us and explain your concern(s). We can usually resolve the matter(s) amicably, without delay.
Step 2: If you’re still not happy with our response, you should contact our Internal Dispute Resolution (IDR) Manager, by emailing us at customer-care@ozcashloans.com.au as soon as possible.
Step 3: Should you still be dissatisfied after using both of the above steps, you may contact our ASIC-approved External Dispute Resolution (EDR) provider, Australian Financial Complaints Authority. You can contact them at no cost by writing to GPO Box 3, Melbourne Victoria 3001, telephoning 1800 931 678 (free call), emailing info@afca.org.au, or via their website, https://www.afca.org.au.
Please note that you must have gone through our IDR process first before doing so. If you fail to do so, the matter will be referred back to us to resolve in the first instance.
Target Market Determination for Medium Amount Credit Contract
Medium Loans
This Target Market Determination (TMD) has been prepared by Swift Loans Pty Ltd trading as Oz Cash Loans ABN 59600167084 (Us, We, Our) Australian Credit Licence 461533 in compliance with our Design and Distribution Obligations under Part 7.8A of the Corporations Act 2001 (DDOs). It applies to our Medium Amount Credit Contract (MACC) product.
1. The Target Market for Our MACC Product
The Target Market our MACC product is consumers who:
need amounts of between $2,001 to $3,500;
need or require:
to pay for infrequent and sometimes unforeseeable expenses that cannot be met from their regular or usual disposable income but not for paying regular, ongoing ordinary household expenses such as utilities unless it is to pay accumulated arrears or unusually high amounts due to special circumstances; or
finance for the purchase of major items of personal property; or
refinance of pre-existing debts;
for personal non-business purposes.
are interested in a loan term no longer than 5 months;
can afford the repayments on the product without hardship;
have a net income greater than $600 a week ($1200 a fortnight);
want contracts which are clear and easy to understand with fixed interest and easily identifiable fees and charges.
want easy access to customer services to discuss payments, hardship and terms of the contract;
want the funds quickly;
want the loan application process to be simple, online, and quick.
2. The Key attributes of Our MACC Product
The key attributes of our MACC product are:
Loan amounts from $2,001 to $3,500.
Terms up to 12 months.
Fixed interest of 35% per year and an establishment fee of $400 and a $7 monthly account fee.
Transparent, legible and easily understood contract documents, including a financial table and standard loan terms.
Ready access to customer services and hardship policy.
Fast on-line application and approval process.
3. The key attributes of Our MACC Product meet the Target Market.
The key attributes of our MACC product meet the needs, objectives and financial situations of consumers in its target market because:
our MACC product:
provides easy access to medium term finance for consumers for their infrequent and sometimes unforeseeable expenses or for purchases of personal property or refinancing of other debts.
loan amounts are closely related to the amounts required by the target market consumers in their loan applications.
terms match the consumers’ needs, requirements and objectives, and financial situation;
has a fixed interest rate, a one-off establishment fee and no other regular monthly fee.
repayments on our MACC loans are affordable for the consumer without hardship.
the application process is online and can be completed quickly.
our contract documents are short, legible and easy to understand.
we provide ready access to online and telephone customer service.
4. Distribution Channels and Conditions
All our Distribution channels present the product appropriately to consumers as follows:
Our website which contains:
No misleading information
All relevant disclosures and warnings required by law;
An easy to follow application process during which the consumer is given informed choices at every stage;
All third party referrers are:
vetted before being allowed to present our product;
subject to regular monitoring;
required to enter into referral agreements with us.
We have adopted the following Voluntary Distribution Conditions to ensure that our product is distributed appropriately to its target market:
No loans to any customer whose net income is less than $600 a week ($1200 a fortnight).
No loans for the purpose of paying regular, ongoing ordinary household expenses such as utilities unless it is to pay accumulated arrears or unusually high amounts due to special circumstances.
No loans for business purposes.
All our products are distributed in compliance with our responsible lending obligations.
5. Review Triggers
We will review this TMD if the following occurs in relation to this product:
The number of customers in default at the end of the year exceeds 100. The number of all complaints (whether referred to AFCA or not) from approved MACC loans is more than 50 higher than that for the previous year.
If the number of variations to payment schedules due to hardship is greater than 100 for the year.
The number of defaults or hardship applications before the first 3 scheduled payments for a loan at the end of the quarter exceeds 50.
Communication from the following external sources will be Trigger Events:
AFCA if either
Complaints resolved against us by AFCA increase by 5 in a three (3) month period; or
AFCA identifies a “systemic issue”;
ASIC if it identifies a systemic issue;
Community based consumer organisations if they raise a systemic issue.
The responsible manager will collect, assess and review all the above data every three (3) months. If any of the above Trigger Events occur, this will trigger a review as if it were a Periodic Review as below.
6. Periodic Scheduled Reviews
We will conduct Periodic Reviews every 36 months whether or not a trigger event has occurred in the previous quarter.
The responsible manager will conduct all reviews of this TMD.
The responsible manager will report to our board of directors within two weeks of conducting a review as to:
Whether any trigger events have occurred.
What factors may have caused these trigger events to occur including external factors not related to the design and distribution of our product such as seasonal variations.
Which of the follow actions we should take:
No change if all of our DDOs as published above are being met;
The product needs a redesign;
A new distribution condition is required; or
The product must cease to be offered.
7. Significant Dealings
If at any time, we detect that more than 50 consumers receiving our product within a three (3) month period are not within our Target Market, we shall report this to ASIC as a Significant Dealing within ten (10) business days.
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