Target Market Determination

This document is published by Hardship Hub Pty Ltd (ACN 695 494 181) in accordance with the Design and Distribution Obligations (DDO) in Part 7.8A of the Corporations Act 2001 (Cth) and ASIC Regulatory Guide 274.

Draft status: this Target Market Determination is a working draft held for review by our legal counsel and will take effect once the associated Australian Credit Licence and AFCA membership are in place. The product described is not yet available to consumers. For launch readiness status, contact compliance@hardshiphub.com.au.

1. Product covered by this TMD

2. The target market

2.1 Consumers this product is designed for

The Temporary Hardship Plan is designed for consumers who:

• Are Australian residents aged 18 or older.
• Have one or more unsecured consumer debts they are struggling to meet.
• Are experiencing a short-term, identifiable change in circumstances — for example, loss or reduction of income, medical events, relationship breakdown, natural disaster, death in family, or domestic violence — that has temporarily reduced their ability to meet unsecured repayments.
• Have a realistic prospect of returning to their original repayment schedule, or of transitioning to a longer-term arrangement, within approximately 3 months.
• Have sufficient income (including government support) to afford a reduced consolidated monthly payment after essential living expenses (per the Household Expenditure Measure benchmark) and secured-debt repayments.

2.2 Needs the product is intended to meet

• A single coordinated point of contact for multiple unsecured creditors.
• Temporary relief from the ordinary repayment schedule on unsecured debts.
• A calculated, sustainable monthly payment split proportionally across participating creditors.
• Consumer-friendly communication with creditors on the consumer’s behalf.

2.3 Consumers this product is NOT designed for

The Temporary Hardship Plan is not suitable for consumers who:

• Need assistance with debts we don’t cover — Australian Taxation Office (ATO) debts, court-ordered debts, child support, HECS / HELP loans, or secured debts like mortgages or car finance.
• Are in long-term, permanent financial hardship with no realistic prospect of recovery within 3 months. These consumers may be better served by a free financial counsellor (National Debt Helpline on 1800 007 007), a formal debt agreement under Part IX of the Bankruptcy Act 1966 (Cth), or bankruptcy advice.
• Have insufficient income, even after a reduced hardship payment, to meet the Household Expenditure Measure for essential costs plus any secured-debt repayments. In these cases, creditor hardship applications or external dispute resolution may be more appropriate.
• Are seeking new credit or a loan. The Temporary Hardship Plan is not credit and does not extinguish, reduce, or forgive any debt.
• Are not Australian residents or are under 18 years of age.

3. How this product is consistent with the target market

The key attributes of the Temporary Hardship Plan — a 3-month term, a consolidated monthly payment, coverage of unsecured debts only, a budget sized to income minus HEM minus essential costs minus secured repayments, and a no-credit-check application — are consistent with the needs of consumers experiencing short-term hardship and inconsistent with long-term insolvency situations.

4. Distribution conditions

4.1 How the product may be distributed

• Direct to consumer via the Hardship Hub website.
• Through partners or referrers who agree in writing to our distribution conditions.

4.2 Conditions applied

• Consumers must complete our eligibility assessment (the online application) before a Temporary Hardship Plan can be established.
• No distribution via high-pressure sales, unsolicited outbound calls, or targeted advertising that emphasises avoiding repayment obligations.
• Partners must provide the consumer with direct access to our application — no intermediated forms that collect different data.
• Partners must not represent the product as a loan, debt forgiveness, or debt consolidation in the conventional sense. It is a hardship arrangement.

4.3 Why these conditions make distribution consistent with the target market

The application’s eligibility assessment (income vs HEM, unsecured-debt threshold, hardship event capture) is the primary mechanism for matching consumers to the target market. Restricting distribution channels and representations prevents the product from reaching consumers for whom it isn’t a good fit (for example, consumers who need long-term insolvency support) and prevents misrepresentation.

5. Reviews of this TMD

• First review: 12 months after the effective date.
• Periodic reviews: every 12 months thereafter.
• Review triggers— we will review this TMD before the next scheduled review if any of the following occur:
  • A material change in the product (fees, term, eligibility).
  • A material change in the market or consumer behaviour.
  • A significant dealing outside the target market identified during monitoring or reported to us.
  • Regulatory guidance or a regulator direction suggesting the TMD is inadequate.
  • A sustained rise in complaints, especially complaints indicating the product was unsuitable for the consumer.

6. Reporting to us

6.1 Significant dealings

Distributors must report any significant dealings in the Temporary Hardship Plan that are inconsistent with this TMD to us within 10 business days of becoming aware of the dealing.

6.2 Complaints

Distributors must report all complaints received about the Temporary Hardship Plan to us on a monthly basis. Consumers may complain directly via our Feedback & Complaints process, including free escalation to the Australian Financial Complaints Authority (AFCA).

6.3 Information to assist our reviews

On request, distributors must provide us with information reasonably required to assess whether the product is reaching the target market — including number of applications, application-to-plan conversion, reasons for rejection, and demographic information within Privacy Act limits.

7. Related documents

• Terms of Service— the contract you sign to use the product, including fees, cancellation, and direct debit.
• Privacy Policy— how we handle your personal information, including overseas disclosure (APP 8) and credit reporting.
• Feedback & Complaints— how to raise a concern and how to escalate free of charge to AFCA.

8. Contact

• Compliance & TMD queries: compliance@hardshiphub.com.au
• General support: support@hardshiphub.com.au
• Complaints: see our Feedback & Complaints page.