Target Market Determination (TMD)

1. TMD for the Financial Wallet Account

Target Market Determination
Product: Financial Wallet Account
  Non-cash payment product
Issuer Hay Limited ABN 34 629 037 403, AFSL 515459 (Hay)
Start Date: June 2024
Review Date: June 2025
Target Market:

Class of retail individuals that comprise the target market for  the product.

Retail Individual Description:

This describes retail individuals in the target market.

Eligibility criteria for the product

Retail Individuals will need to satisfy specific eligibility criteria to open and maintain this product. To qualify, the Retail Individual must:

  • Be an individual person; and
  • Have a valid Australian residential address; and
  • Be aged 18 years or older

Objectives & Needs

This product is targeted at Retail Individuals with the likely objectives, financial situation and needs of wanting:

  •  Access to an account which can take in deposits from another bank account.
  • To store money in an account within a Digital Wallet, without the ability to access interest on their balance.
  • To be able to access the 3P Card Services Website ( or App offered by 3P Card Services to open the Financial Wallet Account.
  • To be able to fund a gaming wallet, which then allows the individual to be able to access gaming machines at select locations as prescribed by ALH (Australian Leisure and Hospitality Group Pty Ltd (ACN 133 770 162)) and receive proceeds of gaming activities from the gaming wallet.
  • To have limits set on the balances that can be held in the Account to support transactions in and out of the gaming wallet.
Financial Situation

  • At the time of application, the Retail Individual has the right to open a Non-Cash Payment product and has access and the ability to transfer funds in Australian dollars to fund the account, pay fees and transact.
  Product Description:


This describes the non-cash payment product.

  • A Non-Cash Payment Product issued by Hay Limited is a digital transaction account that allows the Retail Individual to access their funds on demand.
  • Access is only possible through the Digital Wallet  that will be provided to the customer. The Non-Cash Payment Product issued by Hay Limited will have a BSB and Account number, which allows the Retail Individual to transact on the account. The account will not be accessible via any physical locations neither can cash be deposited into the account.
  • No interest can be earned on the funds deposited in the account.
  • Overdrawing the account is not permitted.
  • There are limits in place for the account balance, deposits into and withdrawals from the account via New Payments Platform (NPP)/ Direct Entry (DE) channels.
Appropriateness Statement:

This explains why the

product is consistent with the target market’s likely

objectives, financial situation, and needs.

The issuer, Hay Limited, has considered that the product is likely to be consistent with the possible objectives, financial situation and needs of the Target Market as:

  • Retail Individuals can deposit funds into the Financial Wallet account from any bank account or withdraw funds from the account to any other bank account, via NPP/DE.
  • Towards funding or withdrawal, a BSB and Account number will be issued to them as part of the account opening process.
  • The balances in this Financial Wallet account can be utilized to fund their gaming wallet (issued by ALH, and which allows them to access gaming machines at select locations) subject to account balance and deposit/withdrawal limits.
  • The account can also accept and store proceeds from gaming activities.
  • The account cannot be linked to a Debit card and neither will it have access to any other features such as BPay.



Category Description  
Distribution Conditions:

The conditions and restrictions on the distribution of the product

Marketing and Promotion

This condition applies to marketing and promotional materials that describe the product

Condition 1

The authorised distribution partner must only market and promote the product as a Non-Cash Payment Product in Australia, which can be funded via transfers into the account.

This condition is suitable as the issuer has distributed this product using these methods, with limited risk to Retail Individuals.

Retail Product Distribution Conduct (other than Marketing)

This condition applies to all conduct (other than marketing), such as issuing, arranging, and providing disclosure material.

Condition 2

The authorised distribution partner must only engage in arranging, distribution and

providing factual product advice:

  • through the website;
  • to prospective Retail Individuals who meet Hay Limited’s eligibility criteria for the product; and
  • to issue a Non-Cash Payment Product to retail individuals after applying for and completing the application process.

This condition is suitable as the issuer has distributed this product using these methods, with limited risk to retail individuals.

Review Triggers:

The events and circumstances that would reasonably suggest the determination is no longer appropriate

The issuer, and any distributor of this product, must cease retail product distribution conduct in respect of this product when the issuer determines a material event or circumstance has occurred concerning:
Material Complaints Material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.
Product Performance Evidence, as determined by the issuer, of the product’s performance, in practice, may suggest that the product is not appropriate for the target market.
Distributor Feedback Reporting from distributors, or consistent feedback from distributors on the target market, suggesting that the determination may no longer be appropriate.
Substantial Product Change A significant change to the product features outlined in the product description will likely make the determination no longer appropriate for the target market.
A significant change to the product because of regulatory, legislative or code changes will likely result in the determination no longer being appropriate for the target market.
Significant Dealing A material pattern of dealings in the product or distributor conduct is inconsistent with the determination.
Annual Product Review Hay conducts an annual product review to ensure that the product and disclosures remain relevant and fit for purpose.
Notification from a Court or relevant regulatory authority A notification is received by Hay Limited from a Court or relevant regulatory authority requiring immediate cessation of product distribution or conduct concerning the product.
Review Trigger Information Reporting requirements The distributor of this product must provide the following information to Hay Limited within the below timeframes.
Product Complaints data Information relating to complaints received, including the number and complaint summary details by the distributor of this product and provided quarterly within ten days of the end of the Quarter.
Significant Dealings Any significant dealings of the product to retail individuals who are outside the target market. This must be provided as soon as practicable and no later than 10 business days after the distributor becomes aware of such dealings.