provided by RealPay Holdings Pty Ltd, trading as “Rello” (ABN 43 651 812 645) and its subsidiaries
Issue Date: 1 November 2021
Review Date: 1 November 2022
This target market determination (“TMD”) details a description of the likely objectives, financial situation and needs of consumers in the target market where the payment of marketing costs associated with selling a property is required to be paid upfront by the vendor.
Rello is a FinTech that provides real estate agencies and cloud-platforms with payment solutions including pay now, pay-in-instalments and pay later payment plans. Rello provides a payment plan option to defer the costs associated with selling a property which is distributed through third parties.
A description of the payment plan product for this TMD, including the key attributes and explanation of why the product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market is provided in this document.
This document is not intended to provide financial advice. It forms part of Rello’s design and distribution framework for the product.
This TMD applies to the payment and funding of marketing costs by Rello on behalf of a vendor, where the vendor agrees to defer the cost and in return agrees to pay from the sales proceeds.
Real estate agencies require vendors selling a home to pay marketing costs associated with selling their property at the time of entering into an exclusive agreement with a Listing Agent to sell their property. Rello provides the vendor the payment option to pay upfront or defer to settlement the payment of such marketing costs normally associated with listing and selling a property (“Payment Plan”).
1 November 2021 (the Effective Date).
The information below summarises the class of consumers that fall within the target market for this product, based on the key product attributes, the likely objectives, financial situation and needs that the product has been designed to meet.
Marketing costs, also referred to as vendor paid advertising (“VPA”) costs, are specific to the real estate industry, when a vendor (a seller of a residential real estate property) agrees to sell their property. VPA costs can include (i) property advertising and listing fees; (ii) property presentation and styling; and (iii) property improvement costs.
Under a pay later Payment Plan, Rello pays the agreed marketing costs amount for listing the property, to the Real Estate Agency. In exchange, the Vendor sells to Rello the right to receive an agreed amount form a share of the sale proceeds, which is paid to Rello at settlement of the property or on the release of the deposit, whichever is earliest.
Customers for this product are vendors who are selling residential real estate property and have signed an exclusive sales authority with a licensed real estate agency. The vendors wish to defer paying the costs of marketing their property, until the proceeds of settlement are available.
The pay later Payment Plan for marketing costs has been designed for vendors, that require a deferred payment option to fund their VPA to maximise the chance of achieving their target selling price (the Target Market).
A typical summary of VPA costs includes:
To be eligible for a Payment Plan to fund for Marketing Costs, a Vendor must;
Rello has concluded that this product is consistent with the likely objectives, financial situation and needs of individuals in the Target Market.
The value proposition for the Vendor includes:
A summary of terms which may apply to the product are set out below:
The pay later payment plan for Marketing Costs product is distributed by Rello via a licensed real estate agency (“Agency”).
Each distributor, an Agency is required to be onboarded with a Rello Account to use the Rello Platform and make available Rello’s products (“Payment Services”). Each Agency must satisfy our know-your-customer and AML/CTF requirements and any other checks we deem necessary.
Once onboarded, Rello provides the Payment Services to the Agency to make them available to their customers via API integration. Each Agency is provided with appropriate training to not make any false or misleading representation or statement about us or about the Payment Services.
Each Vendor is required to make their own assessment once agreeing to the VPA costs with their listing Agent whether to make an upfront payment of defer the costs associated with selling their property.
A vendor will receive SMS/email communication from the Listing Agent with a “Pay Now” and “Pay Later” payment option for marketing costs once they have secured an exclusive sales listing authority.
We have determined that the distribution conditions and restrictions will make it likely that consumers who open the product are in the class of consumers for which it has been designed. We consider that the distribution conditions and restrictions are appropriate and will assist distribution in being directed towards the Target Market for whom the product has been designed.
Rello has implemented the following monitoring program for the product which is designed to trigger a review of this TMD.
The features of the product, and this Target Market Determination, will be reviewed no later than 12 months after the date of this Target Market Determination, and thereafter annually each June to assess the product’s continued suitability for the objectives, financial situation and needs of vendors in the target market, including:
The following circumstances (review triggers) will trigger an earlier review of this Target Market Determination, and of the suitability of the product to the target market:
We will collect the following in relation to the TMD:
Rello will obtain quarterly reports from its distributors regarding any complaints made about this product, by vendors or potential users of the product.
A register will be maintained for all vendor complaints and will be shared as part of the quarterly review with each real estate agency.
We will report any significant dealings to ASIC within 10 business days of becoming aware of the dealing.
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© 2022 Rello. trading as Rello (ABN 43 651 812 645)
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