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Plico

Target Market Determination

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 Issuer:
Plico Energy Personal Loans are issued by CEPCO 2022 Pty Ltd (ABN:73 664 797 102) pursuant to a servicing agreement with Allied Financial Consulting Pty Ltd (ABN: 86 059732 419) (Australian Credit Licence #393845). 
 Effective Date:
31 October 2024
 Product:
Plico Energy Personal Loan. A Plico Energy Personal Loan is primarily a 10-year secured personal loan which allows consumers to finance the installation of solar panels and/or battery systems at their residential premises (Premises). 


1. About this Target Market Determination (TMD): 

This TMD seeks to offer consumers and staff with an understanding of the class of consumers for which this product has been designed, having regard to the objectives, financial situation and needs of the target market. 

This TMD is not to be treated as a full summary of the product’s terms and conditions and is not intended to provide financial advice. Consumers must refer to the Product Terms and Conditions and any supplementary documents which outline the relevant terms and conditions under the product when making a decision about this product. 

2. Target Market

The information below summarises the overall class of consumers that fall within the target market for the Product, based on the key attributes and the objectives, financial situation and needs that it has been designed to meet. 

The Product has been designed for consumers whose likely objectives, financial situation and needs(as listed below) are aligned with the Product (including the key attributes). The Product is for consumers who are seeking an affordable finance solution which enables them to pay for goods and services over time and to make their home more sustainable.

The typical consumer base is any homeowner, businessowner or long-term house occupier located in either the South West Interconnected System in Western Australia(SWIS)or in Melbourne, Victoria. In the future the Issuer may expand in to other Australian state or territories, focusing on the National Energy Market.   

2.1 Objectives, financial situation and needs

The Product has been designed for consumers with the following objectives and needs:

  1. wanting to install a solar (photovoltaic) and/or battery system on their Premises that generates and stores clean energy, to help satisfy the customers objectives to be greener and/or more sustainable;
  2. looking to finance the supply and installation of a solar (photovoltaic) and/or battery system at their Premises;
  3. wanting to split the cost of a solar (photovoltaic) and/or battery system over weekly repayments via a secured personal loan.

2.2 Excluded class of consumers

This Product has not been designed for individuals who:

  1. do not meet the Product eligibility requirements;
  2. do not have an ability to make all payments as and when they become due;
  3. are in financial hardship, are currently or previously bankrupt or have a court judgment against them;
  4. do not want to enter into a secured personal loanwitha10-year repayment term to acquire solar(photovoltaic) and/or battery system;
  5. require a variable interest rate or interest free facility;
  6. want a line of credit facility, the ability to redraw funds or access to cash;
  7. want to secure the loan with an asset;
  8. do not want to engage Starling Energy Group as a contractor to install the solar panels and/or battery systems;
  9. do not want to be a member of (DCEP Incorporated), a not-for-profit association that all Plico members are part of; and
  10. do not own the home or property or have the landowner’s permission to install solar and/or battery system.

3.Eligibility requirements

To be eligible for the Product, consumers must meet the following criteria:

  1. be an individual over 18 years of age;
  2. be employed, self-employed, retired or a pensioner; 
  3. have their identity successfully verified by the Issuer;
  4. have an Experian credit score of at least 700;
  5. not be a current or prior bankrupt or have a court judgment against them;
  6. be the homeowner or occupier with landlord’s authorisation to install solar and/or battery system;
  7. hold an Australian phone number and a Western Australian or Melbourne, Victoria address for installation of the solar and/or battery system
  8. be a party to, or agree to become a party to, a Virtual Power Plant Service Agreement with the Issuer; and
  9. be able to make the repayment amounts in accordance with the repayment schedule without missing or experiencing hardship. 

4. Key attributes of the Product

The key attributes of the Product are as follows:

  1. no annual fees;
  2. fixed weekly repayments (subject to Consumer Price Index adjustment annually);
  3. ability to apply as a single or joint applicant;
  4. primarily a 10-year term, but could also be 4, 5 or 7 year terms;
  5. ongoing customer service support;
  6. financing available for amounts ranging from $5,001 to a maximum of $66,400.
  7. ability to end the agreement, at any point in time over the 10-year contract by buying the system outright. No fees or penalties are associated with this, and the buyout amounts stated in the contract decrease annually over the life of the contract;
  8. ability to potentially participate in the Plico Virtual Power Plant and make small amounts of passive income for customers; and
  9. ability to pay instalments weekly, fortnightly, monthly or quarterly.

5. Consistency between target market and the Product

The Issuer has assessed the Product and formed the view that the Product, including its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market, as described above due to the fact that:

  1. the Product has been designed for consumers who:
    1. want to install a solar (photovoltaic) and/or battery system at a Premises they own or they occupy with landlord’s authorisation; and
    2. are over the age of 18 and have the means to make the repayments in accordance with the repayment schedule; and
  2. the Product primarily has 10-year repayment terms with no upfront or annual fees, its design is otherwise consistent with the target market.

6. How this Product is to be distributed

6.1 Distribution channels

The Product is designed to be distributed by Starling Energy Group Pty Ltd trading as Plico Energy (Plico Energy) (as a credit representative of Allied Financial Consulting Pty Ltd) via its website, social media channels and sales staff. 

Sales staff are required to:

  1. undertake training prior to assisting consumers;
  2. staff are monitored by senior management to ensure they comply with training;
  3. follow all documented procedures;
  4. ask knockout screening questions before an application is commenced to ensure that a consumer is within the target market set out in this TMD.

The Issuer considers this is an appropriate distribution channel because of the broad nature of the target market and the requirement for all sales staff to have the necessary training, skills and knowledge to assess whether the consumer is within the target market. 

6.2 Distribution conditions and restrictions

The Product can only be distributed by Plico Energy:

  1. to consumers who meet the eligibility requirements of the Product;
  2. to consumers who have appropriate borrowing capacity;
  3. in accordance with responsible lending guidelines and the Issuer’s product and process requirements.

6.3 Adequacy of distribution conditions and restrictions

The Issuer has concluded that the distribution conditions and restrictions will make it likely that a consumer who acquires the Product will be in the target market. This is based on an assessment of the distribution conditions and the appropriateness of them to assist distribution being targeted towards the class of consumers within the target market.  

7. Reviewing this target market determination

We will review this target market determination in accordance with the below:

Initial Review Within 6 months of the date of this TMD
Periodic reviews At least every 12 months from the last review
Review triggers or events
Any of the below triggers may suggest that this TMD is no longer appropriate and a review of the TMD is to be undertaken:
(a) a material change to the design of the Product or the terms and conditions of the Product;
(b) occurrence of a significant dealing, including when distribution occurs outside the target market;
(c) repetitive and/or systemic complaints of the same type about the Productor a feature of Product;
(d) the number of hardship applications and/or complaints exceeds 1% of total customer base;
(e) the distribution conditions are found to be materially inadequate;
(f) external events such as material adverse media coverage or regulatory attention; and
(g) significant changes in metrics, including but not limited to:
  • more than 1.5% consumers default in a year; and
  • a material increase (1% increase or 100 basis point in the RBA Cash rate in a 12-month period)in the interest rate being charged; and
  • sales volumes have doubled above targets.

Reviews to be completed within 10 business days of the identification of a trigger event.  

8. Reporting and monitoring this target market determination

The Issuer collects the following information from Plico Energy in relation to this TMD: 

Specific complaints Details of any complaints in relation to the Product covered by this TMD as soon as practicable and within 5 business days of receipt of the complaint. This will include written details of the complaint, including the complainant’s name and contact details and a summary of the substance of the complaint.
General information about complaints Plico Energy will report in writing the number of complaints, channel it received the complaint and general feedback relating to the Product and/or performance of the Product covered by this TMD. This information is reported by Plico Energy to Allied Financial Consulting Pty Ltd and the Issuer in writing every 6 months.
Significant dealings Plico Energy will report to Allied Financial Consulting Pty Ltd and the Issuer in writing if it becomes aware of a significant dealing in the Product that is not consistent with this TMD as soon as practicable, and in any case within 10 business days after becoming aware of the significant dealing in the Product.