Target Market Determination: Float Forward Personal Loan

1. About this Target Market Determination

This Target Market Determination (TMD) is prepared and issued by Float Payments Pty Ltd (Float) in accordance with the design and distribution obligations (DDO) set out in Part 7.8A of the Corporations Act 2001 (Cth), as applied to credit products by section 12DAB of the Australian Securities and Investments Commission Act 2001 (Cth).

The purpose of this TMD is to describe the class of consumers for whom the Float Forward Personal Loan has been designed and is likely to be appropriate, having regard to the consumers’ likely objectives, financial situation, and needs. This TMD also sets out the conditions and restrictions on the distribution of this product, the events and circumstances that would require a review of this TMD, and the reporting obligations of persons who distribute this product.

This TMD is not a product disclosure document, credit guide, or credit contract. Consumers should refer to the applicable credit contract, pre-contractual disclosure documents, and credit guide before making a decision about whether to apply for this product.

Regulatory reference: ASIC Regulatory Guide 274 (Product design and distribution obligations); ASIC Regulatory Guide 209 (Credit licensing: Responsible lending conduct); National Credit Code Part 2, Division 4A (Medium amount credit contracts).

2. Product Description and Key Attributes

The Float Forward Personal Loan is a medium amount credit contract (MACC) issued by Float under Australian Credit Licence 561664. The key attributes of the product are set out below.

2.1 Risk-Based Pricing Tiers

Float uses a risk-based pricing model that assesses each applicant against three pricing tiers. The tier assignment is determined by a combination of credit bureau data, analysis of the bank statements and transaction data the applicant provides, and Float’s proprietary behavioural scoring. The applicable pricing tiers for Float Forward are:

The interest rate offered to a consumer reflects their individual risk assessment at the time of application. Rates are fixed for the duration of the contract.

3. Target Market

3.1 Description of Target Market

This product has been designed for, and is likely to be consistent with the likely objectives, financial situation, and needs of, consumers in the target market described below.

3.1.1 Consumer Objectives

The Float Forward is designed for consumers whose objectives include:

• Funding a planned or semi-planned personal expense such as vehicle repairs, medical or dental costs, education fees, relocation costs, or home improvements
• Consolidating two or more existing small credit obligations into a single, structured repayment plan at a lower effective cost

3.1.2 Positive Target Market

This product is likely to be appropriate for consumers who meet all of the following criteria:

• Individuals aged 18 years or older who live in Australia and are Australian citizens, permanent residents, or holders of a long-term Australian visa with the right to work
• Consumers who have a demonstrated capacity to repay from regular income (employment, self-employment, government benefits, or a combination)
• Consumers seeking fixed, predictable repayment obligations over a defined term
• Consumers who value a fully digital application and servicing experience
• Consumers who may be underserved by traditional bank lending, including self-employed individuals, gig and platform workers, new migrants to Australia, and those with limited or impaired credit histories
• Consumers who require credit between $2,001 and $5,000 and prefer a fixed interest rate product with predictable repayments
• Consumers who have the capacity to sustain repayments over a 12 to 24 month period
• Consumers who have been assessed at one of Float's three risk-based pricing tiers and understand the applicable interest rate

3.1.3 Negative Target Market

This product is unlikely to be appropriate for consumers who meet any of the following criteria:

• Consumers who do not have a regular or reasonably predictable source of income
• Consumers who are currently bankrupt or subject to a debt agreement under Part IX or Part X of the Bankruptcy Act 1966 (Cth)
• Consumers for whom the proposed repayments would cause substantial hardship
• Consumers who require funds for business or investment purposes (this is a personal credit product regulated under the NCCP Act)
• Consumers who have indicated they do not understand or do not accept the total cost of credit
• Consumers who require credit of $2,000 or less (these consumers should be assessed for Float Bridge)
• Consumers who require credit exceeding $5,000 (these consumers should be assessed for Float Ascend)
• Consumers who require a loan term shorter than 12 months or longer than 24 months
• Consumers who are unable to meet the responsible lending assessment criteria under Part 3-2 of the NCCP Act

3.1.4 Consumers for Whom this Product is Clearly Not Suitable

This product must not be distributed to:

• Consumers with no assessable income
• Consumers under 18 years of age
• Consumers seeking credit for speculative or investment purposes
• Consumers who would need to forgo essential living expenses to meet repayments

3.2 How the Product’s Key Attributes Are Consistent with the Target Market

Float Forward is a medium amount credit contract with fixed interest rates, risk-based pricing, and regulatory cost caps. These attributes are consistent with the target market because:

• The loan amounts ($2,001 to $5,000) and terms (12 to 24 months) align with the objectives of consumers who need to fund a planned personal expense or consolidate smaller obligations over a manageable period.
• Fixed interest rates provide cost certainty and support budgeting, which is important for consumers in the target market who may have variable income patterns.
• Risk-based pricing across three tiers ensures the cost of credit reflects the individual consumer's credit profile, rather than applying a flat rate that would over-charge lower-risk borrowers or exclude higher-risk borrowers entirely.
• The annual cost rate cap (48% statutory; 45% Float internal policy ceiling) provides a safeguard against excessive total cost of credit.
• Comparison rate disclosure enables consumers to compare the total cost of this product against alternative credit products in the market.

4. Distribution Conditions and Restrictions

The following conditions and restrictions apply to the distribution of Float Forward. Distributors must comply with these conditions at all times.

4.1 Distribution Conditions

4.2 Distribution Channels

Float Forward may be distributed through the following channels only:

• Float's website via the direct online application process
• Float's installable web app

Distribution is limited to Float’s direct digital channels.

5. Review Triggers and Review Period

5.1 Review Triggers

This TMD will be reviewed if any of the following events or circumstances occur:

• A significant dealing in the product that is not consistent with this TMD
• A significant number of complaints received from consumers in relation to this product
• Material changes to applicable legislation, including amendments to the National Credit Code, the NCCP Act, or ASIC regulatory guidance affecting the design or distribution of this product
• A determination or finding by ASIC, AFCA, or a court that indicates the product (or a materially similar product) is causing consumer detriment
• A material change to the product's terms, pricing, fees, or eligibility criteria
• Material changes to the economic environment or credit market conditions that may affect the suitability of this product for the target market (for example, significant changes to the cash rate, unemployment rate, or cost of living indices)
• A material change to Float's credit assessment methodology, risk-based pricing model, or data sources used in underwriting decisions
• Any event or circumstance that would reasonably suggest this TMD is no longer appropriate for the product
• Changes to the MACC-specific provisions of the National Credit Code, including the establishment fee cap under s.32B or the annual cost rate cap under s.32A

5.2 Review Period

In addition to the review triggers specified above, this TMD will be reviewed:

• Initial review: within 12 months of the date of issue.
• Ongoing reviews: at intervals not exceeding 12 months from the date of each preceding review.
• Ad hoc review: promptly upon the occurrence of any review trigger described in section 5.1.

Where a review trigger occurs, Float will review this TMD as soon as practicable. If the review is not complete within 10 business days after Float first knew of the trigger, Float will stop distributing this product until the review is complete and, if this TMD is no longer appropriate, a new TMD has been made.

6. Reporting Requirements

6.1 Distributor Reporting Obligations

Persons who distribute Float Forward must provide the following information to Float:

6.2 Float’s Monitoring

In addition to distributor reporting, Float will monitor the following data on an ongoing basis to assess whether this product is being distributed consistently with this TMD:

• Application approval rates and decline reasons, segmented by distribution channel
• Consumer default rates and hardship application rates within the first 90 days of the contract
• Consumer complaints data, including trends in complaint type and volume
• Internal compliance audit findings relating to the product or its distribution
• Any significant dealing that is not consistent with this TMD, which Float will notify to ASIC in writing as soon as practicable and in any case within 10 business days after becoming aware of it
• Data from the bank statements and transaction data applicants provide, including indicators of financial stress at the point of application

7. Approval and Governance

This TMD is a regulatory document prepared for the purposes of the design and distribution obligations under Part 7.8A of the Corporations Act 2001 (Cth), and is published on our website in accordance with those obligations. It does not constitute financial product advice.

Document reference: TMD-FORWARD-1.0-28September2026