Target market determinations.
What is a TMD?
A TMD describes the group and categories of customers that the product is targeted at and any conditions around how the product is distributed to customers. It also describes the events or circumstances where Klarna is required to review the TMD.
Why is a TMD required?
A TMD is required in order to make sure customers are at the centre of Klarna’s approach when designing and distributing products and payment methods to consumers. The below demonstrates how Klarna has assessed the design, availability, review and improvement of the product in question.
Pay in 4 TMD
Pi4 is targeted at consumers who want to purchase goods and services online or in-store, and for which the consumer would like to defer and split their payments into four instalments. It is a short term deferred credit option that allows consumers to spread the cost of what they love to buy, and try them out first prior to having to pay the full price. Consumers may have an objective of using a short-term, low value credit facility to assist with managing their cash flow and unexpected expenses between pay cycles.
Pi4 can only be accessed by individual consumers who:
- Are at least 18 years old.
- Have an Australian residential address, as Klarna is intended for customers living in Australia.
- Have been properly identified in accordance with applicable anti-money laundering rules.
- Have provided a valid email address and phone number for us to communicate through.
- Have a financial situation which meets Klarna’s credit assessment criteria based on internal Klarna information and third party data. This excludes customers in recent hardship, bankruptcy and customers who have too much outstanding debt with Klarna.
- Meet the Klarna product usage criteria, such as not having too much outstanding debt, inappropriate usage of Pi4, or previously not repaying a Klarna purchase.
Key features of Pi4
- Allows the customer to split a purchase in four fortnightly instalments, with approximately one fourth of the purchase price paid upfront.
- The first instalment may vary slightly from the other three instalments based on rounding when the purchase is divided into four, this will only be by a matter of cents.
- The downpayment feature allows a customer to purchase an item outside of their credit limit, by allowing them to pay some of their purchase upfront. The amount paid on the first instalment is a combination of the regular payment should they have taken up an amount within their credit limit and the excess value of the purchase.
- No interest or fees apply. However, Klarna may charge a late fee if the customer is late on an instalment. A customer who has a payment outstanding will be blocked from making a subsequent purchase. A failed payment attempt will also impact their spending limit.
- Customers can, through the Klarna app, manage their post purchase experience, with features such as; i) Changing funding source, ii) Paying off instalments early, iii) Extending the instalment plan for a small fee, and iv) Reporting problems and returns.
- Customers can contact Klarna’s Customer Service to discuss their repayment plans if they are having trouble repaying.
Why Pi4 is likely to be consistent with the objectives, financial situation, and needs of the Target Market
- Pi4 allows the Target Market to fulfil its objective of deferring their purchase of goods or services with safety and confidence by borrowing only the amount necessary to buy the goods or services.
- The flexibility to pay off instalments early or extend them provides an additional layer of safety in the event a customer’s financial situation changes.
- Customers can only use Pi4 if they are accepted by Klarna’s credit and identification criteria.
- Choosing Klarna as their payment method when they check out on a seller’s website; or
- Downloading the Klarna app.
- Sellers accepting Klarna as a payment method online or in store who also promote Pi4 directly to their existing customers (Seller Distributors); and
- Businesses other than Seller Distributors that present the option to pay with Pi4 to their customers, and who may also promote Pi4 (Channel Partners).
Klarna applies operational controls to make sure that Pi4 is primarily distributed within the Target Market. These include:
- All sellers who accept Klarna as a payment method, including Seller Distributors, must pass through anti-money laundering and counter-terrorism financing, and underwriting processes.
- The seller does not control whether a purchase is accepted - only Klarna does.
- The Klarna app blocks certain industries, including firearms and weapons, adult services, casinos and online gambling.
Klarna implements legal obligations in its agreements with Seller Distributors and Channel Partners who engage in Pi4 distribution activities to ensure that reasonable steps are taken so that their distribution remains consistent with this TMD.
Klarna views the above distribution conditions as appropriate and of a nature that makes it likely that Pi4 will be distributed to the Target Market given that:
- Klarna will technically control, and have oversight of, how Pi4 is promoted and issued, including that:
- Klarna staff are appropriately trained to discuss the features of Pi4 with customers;
- Sellers integrating Pi4 and Channel Partners must comply with their obligations under their agreement with Klarna; and
- Customers must satisfy Klarna’s eligibility criteria;
- Klarna has received a significant number of complaints from customers, which relate to the customer’s purchase or use of Pi4 and which shows that the TMD may no longer be appropriate for Pi4.
- A material incident or significant number of incidents has occurred, which relate to the customer’s purchase or use of Pi4 and which shows that the TMD may no longer be appropriate for Pi4.
- A significant increase in usage of Pi4 by customers who are outside the Target Market.
- The receipt of a product intervention power order or notice from ASIC requiring Klarna to immediately cease retail product distribution conduct in respect of Pi4.
- A material change of Pi4 or its terms and conditions, which would cause the TMD to no longer be appropriate for Pi4.
- Any other event or circumstance that Klarna views would materially change a factor taken into account in making the TMD.
- Notify Klarna as soon as practicable, and in any event within 10 business days of becoming aware of a significant adverse dealing in respect of a consumer using Pi4 in a manner not consistent with this TMD.
- Report to Klarna information about whether the distributor received complaints in relation to Pi4, and the number received. This may be done on a monthly or quarterly basis, depending on the distributor. Each report is due no later than 10 business days after the end of the relevant reporting period.