For Citro Account and Citro Card 

Target market determination

Retail individual

December 2023

Version 2.0

Issued by Hay Limited ABN 34 629 037 403 Australian Financial Services Licence No. 515459

1. TMD for Citro Account and Citro Card

Target Market Determination
Citro Account and Citro Card
Non-cash payment product
Hay Limited ABN 34 629 037 403, AFSL 515459 (Hay)
Start Date:
February 2022 – the date the determination was made for the Hay issued Non-Cash Payment product 
Review Date:
September 2023
TMD for Citro Account and Card
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 maintain this product. To qualify, the Retail Individual must:
§ Be an individual person; and
§ Have a valid Australian residential address: and
§  Be aged 40 years or older; or
§ Be an employee of Citro or any of its related body corporates.

Objectives & Needs
This product is targeted at Retail Individuals with the likely objectives, financial situation and needs of wanting:
§  Access to a debit card to make purchases with an internationally branded scheme such as Visa.
§  To store money in an account without the ability to access interest on their balance.
§ To manage access to funds available in the account or on the account through spend limits, merchant blocking and card management.
Financial Situation
§  At the time of application, the RetailIndividual has the right to open a Non-Cash Payment product and has access and the ability to transfer funds in Australian dollars to preload the facility and pay fees.
Product Description:
This describes the non-cash payment product.
§  A Non-CashPayment Product issued by Hay Limited is a fully digital transaction account that allows the Retail Individual to access their funds on demand.
individuals cannot
§  Access is only possible through card, app, BSB and Account number and does not have a physical presence. Retail Individuals cannot make cash deposits or other withdrawals from the account via a physical branch except by using a card at an ATM where Visa Debit cards are accepted.
deposited in
§  No interest can be earned on the funds deposited in the account.
§  Overdrawing the account is not permitted,
§  There are spend control and merchant category code limitations:
o The card program prohibits spending at unsuitable or inappropriate merchants for the Target Market to reduce harm.
o The card program has limits in place for the account balance and daily spending.
o  Account owners can further restrict spending by a merchant to customise the product to suit their needs.
o The account owner can impose daily or weekly spending limits to suit the product to their needs.

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 fund the account to save and or spend those funds through a Debit card accessing the Visa network or through a BSB and Account number via Direct Entry or NPP; and
§ Retail Individuals can manage access to the funds through spend limits, merchant blocking and card management.
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 reloadable Non-Cash Payment Product in Australia.
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 general product advice:
§ through the Citro website and Citro App;
§ 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 including associated disclosure documents in or around May for consultation and implementation by July.

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.