Target Market Determination

About this Document

This target market determination (TMD) sets out who the FG Finance Limited Insurance Premium Funding Loan (the "product") is designed for — the group of consumers whose objectives, situation and needs it suits — along with how it should be distributed and when we'll review it.

This document is intended for, and is of specific relevance to, consumers in New Zealand obtaining funding for insurance policies taken out for personal, domestic, or household purposes, including but not limited to domestic motor vehicle, household, travel, personal accident insurance, and residential strata policies.

About the Product

The Insurance Premium Funding Loan is a fixed-rate, simple-interest credit facility that pays an insurance premium upfront so a consumer can repay it over regular monthly instalments, instead of paying for personal, domestic or household cover in one lump sum.

Target Market Suitability

It suits consumers who'd rather spread an insurance premium across fixed instalments than pay it all at once, and who don't need to put up cash or other assets as security — the loan is secured against the policy rights instead.

Class of consumers in the Target Market:

• Acquiring a cancellable insurance policy for which they are the policy holder(s) under New Zealand insurance guidelines.
• Wishing to finance 100% of the insurance premium payable under their insurance policy with a policy period of up to 12 months.
• Have sufficient steady income or financial resources to meet all regular monthly instalments, fees, and charges under the loan.
• Are prepared to assign their rights under the insurance policy as security (e.g. assigning the refund of premium upon early cancellation of the policy to the lender in the event of default).

Excluded Consumers

It isn't designed for, and won't suit, consumers who:

• Want to pay for their insurance policies in one upfront lump sum.
• Are not the policy holder of the underlying insurance policy.
• Are seeking general-purpose finance, personal loans, or funding for purposes other than paying insurance premiums.
• Do not have the financial capacity to meet the regular instalment payments.

Key Product Attributes

Key features of our premium funding loans:

• Short term: matched to the length of the funded policy — usually 6, 8, 10 or 12 months.
• Monthly instalments: repaid in equal monthly amounts, normally by direct debit through the New Zealand banking system.
• Initial payment: a deposit or first payment must clear before the loan is finalised.
• Policy-secured: if the borrower defaults, the balance is recovered from any premium refund or claim proceeds due under the policy.

Distribution Channels and Conditions

To keep the product reaching the right consumers, these distribution conditions apply:

• Through brokers only: the product is offered solely through licensed New Zealand insurance brokers who are approved FG Finance partners. We don't sell to the public directly or give personal financial advice.
• Broker portal: applications come through our secure broker platform (crm.fgfinance.co.nz), which checks eligibility, policy validity and suitability as details are entered.
• Broker responsibilities: brokers must make sure their clients understand that the policy rights are assigned to us as security.

Review Triggers and Timing

We keep this TMD under review to make sure it stays fit for purpose. We'll start a review whenever any of these triggers happen:

• A material change to the product design, pricing structure, or terms and conditions.
• Systemic complaints from consumers or brokers indicating the product is not meeting customer needs or is causing financial detriment.
• An elevated rate of early defaults or cancellation requests.
• Significant regulatory feedback, guidelines, or warnings regarding premium funding practices in New Zealand.
• Significant dealing in the product outside the defined target market.

Timing: we'll carry out an initial review within 12 months of the effective date, then at least every 2 years. If a trigger event occurs, we'll review this TMD within 10 business days.