Target Market Determination Higher Education Loans

for ZeeFi – Higher Education Loans Product issued by Nimble Australia Pty Ltd (ABN 91 135 501 807, Australian Credit Licence 386010) trading as ZeeFi.


1. About this document

This document is not intended to provide financial advice, customers should refer to the Terms and Conditions and any supplementary documents when making a decision about this product.

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

This document is not to be treated as a full summary of the product’s terms and conditions and it not intended to provide financial advice. Consumers must refer to the relevant Terms and Conditions and other Supplementary Documents which outline the relevant terms and conditions under the product when making a decision about this product.

Terms and Conditions to which this target market determination applies

This TMD applies to the Higher Education Loans Product referred to in the following Terms and Conditions: 

  • Loan Agreement
  • Terms and Conditions of Use

Date from which this target market determination is effective

19 January 2023


2. Class of consumers that fall within this target market

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

This Higher Education Loans 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). Accordingly, the Higher Education Loans Product is for consumers who:  

  • require a loan to assist with financing Higher Education Studies with Accredited Education Providers with ZeeFi because they are unable to pay the upfront costs of those studies;
  • require the flexibility of making additional repayments without penalty; and
  • require the flexibility to borrow some or all the course costs and only repay the amounts drawn down.

Product description and key attributes  

The key product attributes of this Higher Education Loans Product are:  

  • The amount that can be financed under the Higher Education product is between $2,001 and $50,000;
  • The loan term in which the student can repay the amount borrowed can be between 6-84 months;
  • Establishment fee of $200;
  • Monthly Account Keeping Fee of $0;
  • Arrears Fee of $25;
  • Interest rates are determined on a risk profiling basis. Students are provided with an outline of the interest rate applicable to their facility once approved. Students should consider whether the interest rate applicable to their facility is right for them;
  • Interest and payments are structured based on draw downs. Each time the student requests a draw down interest and payments are calculated on the amount outstanding and the remaining term;
  • There are no early repayment penalties for paying out the Higher Education Loans Product early;
  • The student can borrow some or all the course costs to enable them to participate in Higher Education studies;
  • The student accesses the money as needed and only needs to repay the amount borrowed. Each time the student increases their borrowing up to the approved Higher Education Loans Amount, ZeeFi will automatically adjust the repayments to make sure the student stays up to date and the loan is repaid on time;
  • The funds are released directly to the Education Partner to ensure the funds are used for the purpose in which they were intended (i.e., to pay for the costs of those Higher Education Studies);
  • The student identifies the Higher Education Course that is right for them, with any of our Accredited Education Partners.

The key eligibility requirements of this Higher Education Loans Product are:  

  • Be 18 years of age or older;
  • Be an Australian Citizen or Permanent Resident;
  • Be employed in a full-time, part-time, or casual job (minimum of 6 months);
  • Demonstrate serviceability of the loan facility;
  • Have a valid mobile telephone number and email address;
  • Have good credit without any adverse listings;
  • Have positive bank account conduct in the last 180 days; and
  • Be able to provide 6 months of bank statements

Objectives, financial situation, and needs  

This product has been designed for individuals who:  

  • require credit to fund Higher Education Studies of their choice with Accredited Education Providers;
  • wish to repay the loan over a 6–84-month period;
  • are able to provide ZeeFi with sufficient financial evidence of their ability to be able to service the loan; 
  • are able to pay the associated fees and charges;
  • require a loan to finance Higher Education Studies, which will allow them to:
    • Increase their existing skill set in an area of study of interest to advance their career opportunities or advance their understanding in the chosen study area;
    • Learn new skill sets that are of interest to the student for further career development or advancement or to further strengthen their skills and interests in a specific area; and
    • Obtain the necessary credentials, skills and understanding to change their career direction, strengthen their career progression or explore potential education fields of interest.

Excluded class of consumers 

This product has not been designed for individuals who:  

  • Are bankrupt, or a participant in a Part IX or Part X Agreement;
  • Have bad credit or adverse credit behaviour;
  • Income source is solely Centrelink (with exception to Disability Support Individuals);
  • Are unemployed;
  • Expect their financial circumstances to change in the future;
  • Are under the age of 18; or
  • Are not an Australian Citizen or a Permanent Resident.

Consistency between target market and the product   

This product (including its key attributes) has been assessed as meeting the likely objectives, financial situation and needs of consumers in the target market because it provides them with access to Higher Education Studies with Accredited Education Providers by financing the associated upfront costs and spreading it over a fixed term. 


3. How this product is to be distributed

Distribution channels

This product is designed to be distributed through the following means: 

  • Direct: Online via the ZeeFi website or by contacting ZeeFi Pty Ltd Sales & Support Team via 1800 324 909; and
  • Third Party: Via authorised representatives of Accredited Education Partners of ZeeFi.

Distribution conditions and restrictions

This product should only be distributed under the following circumstances: 

  • To individuals who meet the eligibility requirements;
  • To individuals who have the appropriate borrowing capacity and in accordance with the Responsible Lending Guidelines of ZeeFi;
  • To individuals who fall within the target market;
  • All applications must be submitted through the ZeeFi Application and Lending Platforms or via platforms provided to Distributors by ZeeFi from time to time;
  • This product is only available to consumers within the Education Sector;
  • Distributors other than ZeeFi as the Distributor must be accredited by ZeeFi
  • Accredited Distributors (Education Providers) who lose their accreditations for any reason are prohibited in providing any ZeeFi Product without the written consent of ZeeFi or its Representatives. 

Adequacy of distribution conditions and restrictions  

This product has been designed for a specific segment of consumers. Distributors following the Distribution Conditions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed for. 

The distribution channels are appropriate because:

  • our distributors have been adequately trained and have the necessary skills and knowledge to distribute this product in accordance with the TMD;
  • our application and approval process has controls in place to ensure all approved consumers meet our eligibility and lending requirements; and
  • we conduct upfront and ongoing review and monitoring of distributors and distribution conditions and restrictions.


4. Reviewing this target market determination 

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

Where a review trigger has occurred, this target market determination will be reviewed within 10 business days. Meanwhile, we will cease to offer this product to our consumers until our review concludes and any necessary changes to the product or target market determination, including distribution methods, are made.

Initial review Within 12 Months of the effective date. 
Periodic reviews At least every 12 months from the initial review.
Review triggers or events The following events or circumstances arise that would suggest the TMD is no longer appropriate:   
  • a material change to the design or distribution of the product, including related documentation;
  • a significant dealing of the product to consumers outside the target market occurs;
  • distribution conditions and restrictions are found to be inadequate;
  • external events such as adverse media coverage or regulatory attention suggest that the target market for the product might not be appropriate; or
  • there is a significant change in product related metrics, including, but not limited to:
    • increased complaints;
    • changes to ZeeFi’s Credit Risk Appetite and/or any change to the sector in which ZeeFi offers this product;
    • high rates of default; or
    • high rates of hardship applications.


5. Reporting and monitoring this target market determination

The following information must be provided to ZeeFi by our distributors:

Type of Information Description Reporting Period
Specific Complaints Written details of the complaint, including name and contact details of complainant and substance of the complaint. As soon as practicable and in any case within 10 business days of receipt of complaint.
Complaints Number of complaints. Every 3 months.
Significant dealings Any significant dealing which is not consistent with this TMD. As soon as practicable, and in any case within 10 business days of becoming aware.
Other information required  Other distribution information may be required from Distributors such as transaction data, outcomes from sales monitoring, notes and phone recordings relating to those dealing  Within 10 business days of a reporting period, when requested.