Small amount credit contract providers – DDO and ASIC enforcement

ASIC's enforcement in the small amount credit contract (SACC) space has continued, with its issue of an interim stop order preventing City Finance Lending Pty Ltd (City Finance) from issuing its SACC to consumers.

ASIC alleges deficiencies in City Finance's Target Market Determination (TMD). All SACC providers are required to issue a TMD to consumers. The TMD must provide consumers with information about:

• the class of consumers that form the target market for the SACC;
• specify any restrictions and conditions on the distribution of the SACC;
• specify review triggers that would suggest the TMD was no longer appropriate; and
• specify maximum review periods.

In the City Finance case, ASIC alleges that the TMD does not appropriately define the target market for City Finance's SACCs, including that the TMD did not: