Target Market Determination 2023

Prepared and effective 30 September 2023

OzForex Limited, trading as OFX (“OFX”, “we” or “us”) is an issuer and distributor of financial products to retail and wholesale clients. We have prepared the following Target Market Determinations (“TMD”) for each of our financial products in accordance with the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act (Cth) 2019 (“Treasury Laws”).

The purpose of each TMD is to define a target market for each product. OFX is committed to taking steps to ensure each of its products is distributed by itself and other distributors in a way that is consistent with the intended target market and distribution conditions and reporting requirements outlined in the TMD.

Please note a TMD is not a Product Disclosure Statement (‘PDS’) and is not intended to provide financial advice. Any advice provided in this document is general advice only and the information in a TMD does not take into account the investment objectives, financial situation and needs of any particular person. We make no recommendation as to the merits of any financial product referred to. Please review our PDS and Financial Services Guide (‘FSG’) prior to making a decision. In addition, client specific terms and conditions will apply to any product issued to you.

OFX FINANCIAL PRODUCTS

Key Product Attributes

Spot Transfers

Key attributes:
- Send money and exchange currencies, electronically
- Exchange one currency for another at an agreed exchange rate (the ‘Spot Rate’) within 2 days of the transfer being booked
- Limited to pre-determined amounts, with no exposure to a fluctuating exchange rate
- Requires payment upon booking; and
- All payments made are fully deliverable (the cost of the transfer is locked in at the time of booking the transfer).

Forward Exchange Contract (‘Forwards’)

Key attributes:
- Send money and exchange currencies, electronically
- Exchange one currency for another at an agreed exchange rate (the ‘Forward Rate’), which may be better or worse than the Spot Rate when accounting for things such as interest rates, at some time up to 12 months into the future;
- Limited to pre-determined amounts, with no exposure to a fluctuating exchange rate
- Payment may be required in full or in part at the time of booking or in future, in advance of the date of transfer (the ‘Maturity Date’); and
- All payments made are fully deliverable (the cost of the transfer is locked in at the time of booking the transfer).

Options

Key attributes:
- Send money and exchange currencies, electronically;
- The right but not the obligation to exchange one currency for another at an agreed exchange rate (the ‘Strike Rate’), which may be better or worse than the Spot Rate when accounting for interest rates, at some time up to 12 months into the future;
- Both the desired exchange rate (‘Strike Rate’) and the date on which the client must make an election whether or not to Exercise the Option (‘Expiry Date’) are fixed (a “European” style Vanilla Option);
- Requires the payment of a fee (the ‘Premium’) upon booking; and
- Foreign currency exchange not exercised if Option not exercised.

Global Currency Account (‘GCA’)

Key attributes:
- Receive and hold funds in multiple currencies;
- Send money and exchange currencies, electronically;
- Exchange currencies at agreed rates of transfer and times;
- No fees to open a GCA; and
- All payments made are fully deliverable (the cost of the transfer is locked in at the time of booking the transfer).

TARGET MARKET

Product Eligibility

OFX clients must:

be at least 18 years old;
have a means by which to transfer funds electronically;
pass OFX customer due diligence checks, and provide the required information for OFX to complete these checks;
have the authority to bind any person (including non-natural legal persons) on whose behalf they are using the OFX product;
have a valid mobile number;
have a valid email address; and
agree to the OFX global Terms & Conditions and any region or product-specific terms.

Target Market

Spot Transfers

Needs:
- Send money and exchange currencies, electronically; and
- Transfer money from one country to another on a one-off or repeating basis, immediately.
Objectives:
- Save money on international transfer fees at a competitive exchange rate(s); and
- Transfer money quickly and conveniently.
Financial situation:
- Ability to pay out full amount of transfer booked at times notified by OFX.

Forward Exchange Contracts (‘Forwards’)

Needs:
- Send money and exchange currencies, electronically; and
- Transfer money from one country to another on a one-off or repeating basis, at a point in the future.
Objectives:
- Save money on international transfer fees at a competitive exchange rate(s); and
- Manage currency market volatility risk and foreign exchange exposure by ‘locking in’ a future exchange at a specified exchange rate.
Financial situation:
- Ability to pay out full amount of transfer booked at times notified by OFX.

Option Exchange Contracts (‘Options’)

Needs:
- Send money and exchange currencies, electronically; and
- Transfer money from one country to another on a one-off or repeating basis, at a point in the future.
Objectives:
- Save money on international transfer fees at a competitive exchange rate(s); and
- Manage currency market volatility risk and foreign exchange exposure by ‘locking in’ the ability to exchange at a specified exchange rate.
Financial situation:
- Ability to pay out full amount of any Option exercised (transfer booked) at times notified by OFX.

Global Currency Account (‘GCA’)

Needs:
- Send money and exchange currencies, electronically; and
- Transfer money from one country to another on a repeating basis, oftentimes a part of a business, now or in the future.
Objectives:
- Save money on international transfer fees at a competitive exchange rate(s); and
- Transfer money quickly and conveniently.
Financial Situation:
- Ability to pay out full amount of any transfer booked at times notified by OFX.

Target Market Appropriateness

Spot Transfers: This product is suitable for the target market because it is limited to predetermined values chosen by the client and there is no exposure to fluctuation of FX rates as the Spot Rate is locked in at the time of confirming the transfer.

Forwards: This product is suitable for the target market because it is limited to predetermined values and times chosen by the client and there is no adverse exposure to fluctuation of FX rates as the Forward Exchange Rate is locked in at the time of confirming the transfer.

Options: The product is suitable for the target market because it is limited to predetermined values, including the Premium, and times chosen by the client and there is protection against unfavourable currency movement whilst allowing flexibility to take advantage of favourable movements.

Global Currency Account (‘GCA’): This product is suitable for the target market because it is limited to clients with a predetermined need to receive foreign currency and make payments in multiple currencies.

DISTRIBUTION CONDITIONS AND RESTRICTIONS

Distribution Channels and Conditions

OFX clients are required to register an online account directly with OFX. Once registered, OFX products can be distributed to OFX clients either online through their secure account, via email if agreed between the customer and OFX, or over-the-phone (excluding Options, which can only be distributed over-the-phone).

Spot Contracts, Options and Forwards will be distributed separately.

OFX client may be referred to OFX products by third parties with whom OFX has an agreement (an “OFX Referral Partner”). You may receive the product via an Enterprise Partner. OFX does not allow third parties with whom it has no agreement with to distribute its products. All OFX clients are, however, required to register with OFX prior to being issued an OFX product.

Product-Specific Conditions

Forwards and Options will only be distributed to OFX clients that have a desire to lock in a currency exchange rate for a future transfer.

Option and the Global Currency Account will only be distributed to OFX clients with a legitimate business need to purchase the GCA product. These clients are required to answer additional questions and provide additional documentation to confirm this need.

Distribution Appropriateness

Distribution channels and conditions imposed on OFX products are likely to be appropriate because:

OFX products are easy to understand: OFX products are uncomplicated, and an online platform plus the ability to speak to an OFXer allows OFX to answer any (potential or current) OFX client questions. OFXers are also trained to identify instances in which the product is not suitable for a potential OFX client;
The distribution of OFX products is strictly controlled: only OFX, OFX Referral Partners and OFX Enterprise Partners are allowed to distribute OFX products, and OFX clients who are distributed OFX products by OFX Referral Partners must nevertheless be approved by OFX; and
Distribution channels assist in confirming the eligibility of an OFX client for an OFX product: distribution is limited to online account and over-the-phone interactions.

TMD REVIEW

We will review each TMD contained herein if any event or circumstance suggests that the TMD is no longer appropriate. This may include:

Where there is a material change to the product (e.g. adding or removing key product features) or distribution (e.g. adding an authorised representative to OFX’s AFSL, OFX choosing to no longer use referral partners as a distribution channel);
If we receive a significant number of complaints (>15% month to month change) regarding the design or distribution of the product; or
The occurrence of a significant dealing i.e. a dealing to clients outside of the TMD for a product, and which is significant considering the guidance provided by ASIC Regulatory Guide 274 Product design and distribution obligations.

We will review the TMD within 10 business days of the event occurring.

Periodic Review

Notwithstanding the above, OFX will do an initial review of each TMD within two years of the effective date and no less than once every two years thereafter.

Reporting and Monitoring

OFX as the distributor and issuer of the product collects data and information on the client’s use of the product, client complaints and feedback as well as client losses or cancelled transfers and runs reports at least quarterly to understand if the product has been sold to anyone outside the target market. The reports are also used to improve our client service and products.

We will also collect information, every two years, from our distributors in relation to this TMD including details of any client complaints relating to the distribution of OFX products and or details on any significant dealing.

Board Approval and Oversight

This TMD has been reviewed and approved by the OzForex Limited board of directors. The board retains oversight over the suitability of the TMD through quarterly review of complaints received by OFX for the products covered by this TMD.

Target Market Determinations 2021

Prepared and effective 30 August 2021

Please note a Target Market Determination is not a Product Disclosure Statement and is not intended to provide financial advice. Any advice provided in this document is general advice only and the information in this Target Market Determination does not take into account the investment objectives, financial situation and needs of any particular person. We make no recommendation as to the merits of any financial product referred to. Please review our Product Disclosure Statement and Financial Services Guide prior to making a decision. In addition, client specific terms and conditions will apply to any product issued to you.

OzForex Limited, trading as OFX (“OFX”) is an issuer and distributor of financial products to retail clients and we are required to make Target Market Determinations (“TMD”) available in accordance with the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act (Cth) 2019 (“Treasury Laws”).

OFX grew from the idea that there had to be a better, fairer way to move money around the world. That was over 20 years ago, and we’re still driven by the same mission today. Today we continually take a client-centric approach in designing and distributing our products.

As a product issuer, we are required to:

create and maintain the TMD for all our products that are covered by the Treasury Laws; and
take reasonable steps to ensure our products are distributed in line with those TMDs.

As a product distributor, OFX and other distributors are required to:

ensure there’s a TMD in place for all of the products that OFX distribute that are covered by the Treasury Laws;
understand and comply with any distribution conditions and reporting requirements set by OFX in the relevant TMD;
take reasonable steps to ensure the product is distributed in line with the TMD;
to keep records of complaints or other information required by the TMD;
to report information to the OFX as required by the TMD.

All Distributors of our products will need to adhere to the distribution conditions as set out in the applicable TMD.

OFX has four main categories of clients – consumers, corporates, online sellers and enterprise. Our products are all designed to serve a purpose, solve a problem and or make our clients’ lives easier.

Consumers

At OFX we define Consumer clients as individual or personal clients that have a personal and noncommercial need to make payments and exchange currencies. OFX Consumer clients have a predetermined need to transfer money from one country to another in order to make a payment. Some examples of the reason to transfer include overseas investments, transferring salaries overseas, holiday and other travel payments and payments associated with the costs of emigration. OFX’s products support Consumers with a wide range of needs. Whilst some Consumers have a single transfer need, over 50% have recurring needs. For the majority of OFX Consumer clients, Spot Transfers are the primary product purchased.

OFX’s key value proposition for Consumers is digital + human, specialism, savings and 24/7 human support.

The age of OFX Consumers is distributed and not concentrated in a particular group, however you must be over the age of 18 to become an OFX Consumer client.

Corporates

At OFX we define Corporate clients as registered corporations and or businesses that have a commercial need to make payments and exchange currencies. OFX Corporate clients have a predetermined need to transfer money from one country to another in order to make a payment, receive funds in multiple currencies and or have a need to manage currency market volatility risk and foreign exchange exposure. Some examples of the reason to transfer include paying suppliers overseas, paying employee salaries and payment of taxes. OFX’s products support Corporates with a wide range of needs.

These small and medium businesses include a mix of Private Companies, Trusts, Sole Traders, Public Companies. OFX’s products are suitable for both new and established businesses.

For the majority of OFX Corporate clients, Spot Transfers are the primary product purchased and Forward Exchange Products also suit the needs of Corporates.

OFX’s key value proposition for Corporates is digital + human, specialism, savings and 24/7 human support.

Online Sellers

At OFX we define Online Sellers as clients that are registered corporations and or businesses that are predominantly providing their products and services to consumers via an online channel, for example an online marketplace or digital platform. Online Sellers have a predetermined commercial need to receive funds, make payments and exchange currencies. Some examples of the reason to transfer include paying suppliers overseas, paying employee salaries and payment of taxes. OFX’s products support Online Sellers with a wide range of needs.

These Online Sellers include a mix of Private Companies, Trusts, Sole Traders, Public Companies. OFX’s products are suitable for both new and established businesses.

OFX’s key value proposition for Online Sellers is digital + human, specialism, savings and 24/7 human support.

Online Sellers are issued with a Global Currency Account to complement their predetermined payment needs.

Enterprise Partners

OFX partners with larger corporate entities to create a better overall product and service offering for the partner and OFX clients. These Enterprise partners are sometimes our Corporate Clients, and or may be considered distributors of our products to Consumer, Corporate or Online Seller clients.

The purpose of a TMD is to describe:

the type of client the OFX product is designed for;
how the OFX product is distributed;
when the TMD will be reviewed;
the recording keeping and reporting obligations of distributors; and
what information is required to help maintain the accuracy of the TMD.

OFX FINANCIAL PRODUCTS

1. Spot Transfers

Our Target Market

This product is designed for Consumers, Corporates and Online Sellers.

Product description and key attributes

Where a client wants to transfer money immediately, then they will need to enter into a Spot Contract with OFX. A Spot Contract is an agreement to exchange one currency for another at an agreed exchange rate within 2 days of the transfer being booked. For example, when you make a purchase overseas in a foreign currency, you may have to pay the purchase price straight away. In those circumstances, your only consideration will be the exchange rate at the time of the purchase and booking the transfer. Prior to confirming a transfer and booking the Spot Contract, OFX will provide a quote using a Spot Rate. Spot Rate means the exchange rate for settlement within 2 business days from the date the transfer was booked including the OFX margin.

OFX Spot Rates are calculated by adding a margin on top of the interbank rate which OFX receives from its banking counterparties.

The underlying features of a Spot Contract mean that it is an uncomplicated product to serve a predetermined need to make a payment. All Spot Contracts are fully deliverable with the cost of the transfer, including the exchange rate, being locked in at the time of booking the transfer. Payment to fulfil the Spot Contract is required straight away (T + 2) and settlement times vary depending on currency and country of recipient.

OFX does not provide personal financial advice and will not take into account the investment objectives, financial situation and or needs of any particular person. The client has full discretion over the value of the Spot Contract and the timing of booking the transfer.

This product is suitable for the target market because it is limited to predetermined values chosen by the client and there is no exposure to fluctuation of FX rates as the Spot Rate is locked in at the time of confirming the transfer.

OFX does not provide its products or services to clients under the age of 18 years.

How this product is to be distributed

Spot Contracts are issued by OFX directly either online or over the phone. Our OFX employees, known as OFXperts, are trained to assist clients to book in the transfer of their choosing.

The compulsory questions asked and information available to clients when completing a quote and prior to locking in a transfer allow the client to determine if the product is right for them and helps OFX to determine if they are within the target market for this product. This is in addition to the OFX disclosure documents, our PDS and FSG, which are issued to clients prior to them purchasing any OFX product and go into detail on the features, risks and benefits of the OFX products.

You may be referred to OFX by an OFX Referral Partner, however you will be required to register directly with OFX prior to being issued an OFX product. You may receive the product via an Enterprise Partner.

Spot Contracts must be distributed to clients that have a requirement to make a payment and the product will only be issued to a client that has agreed to applicable product terms and conditions. These conditions make it likely that the clients who acquire the product are within the target market because it is the client that ultimately decides to purchase the product after having been provided with adequate information and assistance from OFX.

Reviewing this target market determination

We will review this TMD if any event or circumstance suggests that this TMD is no longer appropriate. This may include:

Where there is a material change to the product or distribution;
If we receive a significant number of complaints regarding the design or distribution of the product; or
The occurrence of a significant dealing.

We will review this TMD within 10 business days of the event occurring.

Notwithstanding the above, OFX will do an initial review of this target market determination within two years of the effective date and no less than once every two years thereafter.

Reporting and monitoring this target market determination

We will also collect information, on a regular basis, from our distributors in relation to this TMD including details of any client complaints relating to the distribution of OFX products and or details on any significant dealing.

2. Forward Exchange Contracts

Our Target Market

This product is designed for Consumers, Corporates and Online Sellers.

Product description and key attributes

A Forward Exchange Contract is an arrangement that allows clients to transfer money at some time (up to 12 months) in the future at an exchange rate that is agreed at the time of booking the transfer. The key feature is that the client knows, and is locking in, what the exchange rate will be at the time the exchange of currencies becomes necessary. This allows clients to avoid the risks and uncertainties associated with adverse exchange rate movements.

The purpose of a Forward Contract is primarily to mitigate the risk of adverse exchange rate movements. A Forward Contract enables future exchange risk to be mitigated however if the Forward Exchange Contract and is required to be settled on or before the Maturity Date. Forward Contracts are generally used by Corporates such as importers, exporters and investors who seek to lock in exchange rates for settlement at a future date in order to protect their foreign currency cash flows. However, they can also be used by Consumers migrating or buying property overseas.

OFX Forward Exchange Contract rates are determined using the current Spot Rate and the forward rate adjustment. The Forward Rate quoted by OFX will not be the same as the Spot Rate, because it will take into account the interest costs in holding the money until the maturity date (i.e. the date in the future which the client has nominated to settle the transfer). It may be better or worse than the prevailing Spot Rate on the day depending on the difference in interest rates between the country of the currency being sent and the country of the currency being received.

The underlying features of a Forward Exchange Contract mean that it is a simple product to serve a desire to lock in a current currency exchange rate. All Forward Exchange Contracts are fully deliverable with the cost of the transfer, including the exchange rate, being locked in at the time of booking the transfer. Clients may be asked to make a payment of part of the sum that is due to OFX on the Maturity Date either at the time of booking the transfer or at any time prior to the Maturity Date.

OFX does not provide personal financial advice and will not take into account the investment objectives, financial situation and or needs of any particular person. The client has full discretion over the value of the Forward Exchange Contract and the timing of booking the transfer, including the settlement date.

This product is suitable for the target market because it is limited to predetermined values and times chosen by the client and there is no adverse exposure to fluctuation of FX rates as the Forward Exchange Rate is locked in at the time of confirming the transfer.

OFX does not provide its products or services to clients under the age of 18 years.

How this product is to be distributed

Forward Exchange Contracts are issued by OFX directly either online or over the phone. Our OFX employees, known as OFXperts, are trained to assist clients to book in the transfer of their choosing.

Clients are asked additional questions by OFXperts to promote awareness of the additional risks associated with booking a Forward Exchange Contract compared to booking a Spot Contract to ensure that the client confirms the product is appropriate for them.

Clients may be referred to OFX by an OFX Referral Partner, however they will be required to register directly with OFX prior to being issued an OFX product. You may receive the product via an Enterprise Partner.

Forward Exchange Contracts must be distributed to clients that have a desire to lock in a currency exchange rate for a future transfer and the product will only be issued to a client that has agreed to applicable product terms and conditions. These conditions make it likely that the clients who acquire the product are within the target market because it is the client that ultimately decides to purchase the product after having been provided with adequate information and assistance from OFX.

Reviewing this Target Market Determination

We will review this TMD if any event or circumstance suggests that this TMD is no longer appropriate. This may include:

Where there is a material change to the product or distribution;
If we receive a significant number of complaints regarding the design or distribution of the product; or
The occurrence of a significant dealing.

We will review this TMD within 10 business days of the event occurring.

Notwithstanding the above, OFX will do an initial review of this target market determination within two years of the effective date and no less than once every two years thereafter.

Reporting and monitoring this target market determination

3. Global Currency Account

Our Target Market

This product is designed for Corporates and Online Sellers.

Product description and key attributes

The Global Currency Account (“GCA”) is a multi-currency account for businesses that allows clients to pay and get paid in the foreign currencies that they do business in. The GCA allows clients to receive electronic transfers of funds from payment gateways, marketplaces or directly from clients. It also allows clients make payments to third parties including paying suppliers, vendors and paying taxes.

Clients are able to receive funds in multiple currencies and then hold the funds in multiple currencies without the need to convert the funds. Clients are then able to choose which currency they make payments in using the balance of funds help in their GCA. There are no fees to receive payments and clients choose when to make a payments including the value of the payment and confirm the exchange rate the time of confirming the payment.

The underlying features of the GCA mean that it is an uncomplicated product to serve the Corporate client’s need to receive and hold funds for business purposes. All funds received are allocated to the client’s held balance and all payments made from the GCA are fully deliverable with the cost of the transfer, including the exchange rate, being locked in at the time of booking the transfer.

OFX does not provide personal financial advice and will not take into account the investment objectives, financial situation and or needs of any particular person. The client has full discretion over the currency denomination and value of the held balance and value of any payment as well as the timing and booking any transfer.

This product is suitable for the target market because it is limited to clients with a predetermined need to receive foreign currency and make payments in multiple currencies.

Clients must be a Corporate client and have a legitimate need to purchase the GCA product.

OFX does not provide its products or services to clients under the age of 18 years.

How this product is to be distributed

The GCA product is issued by OFX directly either online or over the phone. Our OFX employees, known as OFXperts, are trained to assist clients to purchase the product and or book in the transfer of their choosing.

Clients are required to answer additional questions and provide additional documentation to confirm their legitimate business needs and ensure that the product is appropriate for them.

The compulsory questions asked and additional information available to clients when completing a request for the GCA product allows the client to determine if the product is right for them and helps OFX to determine if they are within the target market for this product. This is in addition to the OFX disclosure documents, our PDS and FSG, which are issued to clients prior to them purchasing any OFX product and go into detail on the features, risks and benefits of the OFX products.

The GCA product must be distributed to clients that are Corporate clients with a business need to receive and make payments in multiple currencies and the product will only be issued to a client that has agreed to applicable product terms and conditions. These conditions make it likely that the clients who acquire the product are within the target market because it is the client that ultimately decides to purchase the product after having been provided with adequate information and assistance from OFX.

Reviewing this Target Market Determination

We will review this TMD if any event or circumstance suggests that this TMD is no longer appropriate. This may include:

Where there is a material change to the product or distribution;
If we receive a significant number of complaints regarding the design or distribution of the product; or
The occurrence of a significant dealing.

We will review this TMD within 10 business days of the event occurring.

Notwithstanding the above, OFX will do an initial review of this target market determination within two years of the effective date and no less than once every two years thereafter.

Reporting and monitoring this target market determination

4. Options

Our Target Market

This product is designed for Corporates.

Product description and key attributes

A foreign exchange Option is an agreement that gives you the right but not the obligation to enter into a foreign currency transfer at a predetermined exchange rate on a pre-determined date in the future. You will have to pay a non-refundable fee (“Premium”) for the Option, but you will not have to settle the foreign currency transfer if you choose not to exercise the Option.

OFX offers only European style bought Vanilla Options. A “European” style Vanilla Option means that both the exchange rate (“Strike Rate”) and the date on which the client must make an election whether or not to Exercise the Option (“Expiry Date”) are fixed. When a client enters into a vanilla Option, the client is required to nominate the currencies they want to exchange (the “Currency Pair”), the Strike Rate and the Expiry Date. The currencies that the client chooses to exchange must be acceptable to OFX and clients cannot sell the Option to a third party.

OFX Option Premiums are determined on a transfer vs transfer basis and in calculating the Premium the following factors could be relevant: the currencies involved, the Strike Rate, the Expiry Date, the amount involved, current market exchange rates, current market interest rates in the two relevant countries and general market volatility.

The underlying features of an OFX Vanilla Option mean that it is a simple product to serve a desire to lock in a current currency exchange rate. Options enable a client to hedge their currency exposure by providing protection against unfavourable currency movements between the time you enter into the Option and the Expiry Date, while allowing you to take advantage of any favourable currency movements. Options offer a more flexible arrangement than Forward Exchange Contracts because the client is not committed to going ahead with the foreign exchange transfer if they choose not to.

OFX does not provide personal financial advice and will not take into account the investment objectives, financial situation and or needs of any particular person. The client has full discretion over the value of the Option and the timing of booking the transfer, including the Expiry Date.

This product is suitable for the target market because it is limited to predetermined values, including the Premium, and times chosen by the client and there is protection against unfavourable currency movement whilst allowing flexibility to take advantage of favourable movements.

OFX does not provide its products or services to clients under the age of 18 years.

How this product is to be distributed

Options must be purchased over the phone. Only qualified OFXperts that have received the adequate training from OFX and that follow any policies and procedures which we require (including product specific scripts and additional documentation requirements) can assist clients in booking an option.

Clients are required to answer additional questions and provide additional documentation to confirm their legitimate business needs and ensure that the product is appropriate for them. Clients are also informed of the additional risks associated with booking an Option compared to booking a Spot Contract to ensure that the client confirms the product is appropriate for them.

Clients may be referred to OFX by an OFX Referral Partner, however they will be required to register directly with OFX and be issued the OFX product directly by OFX. You may receive the product via an Enterprise Partner.

Options must be distributed to clients that have a desire to lock in a currency exchange rate and the product will only be issued to a client that has agreed to applicable product terms and conditions.

These conditions make it likely that Options will only be distributed to clients within the target market for this product because OFX representatives and the client has knowledge of the product terms and OFX processes are designed to identify instances where the product is not suitable for the applicant.

Reviewing this target market determination

We will review this TMD if any event or circumstance suggests that this TMD is no longer appropriate. This may include:

Where there is a material change to the product or distribution;
If we receive a significant number of complaints regarding the design or distribution of the product; or
The occurrence of a significant dealing.

We will review this TMD within 10 business days of the event occurring.

Notwithstanding the above, OFX will do an initial review of this target market determination within two years of the effective date and no less than once every two years thereafter.

Reporting and monitoring this target market determination