UKForex Limited, trading as OFX (“OFX”), is a manufacturer and distributor of financial products to retail clients, and is regulated by the Financial Conduct Authority (“FCA”). As such, OFX is required by the FCA’s Consumer Duty (the “Consumer Duty”) to identify those groups of customers sharing common features whose characteristics, needs and objectives OFX’s products are designed to meet (the “Target Market”).
As a product manufacturer, OFX is required to:
- Identify the Target Market of the products it offers to retail customers, to help avoid sales to customers for whose needs, characteristics and objectives the products are generally incompatible; and
- consider whether the design of its products meets the needs, characteristics and objectives of the Target Market, including those customers with characteristics of vulnerability, and, where the products do not, takes appropriate action to mitigate the situation and prevent any further harm.
As a product distributor, OFX is required to:
- ensure there is a distribution strategy appropriate for the Target Market, by selling to customers for whose needs, characteristics and objectives its products were designed; and
- ensure that any third-party distributors that OFX might use distribute the product in the same way.
OFX has four main categories of clients – consumers, corporates, online sellers and enterprise. Its products are all designed to serve a purpose, solve a problem and or make its clients’ lives easier.
Consumers
OFX defines 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 OFX Consumer clients must be over the age of 18.
Corporates
OFX defines Corporate clients as registered corporations and or businesses (whether micro-enterprises or larger corporates) 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, Partnerships, Sole Traders, Public Companies and Trusts. 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
OFX defines 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, Partnerships, Sole Traders, Public Companies and Trusts. 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 defines Enterprise Partners as corporates who will both act as a customer of OFX and as a partner of OFX, whose clients will transact with OFX. Due to the nature of Enterprise Partners it is unlikely that they will fall within scope of the Consumer Duty, but their customers (who will become OFX customers) will fall within one of the above categories.
OFX FINANCIAL PRODUCTS
1. Spot Transfers
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 a customer makes a purchase overseas in a foreign currency, they may have to pay the purchase price straight away. In those circumstances, their 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. 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.
Customers 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.
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.
2. Forward Exchange Contracts
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. OFX also only offers forwards where the customer can demonstrate an accompanying payment to be made, in line with the “payment purpose exemption” under MiFID II.
How this product is to be distributed
Forward Exchange Contracts are issued by OFX directly either online or over the phone. 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.
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.
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.
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.
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 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. 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.
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.
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 document if any event or circumstance suggests that OFX’s identification of its Target Market 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.
Notwithstanding the above, OFX will do an initial review of this target market determination within one year of the effective date and no less than annually thereafter.
Reporting and monitoring
OFX as manufacturer 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. The reports are also used to improve client service and products.
Please note this document is not intended to provide financial advice. Any advice provided in this document is general advice only and the information within it does not take into account the investment objectives, financial situation and needs of any particular person. OFX make no recommendation as to the merits of any financial product referred to. Client specific terms and conditions will apply to any product issued to OFX customers.