Target Market Determination (TMD)

For the Grineo Debit Card

Grineo Version 1.0

Effective March 2024

Issued by Hay Limited ABN 34 629 037 403

Australian Financial Services Licence No. 515459

1. TMD for Non-Cash Payment product

Target Market: Class of retail individuals that comprise the target market for the product.

Retail Individual Description:

This describes retail individuals in the target market.

Eligibility criteria for the product

Individuals will need to satisfy specific eligibility criteria to maintain this product. To qualify, the Retail Individual must:

• Be an individual person; and
• Be aged 18 years or older; and
• Be an Australian resident and have a valid Australian residential address;
• Hold an existing Grineo Wallet.

Objectives & Needs

This product is targeted at Individuals with the likely objectives, financial situation and needs of wanting:

• Access to funds converted from their digital currency wallet.
• Visa-branded Grineo Debit Card to make purchases, and to withdraw cash at ATMs.

Financial Situation

• At the time of application, the Individual has the right to open a Non-Cash Payment product, by making a request for such a product from within the Grineo App.

Product Description:

This describes the non-cash payment product.

• The Non-Cash Payment Product issued by Hay Limited is a Visa Debit Card.
• The Individual can make purchases at merchants (in-store or online) with the Visa Grineo Debit Card. Access to the transaction history and usage is possible only through the Grineo App.
• No cash deposits or bank transfers can be made into the card by the customer
• When the card is utilised, Grineo will convert Stablecoins into fiat currency (e. the transaction amount at a merchant location or ATM) at a rate that Grineo sets. This converted amount will be utilised to present the available balance, fund the Grineo Debit Card transaction, and for fiat settlements with Hay.
• A Grineo Debit Card (including ATM) transaction will be permitted only to the extent of available Stablecoin value within the customer’s Grineo account. Accordingly, the transaction may be declined in the event Grineo confirms to Hay that the Stablecoin value held by the customer is insufficient to fund the transaction taking place in fiat currency.
• There are daily limits on Grineo Debit Card and ATM transactions which can be viewed in the Product Disclosure Statement.

This describes the relationship between the Debit Card and Grineo Wallet.  

• The Stablecoin balance and final conversion to fiat determines the approval of purchase requests via the Visa International network.
• The conversion rate from Stablecoin to fiat current will be determined and applied by Grineo in real time.

Appropriateness Statement:

This explains why the product is consistent with the target market’s likely objectives, financial situation, and needs.

The issuer, Hay Limited, has considered that the product is likely to be consistent with the possible objectives, financial situation and needs of the Target Market as:

• Individuals can utilise the Grineo Debit Card to make purchases at merchant locations and withdraw cash to the extent of the value of Stablecoins within their Grineo Wallet.
• The customer can view the value of their Stablecoins within the Grineo App at any time.
• This value will be in A$ (with a conversion rate applied from US$ by Grineo within their App).
• There are daily limits on the Grineo Debit Card and ATM transactions. These limits reflect the nature of the product and help customers manage their spend/usage.

Distribution Conditions:

The conditions and restrictions on the distribution of the product

Marketing and Promotion

This condition applies to marketing and promotional materials that describe the product

Condition 1

Grineo, the authorised distribution partner, must only market and promote the product as a Non-Cash Payment Product in Australia.

This condition is suitable as the issuer only distributes this product in Australia, using these methods, with limited risk to Individuals.

Retail Product Distribution Conduct (other than Marketing)

This condition applies to all conduct (other than marketing), such as issuing, arranging, and providing disclosure material.

Condition 2

Grineo, the authorised distribution partner, must only engage in arranging, distribution and providing factual product information:

• through the Grineo Website/App;
• to prospective Individuals who meet Hay Limited’s eligibility criteria for the product; and
• to make available the Non-Cash Payment Product to individuals after applying for and successfully completing the application process for the Non-Cash Payment Product.

This condition is suitable as the issuer has distributed this product using these methods, with limited risk to individuals.

Review Triggers:

The events and circumstances that would reasonably suggest the determination is no longer appropriate

The issuer, and any distributor of this product, must cease retail product distribution conduct in respect of this product when the issuer determines a material event or circumstance has occurred concerning:

Material Complaints

Material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct.

Product Performance

Evidence, as determined by the issuer, of the product’s performance, in practice, may suggest that the product is not appropriate for the target market.

Distributor Feedback

Reporting from distributors, or consistent feedback from distributors on the target market, suggesting that the determination may no longer be appropriate.

Substantial Product Change

A significant change to the product features outlined in the product description will likely make the determination no longer appropriate for the target market.

A significant change to the product because of regulatory, legislative or code changes will likely result in the determination no longer being appropriate for the target market.

Significant Dealing

A material pattern of dealings in the product or distributor conduct is inconsistent with the determination.

Annual Product Review

Hay conducts an annual product review

Notification from a Court or relevant regulatory authority

A notification is received by the Issuer from a Court or relevant regulatory authority requiring immediate cessation of product distribution or conduct concerning the product.

Review Trigger Information Reporting requirements

The distributor of this product must provide the following information to Hay Limited within the below timeframes.

Product Complaints data

Information relating to complaints received, including the number, type and summary details by the distributor of this product and provided quarterly within ten days of the end of the Quarter.

Significant Dealings

Any significant dealings of the product to retail individuals who are outside the target market. This must be provided as soon as practicable and no later than 10 business days after the distributor becomes aware of such dealings.