Target Market Determination (TMD)

Effective date of TMD: 5 October 2021
Version: 0.1

What’s a Target Market Determination (aka TMD)?

A TMD is a document that describes who a product is likely appropriate for (aka the target market), and any rules around how the product can be distributed. It also describes the scenarios where we may need to review this document, and reporting requirements that distributors need to follow.

This document isn’t a summary of the product and doesn’t take your personal situation into account. Head to to learn more and read our Product Disclosure Statement (aka PDS). 

In this document, ‘we’, ‘us’, ‘our’ and ‘HCF Life’ means HCF Life Insurance Company Pty Ltd, AFSL 236 806. HCF Life is the issuer of Flip cover.

Key features of Flip cover

Flip pays a cash benefit if an insured person has a specified injury as a result of an accident, as per the terms and conditions in the PDS. Insured persons can: 

  • subscribe for a base level of ongoing cover;
  • choose to increase cover as needed for an additional premium; 
  • and cancel cover at any time.

Target market for Flip cover 

Flip cover is suitable for people who are:

  • looking for a product that will provide a cash payout if they suffer a specified injury as a result of an accident; 
  • looking for a product that reduces the financial impact resulting from specified injuries that can be used flexibly to cover items such as medical and other expenses; 
  • aged 18 to 64;
  • an Australian citizen, New Zealand citizen, or Permanent Australian resident; and
  • permanently living in Australia at the time of purchase. 

Flip cover is not suitable for people who

  • hold an existing Flip policy; or
  • people looking to be covered for injuries that happen as a result of: 
    • motorcycling; or 
    • paid work or employment, unless the paid work or employment is a sport-related activity such as tennis coaching. 

This section talks about how Flip cover is sold, when we’ll review this TMD, and what our distributors need to tell us

Distribution of this product

People are more likely to be in the target market if a product is distributed in line with the issuer’s distribution rules. For Flip cover, these rules are: 

  • Applications for Flip cover can only be made online via; 
  • The application process must include questions designed to determine whether the person is likely to be in the target market; and 
  • Any promotional or advertising materials must be informed by, and be consistent with, the TMD, and approved by us. 

Reviewing this TMD

We will review this TMD at least every 3 years from the effective date of this TMD. We will also review this TMD earlier if a review trigger occurs that would reasonably suggest that the TMD is no longer appropriate. 

Review triggers 


The commencement of a significant change in law that materially affects product design and/or distribution of the product or class of products that includes this product. 


Product performance is materially inconsistent with our expectations having regard to:

  • Product claims ratio
  • The number or rate of paid, denied and withdrawn claims
  • The number or rate of new, active and unengaged customers
  • Lapse or cancellation rates 

ASIC’s use of its Product Intervention Powers in relation to the distribution or design of this product where we consider this reasonably suggests that this TMD is no longer appropriate. 


Significant or unexpectedly high number of complaints* regarding product design, claims, or distribution where we consider that this reasonably suggests that the TMD is no longer appropriate.

*As defined in ASIC Regulatory Guide 271 


We determine that a significant dealing in the product outside the target market (except for an excluded dealing) has occurred.


Product performance

Distributors must report on the metrics in Review Trigger 2 on a monthly basis. 


Distributors must record all complaints relating to Flip cover and must report on these on a quarterly basis. 

Distributors must report on:

  • The total number of complaints they receive during the reporting period; and 
  • The nature and details of each complaint

The reports must be shared with us within 10 business days of the end of the reporting period. 

Any dealings outside the TMD 

Any dealing in the product to a person which we and/or our distributors become aware is not consistent with the TMD must be reported to us within 10 business days of becoming aware of the dealing. 

HCF Life Insurance Company Pty Ltd, ABN 37 001 831 250, AFSL 236 806 is the issuer of Flip cover.