Flip Roaming Target Market Determination (TMD)

Effective date of TMD: 15 April 2026
Version: 2.2
Review trigger explanation Obligations
1. Regulatory environment The commencement of a significant change in law that materially affects product design and/or distribution of this product. We must monitor relevant regulation, legislation and/or ASIC instruments relating to the change in law, as required.
2. Product performance Product performance is materially inconsistent with our expectations having regard to:
  • the number of times cover is sold, and the periods for which cover is sold;
  • cancellation rates;
  • the product claims ratio;
  • the number or rate of paid, denied, and withdrawn claims;
  • the Net Promoter Score (NPS); or
  • the number or rate of new and active customers.
We must monitor product performance metrics on a quarterly basis against targets and expectations.

Flip Insurance, as the distributor of this product, must report on these metrics on a monthly basis. This information must be shared with us within 10 business days of the end of the reporting period.
3. Product changes Material changes in the product design or distribution that could affect whether the product remains consistent with the target market. We must assess changes to product terms or distribution arrangements to determine whether they affect target market alignment.
4. Product intervention powers ASIC's use of its Product Intervention Powers in relation to the product or a similar product. We must monitor the terms of any Product Intervention Orders that impact the product, or similar products, and consider whether a review is required.
5. Complaints Significant or unexpectedly high number of complaints about the product or its distribution. Flip Insurance, as the distributor of this product, must record all complaints relating to Flip Roaming cover and must report the following on a quarterly basis:
  • the total number of complaints they received during the reporting period; and
  • the nature and details of each complaint.

This information must be shared with us within 10 business days of the end of the reporting period.

6. Significant dealings We determine that a significant dealing in the product outside the target market (except for an excluded dealing) has occurred. Any dealing in the product to a person which we or Flip Insurance, as the distributor of this product, becomes aware is not consistent with the TMD must be reported to us within 10 business days of becoming aware of the dealing.
7. Other events or circumstances Any other event or circumstance that materially affects the product's alignment with the target market or the distribution conditions. We must review other material events (e.g. systemic incidents, distributor feedback, claim trends) that may indicate misalignment with the target market or distribution conditions.