The Australian Securities and Investments Commission has followed up its stop order preventing humm selling its buy now pay later product with details of its latest BNPL industry review, focusing on compliance with the design and distribution obligation. The review found that definitions of target markets were deficient, review triggers were vague or non-existent and key features were poorly described. ASIC had concerns about the target market determination of the products sold by humm’s subsidiary humm BNPL Pty Ltd. It said the TMD failed to appropriately define the target market and did not provide enough detail about a bill payment deferral feature. ASIC withdrew the order after humm addressed the design and distribution deficiencies it had identified. In its review of the BNPL sector’s compliance with DDO, ASIC said most of the target market determinations “lacked sufficient detail in describing features and attributes of the product.” A number of TMDs mentioned fees as a key attribute without specifying the value of the fees.   ASIC said TMDs used descriptions that were too broad, making it difficult to work out the class of consumers comprising the target market. It said the problem with this was that “a BNPL provider that has a broad description of the consumers who comprise its target market, without that having appropriate consideration of the key attributes of the product, is at risk of including consumers who should not be in that target market”. A broad description of the target market that does not include references to financial hardship or the ability of consumers to make repayments is at risk of including vulnerable customers in the class of consumer that comprise the target market. ASIC said some providers set TMD review periods of two years, which it said was unlikely to be frequent enough to satisfy the provider that the TMD remains appropriate.  In addition, many TMDs did not have review triggers and among those that did, the triggers were vague. ASIC said review triggers should be based on objective measures. ASIC said that following the review, it will be providing feedback to BNPL providers.