Douugh 50 Cents Club, page-26

"For a local Aussie Fintech Neobank with its own Niche`, getting through massive regulatory, banking, competitive, technological hurdles...".

I've been pretty closely following neobank developments in Australia, so wanted to clarify on this a little.

In Australia, to be a bank, you have to be registered as an ADI (authorised deposit-taking institution). The other newer and increasingly more common scenario is that you use an existing banks' ADI and put something on top of it - this is DOU.

As we can see by https://www.apra.gov.au/register-of-authorised-deposit-taking-institutions, the newest Australian-owned banks are:

• 86 400
• Judo Bank
• Lutheran Laypeople's League of Australia
• volt bank
• Xinja Bank

I don't know if there is a formal name for "using another bank's ADI", but perhaps the most commonly known one at the moment might be Up, who come under Bendigo and Adelaide Bank. There are many others doing this and soon to be doing this.

For DOU this is Regional Australia Bank. Specifically, "Regional Australia Bank Ltd (Regional Australia Bank) is the Australian Sponsor Bank that provides the banking infrastructure, licencing, BIN sponsorship and services (Services) to support the operation of the Douugh Banking Platform in Australia." "Douugh must ensure that all marketing material, disclosure documents and correspondence relating to the products provided pursuant to this agreement notifies the recipient that Regional Australia Bank is the Australian Financial Services Licence Holder, the Australian Credit Licence holder, and is the provider of the product or service." - https://static.douugh.com/media/Douugh_Prospectus_2020.pdf - p.170

So, in Australia DOU will not be an Authorised Deposit-taking Institution, nor an Australian Financial Services Licence Holder, nor an Australian Credit Licence holder, nor is the product / service provider.

DOU will be offering a banking / financial product, but it should be clear they themselves are not a bank or financial services provider. This is neither a good nor bad thing, it's just their chosen business model.

Which leads me to the second part of your statement.

Largely due to the above, DOU has not gone through, nor should anyone be under any impression that they have the same hurdles as a bank. DOU just simply does not have massive regulatory, banking or capital requirements - they are essentially a product that sits on top of an existing bank's offerings. They just have to closely follow the bunch of agreements they've made and do their their software development.

If they had these hurdles of which you mention, I can tell you that their recent $6M raise would be gone in about a heartbeat. This would be more of an issue for the groups listed above.

Holders should not be surprised to encounter a CR soon.

The more serious hurdle that DOU is currently facing is that one of their directors is also a director of another ASX company that is currently suspended. In an age of increasing banking and financial services transparency, this is a very big deal, particularly having not even launched.