An evidence-led banking product investigation

Can a bank create a fair retail investment for mortgage funding?

HomeFund asks whether Australians could allocate money to support a major bank’s residential mortgage funding through an investment that is clearer and more accessible than direct property ownership.

The idea sounds simple: provide the bank with longer-term funding, give the investor a defined return and protect principal at maturity. The investigation shows why those promises cannot be accepted at face value. Product structure, protection, return, term, liquidity, tax, accounting, regulation and commercial value must work together, not merely sound attractive in isolation.

No bank has sponsored or approved HomeFund. No return, protection mechanism, legal structure or liquidity arrangement has been confirmed.

Current verdict

Worth investigating. Not ready to become a product.

No structure currently passes every consumer, commercial, legal, prudential, accounting, tax and operating gate.

The research supports continuing with three tightly defined validation cells. It does not support building, launching or presenting HomeFund as an available investment.

Baseline

Purpose-branded term deposit

The clearest customer claim and the mandatory comparison. It may offer the simplest path to principal protection and possible Financial Claims Scheme treatment, if confirmed for the exact structure. It may also fail by paying more for deposits the bank already holds.

Leading investment-form option

Senior unsecured retail note

The closest fit with an investment product and hard contractual term. It would likely expose investors to the issuing bank rather than the Financial Claims Scheme, and any transfer before maturity would occur at market value rather than guaranteed principal.

Conditional option

Mortgage-covered retail note

A stronger legal connection to an identified mortgage cover pool may improve the credibility of the mortgage link. It also adds encumbrance, legal, collateral, reporting and operating costs that customers may not value enough to justify.

Parked or rejected initially

A transferable deposit is parked because transferability may undermine the protected-deposit treatment it attempts to preserve. Managed or securitised mortgage exposure is not the initial direction because it would transfer risks the bank is currently intended to retain.

The consumer question

Is there a useful space between cash, securities and direct property?

Australians already have many ways to save and invest. At-call savings and term deposits offer familiarity and relative stability. Bonds and bond funds provide income with market and issuer risk. Shares and diversified funds offer growth with volatility. Direct property is familiar but expensive, concentrated and operationally demanding. Mortgage and private-credit funds provide credit exposure while shifting more risk to investors.

HomeFund tests whether some consumers would value a different combination:

  • a recognisable connection to Australian home lending;
  • no property purchase, tenants or maintenance;
  • a return that is more predictable than an at-call savings rate;
  • principal due at a defined maturity; and
  • a possible way to transfer the investment before maturity.

That opportunity remains unvalidated.

The strongest consumer challenge is that the proposition may be attractive only while important distinctions remain unclear. A bank-issued investment is not automatically a protected deposit. Principal due at maturity is not the same as access at principal before maturity. Mortgage purpose is not mortgage ownership or security. A resale mechanism does not guarantee a buyer, a price or liquidity under stress.

Stated interest is therefore not enough. Demand counts only after a customer understands the legal claim, issuer exposure, Financial Claims Scheme status, mortgage rights, maturity, early value, fees, tax and simpler alternatives.

Explore the consumer case

The bank question

Can committed retail funding create measurable value?

A major bank funds residential mortgages through a mix of at-call deposits, term deposits and wholesale funding, supported by central Treasury, liquidity management and hedging.

Longer contractual funding may be useful because it can reduce uncertainty over when funds leave the bank. But a longer product term does not automatically create incremental value.

The source of the money matters.

External new money or identifiable replacement of more expensive wholesale funding may create value. Moving an existing customer balance from a persistent, lower-cost savings account may simply shift money within the bank while increasing the customer return and adding product costs.

Any claimed tenure benefit must therefore be measured after recognising:

  • the displaced deposit’s existing behavioural value;
  • funds-transfer pricing;
  • liquidity transfer pricing;
  • structural and replicating hedges;
  • cannibalisation;
  • distribution, legal and operational costs;
  • liquidity or market-support costs; and
  • stress behaviour.

The commercial test is a corridor:

The maximum return the bank can support must be at least as high as the minimum return an informed customer requires.

Where no such corridor exists, the proposition must be repriced, simplified, restructured or rejected.

The original approximately 5 per cent return remains only a controlled research cell. Public evidence does not support it as an always-on promise or pricing rule.

Explore funding economics

Why the idea may fail

A credible investigation must make rejection possible.

The three-way promise may not work

Deposit-like safety, investment-like return and share-like liquidity may not be simultaneously deliverable.

A simpler product may be better

A well-designed term deposit, bank bond or diversified fixed-income investment may create clearer consumer value at lower cost.

Liquidity may destroy the funding benefit

If customers require the bank to buy the investment back at principal whenever they choose, the bank may not receive the stable contractual funding that justified the product.

Mortgage linkage may add more complexity than value

A purpose statement may be too weak. A mortgage cover pool may be credible but expensive. Direct mortgage exposure would change the risk allocation and the product itself.

Customer and bank economics may never meet

Informed customers may require a return above the bank’s all-in funding value.

Specialists may validate different products

Legal, prudential, accounting, tax, Treasury and consumer conclusions can appear favourable while relying on inconsistent assumptions. Every discipline must assess the same versioned terms.

Explore challenge and defence

Three structures under controlled validation

One question. Three materially different customer claims.

Cell A

Purpose-branded term deposit

A fixed-term Australian-dollar deposit with controlled mortgage-funding attribution.

Potential strength
Familiar claim and potential protected-deposit pathway, subject to confirmation.
Primary weakness
May be only a more expensive term deposit with little incremental funding value.
Current status
Continue as the baseline and potential kill comparator.

Cell B

Senior unsecured retail note

A fixed-rate senior obligation of the issuing bank, potentially transferable between investors at market value.

Potential strength
Clear investment form and hard contractual maturity.
Primary weakness
Likely non-FCS issuer exposure and customer acceptance of market-price exit risk.
Current status
Continue as the leading investment-form validation cell.

Cell C

Mortgage-covered retail note

A bank obligation supported by an identified residential mortgage cover pool, subject to legal and prudential confirmation.

Potential strength
Stronger and more verifiable mortgage linkage.
Primary weakness
Higher encumbrance, legal, collateral, assurance and operating burden.
Current status
Continue conditionally.
Explore structural options

How the investigation was built

The proposition was attacked before it was defended.

  1. Consumer evidence

    Tested the possible gap between deposits, securities and property, including protection, return, term, liquidity, trust and reasons for rejection.

  2. Treasury economics

    Tested whether contractual tenure can create incremental bank value after source attribution, cannibalisation, pricing, hedging, liquidity and all costs.

  3. Comparable products

    Examined deposits, retail notes, covered bonds, securitisation and mortgage funds in Australia and overseas without claiming HomeFund is unprecedented.

  4. Structural options

    Screened the legal, prudential, accounting, tax, conduct and operating consequences of the credible forms.

  5. Specialist-validation design

    Created common assumptions, validation cells, specialist briefs, dependency controls and explicit stop, park, reject and redesign outcomes.

No specialist opinion or regulator position has been obtained. The next substantive step is controlled specialist engagement and evidence collection, not a product build or business case.

Evidence snapshot

A controlled body of work, not proof of viability.

60Approved external sources

Used only within their recorded findings, limitations and permitted purposes.

18Adversarial challenges

The strongest reasons the proposition may fail, with current responses, residual risks and evidence still required.

16Controlled decisions

Approved directions and preserved assumptions, including matters that remain provisional or open.

0Approved products

No legal form, return, protection mechanism, liquidity promise, business case, pilot or launch has been approved.

Explore evidence and status

Closing section

The value is in finding out whether the proposition survives scrutiny.

HomeFund began with an appealing idea: give consumers a recognisable investment connected to Australian home lending while giving a bank more dependable funding.

The investigation has narrowed that idea rather than confirmed it.

A viable product would need to create informed consumer value over simpler alternatives, provide incremental bank value after every cost and avoid relying on confusion about deposits, protection, mortgages or liquidity. It would also need one coherent answer across legal, prudential, accounting, tax, Treasury, conduct and operations.

The right outcome may be a carefully designed investment, a simpler purpose-branded term deposit, a parked concept or a rejection.

That is the point of the work.