Challenge and defence

The proposition is useful only if it survives the strongest case against it.

HomeFund began as an apparently simple idea: offer consumers a more predictable, principal-protected return while providing a major bank with longer-term funding for residential mortgages.

Adversarial review has made that proposition narrower, more conditional and easier to reject.

The current investigation carries eighteen approved challenges. None is resolved. Each current defence or refinement is a design posture that must still be supported by consumer, bank-specific or specialist evidence.

The purpose of this page is not to win an argument for HomeFund. It is to identify whether a fair, coherent and economically viable proposition remains after the strongest objections are applied.

How the challenge method works

A credible response must do more than provide a plausible explanation.

Every material proposition is assessed through six questions:

  1. PositionWhat is being proposed?
  2. Strongest challengeWhat is the best case against it?
  3. Current treatmentIs the position defended, narrowed, parked or rejected?
  4. Residual riskWhat can still go wrong?
  5. Evidence requiredWhat would change the current view?
  6. Decision consequenceWhat must stop, simplify or be redesigned if the challenge is not resolved?

What survived the attack

The surviving proposition is materially narrower than the original concept.

Original proposition

Original proposition

  • approximately 5 per cent return;
  • bank-provided principal protection;
  • mortgage-linked purpose;
  • share-like or useful liquidity;
  • continuous or familiar availability; and
  • value for both customers and the bank.

Surviving research direction

Current surviving research direction

  • no approved return;
  • approximately 5 per cent retained only as a controlled consumer-research cell;
  • issue-specific pricing under Treasury stop/go authority;
  • three distinct legal validation cells rather than one assumed product;
  • possible principal due at maturity, subject to the exact legal claim;
  • early transfer at market value, if available;
  • no unconditional at-principal bank buyback;
  • mortgage purpose, assured allocation or cover-pool linkage clearly distinguished;
  • bank retains mortgage underwriting and credit-loss risk;
  • no claim of additional lending, housing supply or home-ownership impact;
  • purpose-branded term deposit retained as the mandatory kill comparator; and
  • specialist, consumer and bank-specific validation required before any structure decision.

The investigation continues because a narrower issue-specific retail term-funding channel remains plausible.

That is not evidence that the product is commercially viable or that customers will choose it once all trade-offs are understood.

What did not survive

Some original assumptions have already been rejected or removed from the active direction.

Rejected as a commercial design

Always-on approximately 5 per cent pricing

Approximately 5 per cent remains only a research cell. Pricing would need to be issue specific and supported by the bank’s matched funding economics.

Rejected for the initial design

Unconditional bank buyback at principal

It can destroy contractual tenure, create stress outflows and transfer market risk back to the bank.

Rejected without a named legal source of protection

Generic “principal protected” wording

Deposit protection, an unsecured issuer promise and cover-pool recourse are different rights.

Rejected for the initial direction

Direct mortgage ownership or cash-flow exposure

The bank is currently intended to retain mortgage credit risk, and investors would hold a claim created by the bank rather than own individual loans.

Parked

Transferable deposit as an active cell

Protected-account, FCS, depositor-priority and Single Customer View continuity remain unresolved.

Rejected for the initial design

Managed or securitised mortgage exposure

It changes the risk allocation, legal form, disclosure and operating model.

Unsupported and excluded from the proposition unless additionality is demonstrated

Additional housing or social impact

Changing the funding mix does not itself prove more lending, improved affordability or greater housing supply.

Not supported

An “unprecedented product” claim

No exact comparator was identified in a bounded search, but each major feature exists elsewhere and the search does not prove novelty.

The strongest cross-cutting challenge

The proposition may be attractive only while its trade-offs remain blurred.

HomeFund proposition

  • deposit safety;
  • bank trust;
  • mortgage security;
  • enhanced investment return; and
  • share-like access.

Those associations can create a proposition that sounds stronger than any available legal structure.

Once customers are shown, together:

  • the exact legal claim;
  • Financial Claims Scheme treatment;
  • issuer and resolution exposure;
  • maturity conditions;
  • early market-value risk;
  • fees and tax;
  • mortgage-linkage limits;
  • liquidity mechanism;
  • alternatives; and
  • the possibility that the bank will not support an exit,

informed demand may fall.

At the same time, the return required to compensate customers may exceed the value the bank can economically support.

Theme 1 — Consumer value and comprehension

The proposition fails if demand depends on misunderstanding or if a simpler product is better.

HF-ADV-005 — Deposit confusion and conduct risk

Position
Familiar savings and home-lending language may make the product easier to understand.
Strongest challenge

The same familiarity may cause customers to assume:

  • deposit status;
  • Financial Claims Scheme protection;
  • no issuer risk;
  • access at principal;
  • stronger mortgage rights; or
  • more mandatory disclosure than the legal form provides.

Major-bank branding may strengthen those assumptions.

Current treatment

Refine and test.

Comprehension is a core viability gate, not a disclosure exercise.

Any note cell must use prospectus-equivalent disclosure, target-market-determination-equivalent governance, independent review, controlled distribution and ongoing reporting even where the legal minimum may be lower.

Residual risk
Voluntary controls may be weakened over time and may not overcome major-bank, protection or mortgage-purpose heuristics.
Evidence required
  • external legal confirmation;
  • Board-approved disclosure governance;
  • independent assurance;
  • randomised comprehension testing;
  • reasons-for-rejection analysis; and
  • evidence that demand persists after misconceptions are corrected.

HF-ADV-008 — Three-way product promise may be irreconcilable

Position
HomeFund seeks intended principal protection, an enhanced or stable return and useful liquidity.
Strongest challenge

Deposit-like safety, investment-like return and share-like liquidity may not be simultaneously deliverable at fair customer value and acceptable bank economics.

Comparable products typically constrain at least one of those features because someone must bear the cost, risk or optionality.

Current treatment

Separate and test rather than defend the combined promise.

Protection, return, term, issuer exposure, liquidity, fees and mortgage linkage must be shown together across the three validation cells.

No structure should be selected until legal, Treasury and consumer evidence identifies a feasible combination.

Residual risk
Clear disclosure may materially reduce appeal, while stronger protection or liquidity may remove the bank funding benefit.
Evidence required
  • side-by-side cell economics;
  • structure-specific legal and prudential analysis;
  • informed concept testing;
  • liquidity stress design; and
  • conduct assessment.

HF-ADV-015 — A simpler existing product may dominate HomeFund

Position
HomeFund may offer distinctive value beyond existing deposits, bank notes or fixed-income investments.
Strongest challenge

A purpose-branded term deposit currently provides:

  • the clearest legal claim;
  • the strongest potential FCS pathway;
  • mature operations; and
  • the simplest customer explanation.

The note structures create greater distinction only by adding issuer, market-value, disclosure, collateral or operating complexity.

Current treatment

Use Cell A as the mandatory kill comparator.

Compare Cells A, B and C under the same customer-value, funding, protection, linkage, liquidity, tax, accounting, operating and stress assumptions.

Stop or simplify HomeFund where no investment form demonstrates net incremental value.

Residual risk
The coherent structure may be unattractive, while the attractive structure may be uneconomic or indistinguishable from an existing deposit.
Evidence required
  • specialist validation;
  • one side-by-side controlled cell model;
  • informed customer testing using actual rights and alternatives; and
  • proof that any investment-form benefit exceeds its complexity.

Demand based on misunderstanding is not informed demand.

Theme 2 — Legal claim, protection and disclosure

HF-ADV-001 — Product-classification contradiction

Position
HomeFund is intended to be an investment product with bank-provided principal protection.
Strongest challenge

The same label could describe:

  • a protected deposit;
  • an ADI debenture;
  • a covered bank obligation; or
  • a managed-scheme interest.

Those forms create materially different FCS, ranking, mortgage, disclosure, tax, accounting and operating outcomes.

Current treatment

Choose the legal claim first.

Continue formal validation only for:

  • Cell A — purpose-branded term deposit;
  • Cell B — senior unsecured retail note; and
  • Cell C — mortgage-covered retail note.

The transferable deposit remains parked, and managed or securitised exposure remains outside the initial direction.

Residual risk
The legally coherent form may not support the intended investment positioning or customer-value proposition.
Evidence required
  • external legal classification;
  • APRA treatment;
  • accounting and tax sign-off;
  • disclosure analysis; and
  • structure-specific consumer testing.

HF-ADV-003 — Capital protection conflicts with market liquidity

Position
Customers may be able to sell to other investors or obtain access through the bank.
Strongest challenge

An early market price can fall below principal.

A bank repurchase at principal can:

  • transfer market and liquidity risk to the bank;
  • shorten effective maturity;
  • extinguish the issuer liability;
  • create intervention expectations; and
  • contribute to run dynamics.

Principal due at maturity does not protect fair value before maturity.

Current treatment

Reject unconditional at-principal repurchase.

Distinguish:

  • investor transfer;
  • issuer repurchase; and
  • redemption.

Every mechanism must identify the cash provider, price, liability treatment, capacity and stress outcome.

Residual risk
Customers may face a loss or no buyer, while discretionary bank support may create effective optionality and reputational expectations.
Evidence required
  • legal terms;
  • accounting extinguishment treatment;
  • prudential maturity;
  • valuation and market-making economics;
  • stress testing; and
  • informed acceptance of early market loss.

HF-ADV-013 — Bank protection provides no free capital or insurance benefit

Position
The bank may provide principal certainty while retaining mortgage credit risk.
Strongest challenge

Mortgage quality or purpose does not itself protect principal.

Protection must arise from a defined source such as:

  • an eligible deposit regime;
  • issuer obligation and priority;
  • cover-pool recourse;
  • a reserve;
  • a guarantee; or
  • another credit enhancement.

None automatically removes issuer risk, creates capital relief or protects early market value.

Current treatment

Define and price each protection pathway separately.

For every cell, specify:

  • protection provider;
  • legal trigger;
  • ranking;
  • maturity condition;
  • early-exit treatment;
  • resolution outcome; and
  • economic cost.

Do not claim FCS, government support, asset security or capital benefit without confirmed treatment.

Residual risk
Credible protection may consume the economic corridor, require encumbrance or still be misunderstood as protection from every issuer or market outcome.
Evidence required
  • legal form and ranking;
  • insolvency and resolution analysis;
  • FCS eligibility;
  • collateral or guarantee mechanics;
  • capital, accounting and tax treatment;
  • protection cost; and
  • comprehension testing.

HF-ADV-017 — ADI disclosure exemption may weaken customer protection

Position
A major-bank retail note may be issued efficiently through the existing ADI securities framework.
Strongest challenge
A possible Chapter 6D exemption may result in fewer mandatory disclosure or trustee safeguards than consumers infer from the product’s complexity and major-bank branding.
Current treatment

Do not rely on the legal minimum.

Make the following non-negotiable research gates:

  • prospectus-equivalent disclosure;
  • target-market-determination-equivalent governance;
  • independent review;
  • controlled distribution;
  • ongoing reporting;
  • significant-dealing escalation; and
  • outcome monitoring.

The preliminary Chapter 2L position remains subject to external legal confirmation.

Residual risk
Voluntary controls may not create equivalent enforcement or investor rights and may be weakened after launch.
Evidence required
  • external legal opinion;
  • ASIC engagement where appropriate;
  • Board-approved disclosure policy;
  • independent assurance; and
  • consumer comprehension testing.

Theme 3 — Mortgage purpose and public claims

A mortgage label must describe the rights and controls that actually exist.

HF-ADV-004 — “Dedicated to mortgages” may be misleading

Position
Customer funds support the bank’s residential mortgage book.
Strongest challenge

Bank funding is ordinarily managed at enterprise level.

A purpose statement, assured allocation, cover-pool security and direct mortgage interest are not equivalent.

Without credible controls, the mortgage claim may be marketing rather than a verifiable use of funds and may be mistaken for security or ownership.

Current treatment

Use explicit linkage levels.

  • Level 1 — purpose statement;
  • Level 2 — controlled allocation and assurance;
  • Level 3 — mortgage cover pool;
  • Level 4 — direct asset or securitisation interest.

Levels 1–3 remain active research. Level 4 is a comparator, not the initial direction.

Customer wording must not imply rights beyond the implemented level.

Residual risk
Even an assured allocation may be interpreted as security, additional lending or mortgage ownership.
Evidence required
  • legal and Treasury analysis;
  • auditable allocation or collateral method;
  • reporting and independent assurance;
  • insolvency and security analysis; and
  • conduct testing of customer interpretation.

HF-ADV-006 — Whole-book exposure may not simplify all management

Position
Using the overall mortgage book avoids customer-selected pools and adverse selection.
Strongest challenge

Whole-book wording does not remove the legal, prudential, accounting, tax, data, assurance and operational differences between linkage levels.

Stronger linkage can create disproportionate cost.

Current treatment

Retain bank-wide mortgage purpose but test the operating model cell by cell.

Each cell must identify:

  • legal claim;
  • allocation or collateral method;
  • accounting treatment;
  • data lineage;
  • assurance;
  • reporting;
  • technology; and
  • accountable operating owner.
Residual risk
The simple structure may provide only a weak purpose claim, while the credible mortgage-linked structure may be too expensive or complex.
Evidence required
  • end-to-end operating models;
  • accounting and tax papers;
  • data lineage;
  • allocation or collateral assurance;
  • legal-rights analysis; and
  • activity-based costing.

HF-ADV-007 — Claimed social benefit may not be additional

Position
HomeFund may support home ownership or residential lending outcomes.
Strongest challenge

The bank may fund the same mortgages through other sources.

HomeFund may change only the funding mix without increasing:

  • approvals;
  • affordability;
  • housing supply;
  • competition; or
  • home ownership.
Current treatment

Remove social and additionality claims from the base proposition.

The public investigation may discuss mortgage funding purpose, but it must not claim additional lending or housing outcomes without a causal counterfactual.

Residual risk
Mortgage-purpose language may still create an unsupported impression of social impact.
Evidence required
  • approved impact hypothesis;
  • causal counterfactual;
  • measurement framework;
  • governance for public claims; and
  • evidence separating funding substitution from additional outcomes.

Theme 4 — Funding economics

A plausible Treasury explanation does not establish incremental bank value.

HF-ADV-002 — Funding advantage may disappear

Position
More stable committed funds may be worth more than at-call balances.
Strongest challenge

The customer return and all additional product costs may exceed the value of:

  • the displaced deposit;
  • alternative wholesale funding;
  • contractual tenure;
  • diversification; and
  • contingency capacity.

The product may also cannibalise cheaper balances.

Current treatment

Do not claim a funding advantage.

Continue only to bank-specific, source-attributed, matched-tenor feasibility analysis.

The contractual-tenure defence survives as a hypothesis, not proven value.

Residual risk
HomeFund may be less valuable than established funding sources or viable only at a customer return too low to attract informed demand.
Evidence required
  • Treasury funds-transfer pricing;
  • source attribution;
  • all-in cost;
  • cannibalisation;
  • sensitivity and stress scenarios;
  • required bank benefit; and
  • informed customer return.

HF-ADV-009 — Static target return destroys funding economics

Position
HomeFund may offer approximately 5 per cent while improving bank funding economics.
Strongest challenge
Approximately 5 per cent exceeded published March 2026 aggregate estimates for major-bank at-call deposits, deposits, term deposits, debt and total funding before HomeFund’s additional costs.
Current treatment

Reject approximately 5 per cent as an always-on commercial design.

Retain it only as a disclosed consumer-research cell.

Any future pricing must be issue specific and Treasury controlled.

Residual risk
The minimum informed customer return may remain above the maximum economically supportable return in every practical issuance window.
Evidence required
  • bank-specific matched curves;
  • full non-return costs;
  • source mix;
  • stress scenarios; and
  • informed customer research.

HF-ADV-010 — Internal transfer can be productive conversion or destructive cannibalisation

Position
HomeFund may convert liquid balances into more stable funding.
Strongest challenge

Existing customers may transfer persistent, low-cost balances whose behaviour, internal pricing and hedge value already benefit the bank.

Gross internal transfer can therefore reduce value.

Current treatment

Classify every dollar by source.

Recognise productive conversion only where independently measured contractual-tenure value exceeds:

  • the higher return;
  • all incremental costs;
  • the full economic value of the displaced balance;
  • existing FTP value;
  • structural or replicating hedge value; and
  • risk buffers.
Residual risk
Productive conversion may be a small share of sales or may not support an informed customer return.
Evidence required
  • cohort behaviour;
  • deposit beta;
  • FTP;
  • hedge attribution;
  • earliest-exit terms;
  • replacement-funding impact;
  • control-group behaviour; and
  • independent model validation.

HF-ADV-012 — Existing funding and hedging tools already capture much of the value

Position
HomeFund may provide a uniquely useful mortgage-funding channel.
Strongest challenge

Major banks already use:

  • deposits;
  • term deposits;
  • senior debt;
  • structural hedges;
  • covered bonds; and
  • securitisation.

A covered retail note would use existing collateral and covered-bond capacity rather than create new secured-funding technology.

Current treatment

Compare HomeFund with the actual bank counterfactual.

For Cell C, use the same collateral, encumbrance, APRA limit, issuance, hedge, servicing and stress assumptions as the institutional covered-bond program.

Recognise only incremental retail-channel value.

Residual risk
Retail distribution may consume scarce capacity and add fixed cost without creating enough diversification or customer value.
Evidence required
  • bank-specific covered-bond capacity;
  • collateral and encumbrance analysis;
  • matched institutional issuance economics;
  • minimum retail issue scale; and
  • independent Treasury and Finance validation.

HF-ADV-014 — Contractual-tenure value may be double counted

Position
The bank may justify a customer premium through contractual funding certainty.
Strongest challenge

The same duration benefit may already appear in:

  • behavioural deposit modelling;
  • funds-transfer pricing;
  • structural or replicating hedges;
  • liquidity transfer pricing; or
  • central balance-sheet management.

Counting it again can manufacture product profitability.

Current treatment

Use one controlled benefit ledger.

Deduct existing FTP and hedge value, reconcile to the general ledger and require independent Finance or Model Risk validation before tenure value enters pricing.

Residual risk
Internal models may not isolate marginal value cleanly, and management judgement may bias the result.
Evidence required
  • deposit-cohort behaviour;
  • FTP methodology;
  • hedge attribution;
  • liquidity transfer pricing;
  • general-ledger reconciliation;
  • sensitivity testing;
  • back-testing; and
  • independent validation.

Theme 5 — Liquidity and transfer

Legal transferability is not dependable access.

HF-ADV-011 — Liquidity promise removes stable tenor

Position
Secondary-market sale or bank buyback may provide access while preserving funding stability.
Strongest challenge

Investor puts, practical redemption expectations and bank repurchase obligations can shorten effective maturity and create stress outflows.

Legal transferability does not guarantee:

  • a buyer;
  • acceptable price;
  • principal;
  • narrow spread; or
  • market depth under stress.
Current treatment

Retain only market-price transfer as a research hypothesis.

No unconditional at-principal buyback.

Describe each mechanism through:

  • counterparty;
  • capacity;
  • price;
  • issuer-liability treatment;
  • term effect; and
  • stress outcome.
Residual risk
Market depth may disappear and customers may still expect bank intervention.
Evidence required
  • legal terms;
  • prudential treatment;
  • minimum issue scale;
  • market-maker economics;
  • normal and stressed depth;
  • valuation;
  • customer acceptance of loss; and
  • conduct testing.

HF-ADV-016 — Transferability may destroy protected-deposit value

Position
A transferable deposit may combine deposit protection, bank tenure and customer liquidity.
Strongest challenge

Protected-account and Single Customer View treatment depend on the account-holder relationship.

Transfer, novation, nominee holding or a security wrapper may leave the investor without:

  • the protected account;
  • FCS treatment;
  • depositor priority; or
  • scalable operational records.
Current treatment

Park the concept.

Do not progress economics or consumer testing until the exact transfer mechanism is confirmed legally and operationally.

Residual risk
The legally clean mechanism may be unscalable, while the scalable mechanism may no longer be a protected deposit.
Evidence required
  • Banking Act and Corporations Act analysis;
  • APS 910 treatment;
  • account terms;
  • assignment and novation mechanics;
  • registry architecture;
  • APRA engagement; and
  • external legal opinion.

Theme 6 — Governance and coherent product definition

Favourable specialist opinions do not add up where they assess different products.

HF-ADV-018 — Specialist opinions may validate different products

Position
Separate legal, prudential, accounting, tax, Treasury and consumer opinions may collectively establish that HomeFund is ready to progress.
Strongest challenge

Each specialist may rely on different assumptions about:

  • term;
  • holder;
  • protection;
  • transfer;
  • redemption;
  • mortgage linkage;
  • distribution;
  • issuer support; or
  • product wording.

Individually favourable opinions can create false convergence and appear to validate a product that no specialist assessed in its final combined form.

Current treatment

Require one controlled product version.

Each opinion must:

  • identify the validation cell and exact term-sheet version;
  • state every changed assumption;
  • map dependencies;
  • be re-opened after material changes; and
  • participate in mandatory cross-specialist reconciliation.

The project owner must approve the reconciled position before consumer testing or business-case development.

Residual risk
Specialists may qualify advice narrowly, dependencies may remain hidden and management may aggregate favourable conclusions while discounting conflicts.
Evidence required
  • version-controlled term sheets;
  • assumptions comparison;
  • dependency register;
  • specialist sign-offs;
  • reconciliation workshop record; and
  • project-owner decision.

False-convergence pathway

False-convergence pathway

  1. different specialist assumptions;
  2. individually favourable conclusions;
  3. apparent product approval;
  4. no specialist assessed the combined product.

Required control pathway

Required control pathway

  1. controlled assumptions schedule;
  2. versioned cells and term sheets;
  3. dependency mapping;
  4. changed-term reopening;
  5. cross-specialist reconciliation;
  6. project-owner decision.

Favourable opinions do not add up where they assess different products.

Contradiction map

The principal tensions cannot be solved independently.

Principal HomeFund tensions and their current treatment
TensionConsumer benefit soughtBank or structural consequenceCurrent treatment
Protection versus issuer riskConfidence in receiving principalProtection must come from a deposit regime, issuer promise, collateral or guaranteeSeparate by legal cell; no generic protection claim
Liquidity versus tenureAbility to leave earlyEarly rights, repurchase or support can shorten effective maturityNo unconditional par buyback; transfer only at market value if available
Return versus funding costAttractive predictable incomeHigher return may eliminate bank value or cannibalise depositsIssue-specific pricing and customer-bank corridor
Mortgage purpose versus legal rightsTangible connection to housingStronger linkage requires allocation, assurance, collateral or asset rightsLevels 1–3 active; Level 4 comparator
Simplicity versus structural credibilityEasy customer understandingStronger rights require more disclosure, operating controls and complexityTerm deposit kill comparator; comprehension gate
Distinctiveness versus existing productsReason to choose HomeFundExisting deposits, notes or covered bonds may already perform the functionProve incremental value or simplify
Specialist certainty versus changing termsConfidence that the structure worksA changed term can invalidate every dependent opinionVersioned cells and mandatory reconciliation

The proposition does not become viable by resolving only one side of a tension.

Current challenge outcomes

No challenge is closed.

Retained as a hypothesis

  • informed consumer interest may exist;
  • hard contractual funding may have incremental value;
  • a senior retail note may provide a distinct investment-form channel;
  • a covered retail note may create meaningful collateral linkage;
  • investor-to-investor transfer may preserve the issuer liability.

Narrowed

  • mortgage purpose is separated from mortgage security;
  • protection is limited to a defined legal pathway;
  • liquidity is described by mechanism and market price;
  • internal conversion is valuable only where incremental;
  • disclosure standards exceed a possible legal minimum;
  • every issue is Treasury controlled.

Parked

  • transferable deposit;
  • any design requiring unresolved protected-account continuity;
  • structure progression where threshold specialist questions remain open.

Rejected for the initial design

  • unconditional at-principal bank buyback;
  • always-on approximately 5 per cent pricing;
  • managed or securitised mortgage exposure;
  • direct mortgage ownership or first-loss exposure;
  • unsupported social additionality;
  • generic FCS or capital-protection claims.

Still open

  • informed demand;
  • legal form;
  • FCS treatment;
  • prudential treatment;
  • accounting;
  • tax;
  • pricing;
  • liquidity mechanism;
  • operating scale;
  • protection cost;
  • market depth;
  • business case; and
  • structure selection.

No challenge is closed.

Evidence required next

The challenges cannot be resolved through more persuasive copy.

Consumer evidence

  • qualitative exploration;
  • side-by-side cell testing;
  • randomised comprehension testing;
  • reasons for rejection;
  • minimum informed return;
  • acceptance of non-FCS issuer exposure;
  • acceptance of term and early market-value risk; and
  • evidence that demand persists after correction of misconceptions.

Bank-specific economics

  • source-of-funds attribution;
  • matched funding curves;
  • displaced-deposit economics;
  • contractual-tenure value;
  • one controlled benefit ledger;
  • liquidity and market-support costs;
  • operating cost;
  • stress testing;
  • required bank return; and
  • independent Finance or Model Risk validation.

Specialist evidence

  • legal classification;
  • FCS and insolvency ranking;
  • APRA treatment;
  • accounting paper;
  • tax paper;
  • disclosure and licensing;
  • structure-specific term sheets; and
  • mandatory cross-specialist reconciliation.

Operating and market evidence

  • registry and servicing architecture;
  • allocation or cover-pool assurance;
  • valuation and transfer process;
  • market-maker or matched-window feasibility;
  • normal and stressed market depth;
  • complaints, hardship, deceased-estate and scam controls;
  • resilience and recovery; and
  • minimum viable issue scale.

The challenges cannot be resolved through more persuasive copy.

Challenge decision gate

Continue only where the response survives without weakening consumer value.

The investigation should continue only where:

  1. the legal claim can be explained accurately;
  2. informed customers understand protection, issuer risk, term and early value;
  3. the minimum informed return fits inside the bank-economic corridor;
  4. mortgage linkage can be verified without implying ownership or additionality;
  5. liquidity does not destroy the funding rationale;
  6. every benefit is incremental and counted once;
  7. the structure performs better than the purpose-branded term-deposit comparator;
  8. operations and controls can support the intended scale;
  9. specialist conclusions apply to one reconciled product version; and
  10. residual risk remains acceptable under stress.

Continue investigation

Continue investigation

Continue only where the response survives without weakening consumer value.

Stop, simplify, park or reject

Stop, simplify, park or reject

The proposition must stop, simplify, park or be rejected where any applicable condition cannot be met.

Current conclusion

HomeFund has survived as a disciplined investigation, not as a validated product.

The original concept has not survived intact.

What remains is a narrower question:

Can one of three defined bank-liability structures create enough informed customer value and enough incremental bank value to justify its legal, liquidity, conduct and operating costs?

The current evidence does not answer that question.

It does show how the proposition must be tested and what must be rejected if the evidence does not support it.

That is the present value of HomeFund: not proof that the product should exist, but a transparent framework for deciding whether it should.