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.
Challenge and defence
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
Every material proposition is assessed through six questions:
What survived the attack
Original proposition
Surviving research direction
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
Rejected as a commercial design
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
It can destroy contractual tenure, create stress outflows and transfer market risk back to the bank.
Rejected without a named legal source of protection
Deposit protection, an unsecured issuer promise and cover-pool recourse are different rights.
Rejected for the initial direction
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
Protected-account, FCS, depositor-priority and Single Customer View continuity remain unresolved.
Rejected for the initial design
It changes the risk allocation, legal form, disclosure and operating model.
Unsupported and excluded from the proposition unless additionality is demonstrated
Changing the funding mix does not itself prove more lending, improved affordability or greater housing supply.
Not supported
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
HomeFund proposition
Those associations can create a proposition that sounds stronger than any available legal structure.
Once customers are shown, together:
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 same familiarity may cause customers to assume:
Major-bank branding may strengthen those assumptions.
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.
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.
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.
A purpose-branded term deposit currently provides:
The note structures create greater distinction only by adding issuer, market-value, disclosure, collateral or operating complexity.
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.
Demand based on misunderstanding is not informed demand.
Theme 2 — Legal claim, protection and disclosure
The same label could describe:
Those forms create materially different FCS, ranking, mortgage, disclosure, tax, accounting and operating outcomes.
Choose the legal claim first.
Continue formal validation only for:
The transferable deposit remains parked, and managed or securitised exposure remains outside the initial direction.
An early market price can fall below principal.
A bank repurchase at principal can:
Principal due at maturity does not protect fair value before maturity.
Reject unconditional at-principal repurchase.
Distinguish:
Every mechanism must identify the cash provider, price, liability treatment, capacity and stress outcome.
Mortgage quality or purpose does not itself protect principal.
Protection must arise from a defined source such as:
None automatically removes issuer risk, creates capital relief or protects early market value.
Define and price each protection pathway separately.
For every cell, specify:
Do not claim FCS, government support, asset security or capital benefit without confirmed treatment.
Do not rely on the legal minimum.
Make the following non-negotiable research gates:
The preliminary Chapter 2L position remains subject to external legal confirmation.
Theme 3 — Mortgage purpose and public claims
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.
Use explicit linkage levels.
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.
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.
Retain bank-wide mortgage purpose but test the operating model cell by cell.
Each cell must identify:
The bank may fund the same mortgages through other sources.
HomeFund may change only the funding mix without increasing:
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.
Theme 4 — Funding economics
The customer return and all additional product costs may exceed the value of:
The product may also cannibalise cheaper balances.
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.
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.
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.
Classify every dollar by source.
Recognise productive conversion only where independently measured contractual-tenure value exceeds:
Major banks already use:
A covered retail note would use existing collateral and covered-bond capacity rather than create new secured-funding technology.
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.
The same duration benefit may already appear in:
Counting it again can manufacture product profitability.
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.
Theme 5 — Liquidity and transfer
Investor puts, practical redemption expectations and bank repurchase obligations can shorten effective maturity and create stress outflows.
Legal transferability does not guarantee:
Retain only market-price transfer as a research hypothesis.
No unconditional at-principal buyback.
Describe each mechanism through:
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:
Park the concept.
Do not progress economics or consumer testing until the exact transfer mechanism is confirmed legally and operationally.
Theme 6 — Governance and coherent product definition
Each specialist may rely on different assumptions about:
Individually favourable opinions can create false convergence and appear to validate a product that no specialist assessed in its final combined form.
Require one controlled product version.
Each opinion must:
The project owner must approve the reconciled position before consumer testing or business-case development.
False-convergence pathway
False-convergence pathway
Required control pathway
Required control pathway
Favourable opinions do not add up where they assess different products.
Contradiction map
| Tension | Consumer benefit sought | Bank or structural consequence | Current treatment |
|---|---|---|---|
| Protection versus issuer risk | Confidence in receiving principal | Protection must come from a deposit regime, issuer promise, collateral or guarantee | Separate by legal cell; no generic protection claim |
| Liquidity versus tenure | Ability to leave early | Early rights, repurchase or support can shorten effective maturity | No unconditional par buyback; transfer only at market value if available |
| Return versus funding cost | Attractive predictable income | Higher return may eliminate bank value or cannibalise deposits | Issue-specific pricing and customer-bank corridor |
| Mortgage purpose versus legal rights | Tangible connection to housing | Stronger linkage requires allocation, assurance, collateral or asset rights | Levels 1–3 active; Level 4 comparator |
| Simplicity versus structural credibility | Easy customer understanding | Stronger rights require more disclosure, operating controls and complexity | Term deposit kill comparator; comprehension gate |
| Distinctiveness versus existing products | Reason to choose HomeFund | Existing deposits, notes or covered bonds may already perform the function | Prove incremental value or simplify |
| Specialist certainty versus changing terms | Confidence that the structure works | A changed term can invalidate every dependent opinion | Versioned 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.
Evidence required next
The challenges cannot be resolved through more persuasive copy.
Challenge decision gate
The investigation should continue only where:
Continue investigation
Continue only where the response survives without weakening consumer value.
Stop, simplify, park or reject
The proposition must stop, simplify, park or be rejected where any applicable condition cannot be met.
Current conclusion
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.