Consumer case

A plausible consumer question is not proof of demand.

HomeFund tests whether there is useful space between familiar deposits and investments that involve greater volatility, complexity or operational effort.

The question is legitimate. Many people value stability, income, access and understandable choices. Residential property is also a familiar part of Australian household wealth. None of that establishes that consumers want HomeFund, understand it or would prefer it to a simpler alternative.

The consumer case succeeds only if people continue to see value after the legal claim, Financial Claims Scheme position, issuer exposure, mortgage rights, term, early value, fees, tax and alternatives are presented together.

The HomeFund consumer research plan is approved but has not commenced. No HomeFund participant evidence, demand forecast or target market exists.

Start with the choices people already have

HomeFund would enter an established landscape, not an empty market.

Consumers can already choose among products with materially different purposes, risks and access conditions.

  • At-call savings

    Familiar and accessible, with returns that can change. Eligible accounts may receive Financial Claims Scheme protection within the applicable limits and conditions.

  • Term deposits

    A defined term and rate with deposit-style familiarity. Early access may be restricted or adjusted, and the product may still be a stronger baseline than a new investment form.

  • Government and corporate debt

    Contractual income and repayment obligations, with issuer, interest-rate and market-value risk before maturity.

  • Bond funds and diversified fixed-income funds

    Diversified exposure and generally easier dealing, but without a promise that the investment value will remain at the original amount.

  • Shares and diversified growth funds

    Potential income and growth with market volatility and no principal-protection promise.

  • Direct property

    A tangible and familiar asset that normally requires substantial capital and brings concentration, transaction, maintenance and management obligations.

  • Mortgage and private-credit funds

    More direct credit exposure, generally with risks and liquidity conditions that HomeFund currently intends the bank to retain rather than pass to investors.

  • No investment

    Keeping money available, reducing debt or not taking additional investment risk is also a legitimate choice.

What the evidence supports

The existing evidence justifies testing, not selling.

Evidence supported

Evidence supports

  • investing beyond the home and super is common;
  • stability and income matter;
  • return, risk, fees, access and lock-up are considered together;
  • online investment interfaces are familiar to many existing investors; and
  • housing, deposits and financial investments are material household assets.

Open / validation required

Evidence does not establish

  • an unmet HomeFund market;
  • willingness to invest or switch funds;
  • acceptable return, term, fee or amount;
  • informed acceptance of issuer or non-FCS risk;
  • acceptance of variable resale value;
  • incremental mortgage-purpose appeal;
  • a target market; or
  • viability.

HF-SRC-001

Investing beyond the home and superannuation is common

The ASX Australian Investor Study 2023 reported that 51 per cent of Australian adults held investments outside their primary residence and ordinary superannuation arrangements.

Limitation: The fieldwork occurred in November 2022 and did not test HomeFund or a mortgage-linked bank investment.

HF-SRC-001

Stability and income matter to many investors

The same study found that stable or guaranteed returns were selected as the preferred risk posture by 77 per cent of intending investors and 67 per cent of investors. Sustainable income was also a meaningful investment goal.

Limitation: A preference for stability is not acceptance of issuer risk, a long term, uncertain early value or a non-FCS investment.

HF-SRC-001

People consider return, risk, fees and access together

Potential return and risk were prominent decision factors. Fees, access to money and the period for which capital is locked away also mattered.

Implication: Headline return cannot be separated from term, liquidity, protection conditions and cost.

HF-SRC-001

Digital investing is familiar to many existing investors

Seventy per cent of on-exchange investors in the study used an online broker or trading platform to place orders.

Limitation: Interface familiarity does not prove product comprehension and must not be used to make an unfamiliar bank liability look like an ordinary share.

HF-SRC-004

Housing, deposits and financial investments are all material

Australian household balance sheets contain substantial residential property, deposits, shares and superannuation.

Limitation: Aggregate wealth does not reveal how much money is available to invest, whether people would switch it or whether HomeFund creates a market.

The evidence supports a disciplined consumer test. It does not establish an unmet market, acceptable terms, preferred structure, willingness to invest or viability.

The possible consumer value

What HomeFund is actually testing

HomeFund tests whether some consumers would value a combination of:

  • a recognisable purpose connected to Australian residential home lending;
  • no direct property purchase, tenants, maintenance or large property deposit;
  • a return intended to be more predictable than an at-call savings rate;
  • principal due at a defined contractual maturity;
  • a possible way to transfer the investment before maturity; and
  • clearer reporting about how the bank attributes the funds to mortgage funding.

Every element remains conditional.

A mortgage purpose does not itself give the investor ownership of mortgages, mortgage cash flows or security over the mortgage book. Principal due at maturity does not promise the original amount on an early sale. A transfer mechanism does not guarantee a buyer or an acceptable price. Bank branding does not determine Financial Claims Scheme coverage.

The possible value therefore depends less on whether the idea initially sounds appealing and more on whether the final structure remains attractive after those distinctions are understood.

Why familiarity can mislead

The language that makes a product easy to recognise can also make it easy to misunderstand.

ASIC’s earlier qualitative research into capital-protected and capital-guaranteed investments identified a perceived gap for a stable investment from a trusted source with returns above term deposits and less volatility or effort than shares.

It also identified the central conduct risk.

Some participants interpreted capital protection as a complete guarantee. Some treated a structured investment as a higher-rate term deposit. Some relied on the issuer’s brand rather than understanding the legal structure. Conditions on protection, early exit, fees, inflation, opportunity cost and changed personal circumstances were often poorly understood.

That research was small, qualitative and conducted more than a decade ago. The products were often more complex than the intended HomeFund direction. It cannot establish current demand.

It does show why HomeFund cannot use familiarity as a substitute for comprehension.

The proposition must not be framed as:

A savings account combined with a share-trading experience.

That description embeds the very category confusion the research needs to detect.

What a consumer must understand

Eight questions must be answerable before preference can count.

1. What is the product?

Common inference

“Major-bank product”

What must be confirmed

Is it a deposit, a senior bank note, a covered obligation or another legal form? The HomeFund name cannot answer that question.

2. Does the Financial Claims Scheme apply?

Common inference

“Protected”

What must be confirmed

Financial Claims Scheme protection applies to eligible deposits within its rules. It cannot be assumed for an investment merely because a major bank issues or distributes it.

3. Who owes the principal?

Common inference

“Principal protected”

What must be confirmed

The exact obligor, legal ranking, maturity conditions and consequences of issuer failure must be clear.

4. What connection exists to mortgages?

Common inference

“Mortgage linked”

What must be confirmed

Does the product contain only a purpose statement, a controlled funding allocation, a mortgage cover pool or direct rights to mortgage assets or cash flows?

The current active structures do not give investors ownership of individual mortgages.

5. When is principal due?

Common inference

“Principal is always available”

What must be confirmed

A contractual amount due at maturity is different from an early exit price. The consumer must understand the term and every condition affecting access.

6. What happens before maturity?

Common inference

“Can sell”

What must be confirmed

An investor-to-investor transfer can occur below the original amount and may have no willing buyer. A discretionary bank purchase is not the same as a legal obligation to repurchase.

7. What creates the return and what reduces it?

Common inference

“Approximately 5 per cent”

What must be confirmed

The return, fees, tax, inflation and opportunity cost must be considered together. Approximately 5 per cent remains only a controlled research cell, not an approved rate.

8. Why choose it over a simpler alternative?

Common inference

“A better alternative”

What must be confirmed

The comparison must include savings, term deposits, bonds, diversified fixed-income funds, shares, property, mortgage or private-credit funds and no investment.

A customer should be able to explain these points accurately to another person. Confidence without accuracy is not comprehension.

Six perspectives the research must include

These are sampling perspectives, not target customers.

Research sampling perspective · Not a target market

Defensive yield seekers

People holding cash or term deposits who may want improved income but resist capital volatility.

Core question: Why accept more complexity, issuer exposure or weaker access than a deposit?

Research sampling perspective · Not a target market

Property-oriented diversifiers

People who understand residential property but cannot or do not want to buy another property.

Core question: Without ownership of property or mortgages, what exposure are they receiving?

Research sampling perspective · Not a target market

Low-confidence intending investors

People who want to invest but lack confidence, product knowledge or trusted information.

Core risk: Bank branding and protection language may encourage action before understanding.

Research sampling perspective · Not a target market

Self-directed income investors

People using shares, exchange-traded funds or online platforms who may consider another income allocation.

Core question: Why accept concentrated exposure to one bank and Australian housing rather than use diversified alternatives?

Research sampling perspective · Not a target market

Capital-preservation investors

Pre-retirees, retirees and others prioritising reliable income and retention of capital.

Core questions: What happens when funds are needed early, the issuer weakens, inflation rises or personal circumstances change?

Research sampling perspective · Not a target market

Deliberate rejectors

People who prefer deposits, fixed income, shares, direct property or no investment.

Research rule: Rejection reasons are evidence. They must not be treated as failed sales leads.

These perspectives help the investigation expose different assumptions and objections. They do not establish eligibility, market size, adoption or distribution.

Reasons a consumer may reject HomeFund

Rejection can be the informed and appropriate outcome.

A consumer may reasonably conclude that:

Value

  • the return premium is too small for the additional complexity;
  • an ordinary term deposit offers a clearer claim;

Protection and issuer risk

  • non-FCS issuer exposure is unacceptable;

Term and access

  • the term is too long;
  • early sale below principal is unacceptable;
  • the bank is not legally required to provide liquidity;

Mortgage rights

  • the mortgage connection is weaker than expected;

Concentration and diversification

  • the investment creates concentration in one issuer or Australian housing;
  • a diversified fund provides better risk spreading;

Cost and tax

  • fees or tax reduce the value;

Social-purpose credibility

  • the social or housing-purpose claim does not demonstrate additional impact;

Personal preference or no investment

  • keeping money accessible or reducing debt is preferable.

A responsible test must capture these reasons without trying to explain them away.

From initial appeal to informed demand

Purchase intention is not the endpoint.

  1. Step 1 — Initial interpretation

    What category does the person think HomeFund belongs to before receiving detailed information?

  2. Step 2 — Full explanation

    Show the legal claim, return source, protection conditions, issuer exposure, mortgage linkage, term, liquidity, resale-price risk, fees, tax and alternatives together.

  3. Step 3 — Comprehension check

    Can the person accurately explain the product and respond to realistic scenarios, including issuer stress, higher deposit rates, early cash needs and a resale value below principal?

  4. Step 4 — Correct misunderstandings

    Make every material misunderstanding visible. Do not silently repair it in the analysis or average it into an appeal score.

  5. Step 5 — Informed preference or rejection

    Only preference expressed after accurate comprehension can contribute to an informed-demand assessment.

How the consumer research is designed

Three stages separate language, prevalence and behaviour.

  • Plan approved
  • Research not commenced
  • Success thresholds open
  1. Stage 1 — Exploratory qualitative research

    Approximately 30–40 participants across the six sampling perspectives, including deliberate rejectors.

    The objective is to identify spontaneous interpretation, customer language, material misunderstandings, access needs and reasons for rejection.

    Qualitative findings must not be converted into market-size or demand estimates.

  2. Stage 2 — Quantitative concept testing

    A nationally representative sample provisionally in the range of 1,200–1,500 Australian adults.

    Randomised cells would test category wording, mortgage purpose, protection wording, Financial Claims Scheme information, maturity, transfer, conditional buyback, return, fees, minimum investment and neutral alternatives.

    Comprehension, misunderstanding, appeal and rejection must be reported separately.

  3. Stage 3 — Behavioural comprehension testing

    Participants would respond to realistic scenarios, including:

    • the bank’s credit rating falling;
    • mortgage arrears rising;
    • savings and term-deposit rates moving above the HomeFund return;
    • a secondary-market price below original principal;
    • bank purchases being limited or suspended;
    • an early need for money; and
    • issuer failure.

    The purpose is to test practical understanding, not recognition of disclosure wording.

No numerical pass thresholds have been approved. Research completion alone cannot approve HomeFund.

Consumer kill conditions

The consumer case should stop or be redesigned where:

Failure is an acceptable project outcome.

Stop or redesign

Demand depends on misunderstanding

Preference falls away once Financial Claims Scheme status, issuer exposure, protection conditions or early market value are understood.

Stop or redesign

A simpler alternative dominates

A term deposit or existing fixed-income product offers clearer value for the same intended need.

Stop or redesign

The informed return requirement is uneconomic

The minimum return required after full comprehension exceeds what the structure can support.

Stop or redesign

Acceptable access destroys the proposition

Consumers require unconditional access at principal, while providing it removes the bank’s funding benefit or creates unacceptable risk.

Stop or redesign

Mortgage purpose cannot be explained fairly

The connection to residential lending is too weak, complex or easily mistaken for mortgage ownership, security or additional housing impact.

Stop or redesign

Vulnerable consumers remain exposed to category confusion

The product is most attractive to people who are least able to distinguish deposits, investments and protection conditions.

Stop or redesign

Reasons for rejection cannot be resolved without weakening fairness

The product can be made appealing only through omission, framing or complexity rather than genuine value.

Current consumer conclusion

There is enough evidence to ask the question. There is not enough evidence to answer it.

The current evidence suggests a plausible interest in stability, income and recognisable investment purpose. It also shows that bank branding, protection language, familiar interfaces and housing terminology can create serious misunderstanding.

That tension is the consumer case.

HomeFund should proceed only if:

  • the legal structure can be explained simply and accurately;
  • protection, issuer and early-value risks are visible;
  • consumers demonstrate comprehension;
  • informed preference remains after fair comparison;
  • reasons for rejection are understood;
  • the product creates net value over simpler alternatives; and
  • no customer group is being relied upon because it misunderstands the category.

The consumer research has not yet occurred.

No demand, target market, return, fee, term, protection wording, liquidity mechanism or distribution approach has been approved.