Evidence record
60 approved external sources
Approved only for their recorded findings, limitations and permitted uses.
Evidence and status
Sixty approved sources support the investigation. They do not validate the product.
HomeFund has a controlled evidence record covering consumer context, major-bank funding, comparable products, structural options and specialist-validation planning.
It also has eighteen unresolved adversarial challenges and sixteen controlled project decisions.
Those counts demonstrate research discipline and traceability. They do not establish customer demand, a legal structure, bank economics, regulator treatment or a business case.
This page separates external evidence, project decisions, current research directions and matters that have not yet been tested.
Current status
The project is ready for further validation, not product development.
Adversarial record
18 unresolved challenges
No challenge is closed. Current responses remain design postures.
Decision record
16 controlled decisions and assumptions
These define the working scope and research boundaries. They do not approve a product.
Current product state
Working concept
No product, pilot, issue, return, protection mechanism, liquidity promise or business case is approved.
What an approved source means
Approval controls how evidence may be used. It is not an endorsement of HomeFund.
Each source has a controlled record containing:
- source ID;
- title;
- publisher;
- publication date;
- URL;
- access date;
- source type;
- jurisdiction;
- proposition tested;
- finding;
- evidence direction;
- limitations;
- approval status; and
- repository documents that use it.
- Identity and provenance
- Proposition tested
- Finding
- Evidence direction
- Material limitations
- Permitted use
- Downstream traceability
A source may be approved because it:
- supports a bounded hypothesis;
- challenges a proposition;
- supplies market or regulatory context;
- defines a design requirement;
- provides an institutional comparator; or
- identifies specialist questions.
Source approval does not mean:
- the source tested HomeFund;
- the evidence is current in every respect;
- stated preference predicts purchase;
- an international structure transfers directly to Australia;
- a public rule determines the treatment of an undefined product;
- a bank disclosure reveals marginal economics; or
- the publisher endorses the proposition.
Approval controls use; it does not endorse HomeFund.
Every public finding must retain its material limitation.
Research chronology
The proposition became narrower as the evidence base expanded.
Foundation
The project established a consumer-first investigation, a major-bank sponsor assumption and an initial mortgage-book funding concept.
- Output
- Working scope, initial assumptions, decision register and challenge method.
- Not completed
- No product, pilot, issue, return, protection mechanism, liquidity promise or business case is approved.
Consumer evidence and concept-test design
Research examined the gap between deposits and more volatile or complex investments, consumer decision factors, protection misunderstanding and comprehension requirements.
- Output
- A mixed consumer evidence position and a staged concept-testing plan.
- Not completed
- No HomeFund interviews, survey, behavioural test, demand forecast or target-market determination.
Treasury economics
Research examined major-bank funding sources, contractual and behavioural tenure, deposit cannibalisation, funding counterfactuals, hedging, liquidity and prudential constraints.
- Output
- An issue-specific term-funding feasibility hypothesis and a customer–bank economic corridor.
- Not completed
- No bank-internal curves, source attribution, profitability model or validated business case.
Comparable products
Research examined deposits, retail debt, covered bonds, RMBS, mortgage funds and overseas structures.
- Output
- Three active validation cells and evidence that protection, return, mortgage linkage and liquidity involve material trade-offs.
- Not completed
- No proof that HomeFund is novel, viable or preferred to an existing product.
Structural options
Research screened deposit, unsecured-note, covered-note, transferable-deposit and managed or securitised forms across legal, prudential, accounting, tax and operating questions.
- Output
- Cell A, Cell B and Cell C retained for formal validation; one option parked and one rejected initially.
- Not completed
- No legal form, FCS treatment, APRA treatment, accounting conclusion or tax conclusion.
Specialist-validation preparation
The project created common assumptions, versioned cells, specialist briefs, dependency controls and a reconciliation sequence.
- Output
- A controlled engagement and structure-decision process.
- Not completed
- No specialist opinion, regulator position, reconciled term sheet or structure decision.
Public evidence publication
The website translates the controlled record into accessible public copy and diagrams.
- Output
- A subordinate publication layer with source provenance and claim controls.
- Not completed
- Publication does not create product evidence or approval.
Evidence categories
The 60 sources cover five bounded research areas.
HF-SRC-001 to HF-SRC-006
Consumer — 6 sources
Covers investor participation, stability and income needs, decision factors, FCS boundaries, investment comprehension and protection-language risk.
- Permitted conclusion
- There is enough contextual and challenge evidence to justify structured concept testing.
- Not established
- HomeFund demand, market size, target market, acceptable return or informed purchase behaviour.
HF-SRC-007 to HF-SRC-016
Treasury — 10 sources
Covers bank funding costs, liquidity and stable funding, deposit behaviour, securitisation, FCS funding context, structural hedging and interest-rate risk.
- Permitted conclusion
- Public evidence supports bank-specific feasibility work and rejects a static headline-return business case.
- Not established
- An individual bank’s marginal funding value, productive conversion, pricing or profitability.
HF-SRC-017 to HF-SRC-035
Comparable products — 19 sources
Covers covered bonds, retail bonds, mortgage funds, RMBS, brokered deposits, principal-protected products and international mortgage-funding models.
- Permitted conclusion
- Established products reveal relevant mechanisms and trade-offs.
- Not established
- An exact comparator, novelty, transferability to Australia or a viable complete HomeFund promise.
HF-SRC-036 to HF-SRC-053
Structural options — 18 sources
Covers Australian deposit, debenture, covered-bond, disclosure, trustee, financial-product, accounting and tax boundaries.
- Permitted conclusion
- Three structures warrant defined specialist validation.
- Not established
- Legal classification, FCS treatment, prudential treatment, accounting, tax or structure selection.
HF-SRC-054 to HF-SRC-060
Specialist governance and tax certainty — 7 sources
Covers regulator engagement, interpretive and private rulings, class rulings, product rulings and controlled specialist-validation preparation.
- Permitted conclusion
- There are established pathways for seeking defined regulatory and tax certainty after terms are sufficiently settled.
- Not established
- That a regulator or tax authority will accept, review or approve a HomeFund structure.
Evidence quality
Authority, relevance and limitations must be read together.
Primary authority
Legislation, prudential standards, regulator guidance, government statistics, tax rulings and official bank or issuer disclosures.
- Strength
- Strong for the rule, institutional practice or published fact addressed.
- Limitation
- Usually does not classify or price an undefined HomeFund product.
Direct consumer research
National surveys, regulator research and consumer guidance.
- Strength
- Useful for investor context, known misunderstandings and research design.
- Limitation
- No approved source directly tests the current HomeFund cells. Some evidence is historical or qualitative.
Comparable-product evidence
Issuer terms, exchange guidance, official product material and regulator records.
- Strength
- Shows how existing claims, protection, transfer and mortgage linkage work.
- Limitation
- A comparator may differ materially in legal form, market, investor base or public infrastructure.
Interpretation and synthesis
Project research packs, evidence synthesis, decisions and adversarial analysis.
- Strength
- Connects multiple sources into a controlled HomeFund position.
- Limitation
- Project interpretation is not independent evidence, specialist advice or regulator confirmation.
The strongest source is not automatically the most relevant source, and a large source count cannot repair a missing customer, bank-internal or specialist test.
Evidence library
Review each source with its permitted use and limitation.
The public evidence library contains all 60 approved source records.
Use the filters to review sources by:
- category;
- source type;
- jurisdiction;
- evidence direction;
- publisher; and
- source ID or keyword.
Each entry shows:
- source ID;
- title and publisher;
- publication and access dates;
- source type and jurisdiction;
- proposition tested;
- bounded finding;
- evidence direction;
- material limitations;
- approval use; and
- link to the original external source.
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Showing 60 of 60 approved sources
No approved sources match those filters. Reset the filters or broaden your search.
HF-SRC-001
Consumer
Australian Investor Study 2023
ASX Operations Pty Limited
- Publication date
- 2023; fieldwork November 2022
- Access date
- 2026-07-29
- Source type
- Nationally representative online consumer survey; 5,519 Australian adults; maximum sampling error stated as ±1.32% for the full sample
- Jurisdiction
- Australia
- Proposition tested
- Investor participation, goals, risk preferences, decision factors, trust, channels, diversification and barriers
- Bounded finding
- 51% of Australian adults, estimated by the study as 10.2 million people, held investments outside their primary residence and ordinary superannuation arrangements. Potential return, potential risk and personal circumstances were the three most selected investment-decision factors among current investors. Fees, access to money and time capital is locked away were also selected considerations. 77% of intending investors selected either stable or guaranteed returns as their preferred risk posture; the equivalent result among all investors was 67%. Building a sustainable income stream was selected as the main next-year goal by 28% of all investors, 34% of wealth accumulators and 36% of next-generation investors. 70% of on-exchange investors used an online broker or trading platform to place trade orders. Barriers among people who had never invested included insufficient money, low confidence, product uncertainty and difficulty finding trusted information. Banks received a 2023 average trust rating of 5.39 out of 10, below ASX, ASIC, accountants and super funds in the study.
- Evidence direction
- Mixed support for concept testing; not demand validation
- Material limitations
- Fieldwork occurred in November 2022 and may not reflect current market conditions. The study did not test HomeFund, mortgage-linked investments, principal protection, secondary-market sale or bank buyback. ASX has a commercial interest in investment-market participation. Stated preference does not establish purchase behaviour, product comprehension or acceptable pricing.
- Approval use
- Approved for consumer context and research design
HF-SRC-002
Consumer
Retail investor research into structured ‘capital protected’ and ‘capital guaranteed’ investments
Australian Securities and Investments Commission; research produced by Susan Bell Research
- Publication date
- Released 1 May 2013; interviews undertaken in 2011; report revised in 2012
- Access date
- 2026-07-29
- Source type
- Exploratory qualitative consumer research; 25 past, current or potential retail investors in capital-protected or capital-guaranteed structured products
- Jurisdiction
- Australia
- Proposition tested
- Meaning of protection, motivations, comprehension, comparison, advice, disclosure, trust, liquidity and satisfaction
- Bounded finding
- Participants perceived a gap for a stable investment from a trusted source with returns above term deposits and less volatility or effort than direct shares. Some wanted property exposure but lacked sufficient funds; others already held property and wanted diversification. Most participants treated “capital protection” as practically equivalent to a full capital guarantee. Some treated the product like a higher-rate term deposit or simple retail banking product and relied on the issuer brand rather than understanding the structure. Conditions on protection, early exit, fees, inflation, opportunity cost and the consequences of changed personal circumstances were often poorly understood. Some assumed a bank or issuer would be supportive or flexible if early access was needed. Lengthy disclosure did not ensure comprehension. Satisfaction varied even where capital was returned because outcomes, costs and illiquidity differed from expectations.
- Evidence direction
- Strong challenge; limited qualitative support for a perceived gap
- Material limitations
- The evidence is old and based on a small, non-representative qualitative sample. Products examined were generally complex and often derivative-based, unlike the intended HomeFund design. The evidence cannot estimate current demand, market size or purchase probability. Recall, hindsight and sample bias are identified limitations in the report.
- Approval use
- Approved as legacy qualitative challenge evidence only
HF-SRC-003
Consumer
Financial Claims Scheme: Banks, building societies and credit unions
Australian Prudential Regulation Authority
- Publication date
- Current guidance; no publication date stated on the page
- Access date
- 2026-07-29
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Deposit-protection boundary relevant to HomeFund comprehension
- Bounded finding
- APRA states that the FCS protects deposits up to $250,000 for each account holder at each incorporated Australian ADI and identifies transaction, savings, cheque, term-deposit and certain mortgage-offset accounts as covered deposit-account types.
- Evidence direction
- Strong challenge to any assumed investment-product equivalence
- Material limitations
- The guidance does not classify HomeFund or determine whether any possible future structure is an eligible deposit or protected account.
- Approval use
- Approved for FCS-boundary and comprehension research only
View the original source from Australian Prudential Regulation Authority
HF-SRC-004
Consumer
Australian National Accounts: Finance and Wealth, March 2026
Australian Bureau of Statistics
- Publication date
- 25 June 2026
- Access date
- 2026-07-29
- Source type
- Official national accounts
- Jurisdiction
- Australia
- Proposition tested
- Scale and composition of Australian household assets
- Bounded finding
- At March 2026, the ABS reported household land and dwellings of approximately $12.983 trillion, currency and deposits of approximately $2.003 trillion, shares and other equity of approximately $1.712 trillion, and superannuation reserves of approximately $4.470 trillion.
- Evidence direction
- Contextual support only
- Material limitations
- Aggregate household balance-sheet values do not establish investable cash, product demand, willingness to switch or a target market.
- Approval use
- Approved for market context only
View the original source from Australian Bureau of Statistics
HF-SRC-005
Consumer
Choose your investments
ASIC Moneysmart
- Publication date
- Updated 14 July 2026
- Access date
- 2026-07-29
- Source type
- Primary consumer guidance
- Jurisdiction
- Australia
- Proposition tested
- Information consumers need to evaluate an investment
- Bounded finding
- Moneysmart says consumers should understand how an investment works, how it generates returns, its risks, fees, intended holding period, legal and tax implications and contribution to diversification.
- Evidence direction
- Consumer-design and testing requirement
- Material limitations
- Guidance establishes good decision inputs; it is not evidence of actual comprehension, behaviour or HomeFund demand.
- Approval use
- Approved for concept and comprehension-test design
HF-SRC-006
Consumer
Check before you invest
ASIC Moneysmart
- Publication date
- Updated 18 June 2026
- Access date
- 2026-07-29
- Source type
- Primary consumer guidance
- Jurisdiction
- Australia
- Proposition tested
- “Safe” and “guaranteed” investment language and basic comprehension
- Bounded finding
- Moneysmart warns consumers not to believe claims of guaranteed returns or safety and asks whether they understand how an investment works and can explain it to another person.
- Evidence direction
- Strong conduct and comprehension challenge
- Material limitations
- The page has an anti-scam purpose and does not assess demand for a legitimate major-bank product.
- Approval use
- Approved for language and comprehension-test design
HF-SRC-007
Treasury
Developments in Banks' Funding Costs and Lending Rates
Reserve Bank of Australia
- Publication date
- 28 May 2026
- Access date
- 31 July 2026
- Source type
- Central-bank analysis using regulatory, market and bank-liaison data
- Jurisdiction
- Australia
- Proposition tested
- Major-bank funding composition, cost and matched-tenor economics
- Bounded finding
- Major-bank funding composition; March 2026 aggregate estimated costs; deposit and wholesale pricing dynamics; hedge context; limits of average funding estimates.
- Evidence direction
- Strong challenge to static 5%; support for matched-tenor and hedge analysis.
- Material limitations
- Aggregate estimates use simplifying hedge assumptions and do not represent an individual bank's marginal FTP or new-issue curve.
- Approval use
- Approved for treasury context and research design.
HF-SRC-008
Treasury
Prudential Standard APS 210 Liquidity
Australian Prudential Regulation Authority
- Publication date
- In force 1 July 2025
- Access date
- 31 July 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Liquidity, stable funding, effective maturity and funding-strategy treatment
- Bounded finding
- LCR, NSFR, retail-deposit, fixed-term, effective-maturity, stress, funding-strategy and liquidity-cost-allocation requirements.
- Evidence direction
- Structural and liquidity constraint; support for hard-term analysis.
- Material limitations
- Treatment depends on final legal terms, investor type, early-exit rights and APRA interpretation.
- Approval use
- Approved for prudential research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-009
Treasury
Prudential Practice Guide APG 210 Liquidity
Australian Prudential Regulation Authority
- Publication date
- Current from 1 July 2025
- Access date
- 31 July 2026
- Source type
- Primary prudential guidance
- Jurisdiction
- Australia
- Proposition tested
- Funding and liquidity transfer pricing, deposit stability and stress testing
- Bounded finding
- Sound practice for funding and liquidity transfer pricing, retail-deposit stability, rate-driven funding, customer-level modelling and stress testing.
- Evidence direction
- Supports source-specific modelling and challenges assumed stability of a high-rate online product.
- Material limitations
- Guidance does not create the same legal requirements as APS 210 and does not classify HomeFund.
- Approval use
- Approved for prudential research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-010
Treasury
2026 Interim Financial Results Presentation and Investor Discussion Pack
Westpac Banking Corporation
- Publication date
- 5 May 2026
- Access date
- 31 July 2026
- Source type
- Official bank investor disclosure
- Jurisdiction
- Australia
- Proposition tested
- Major-bank funding composition, liquidity and maturity management
- Bounded finding
- Funding composition, LCR, NSFR, wholesale funding capability and maturity management.
- Evidence direction
- Strong challenge to uniqueness; conditional support for diversification and maturity-channel analysis.
- Material limitations
- Public disclosure is not marginal FTP and does not quantify HomeFund economics.
- Approval use
- Approved for institutional comparison.
HF-SRC-011
Treasury
CBA 2026 Half Year Results Presentation
Commonwealth Bank of Australia
- Publication date
- 11 February 2026
- Access date
- 31 July 2026
- Source type
- Official bank investor disclosure
- Jurisdiction
- Australia
- Proposition tested
- Major-bank deposit funding, liquidity, maturity and structural hedging
- Bounded finding
- Deposit funding, long-term wholesale maturity, LCR, NSFR and structural-hedge practices.
- Evidence direction
- Strong challenge to uniqueness and to a simple contractually-liquid-equals-economically-short thesis.
- Material limitations
- Public disclosure is bank-specific, historical and not marginal FTP.
- Approval use
- Approved for institutional comparison.
View the original source from Commonwealth Bank of Australia
HF-SRC-012
Treasury
APRA releases quarterly authorised deposit-taking institution statistics for March 2026
Australian Prudential Regulation Authority
- Publication date
- 29 June 2026
- Access date
- 31 July 2026
- Source type
- Primary regulator statistics
- Jurisdiction
- Australia
- Proposition tested
- Industry liquidity and stable-funding context
- Bounded finding
- Aggregate ADI LCR of 137.8% and NSFR of 115.5% at March 2026.
- Evidence direction
- Challenge to an acute system-wide prudential-need case.
- Material limitations
- Aggregate industry statistics do not represent a specific bank's marginal liquidity or funding value.
- Approval use
- Approved for industry context.
View the original source from Australian Prudential Regulation Authority
HF-SRC-013
Treasury
Retail Deposits Inquiry 2023 — Final Report
Australian Competition and Consumer Commission
- Publication date
- 15 December 2023
- Access date
- 31 July 2026
- Source type
- Competition-regulator inquiry
- Jurisdiction
- Australia
- Proposition tested
- Deposit pricing, switching, funding incentives and cannibalisation
- Bounded finding
- Strategic deposit pricing, bonus-rate complexity, consumer engagement, switching barriers and bank funding incentives relevant to deposit counterfactuals.
- Evidence direction
- Strong cannibalisation and conduct challenge.
- Material limitations
- Predates 2026 conditions and does not test HomeFund or quantify behavioural duration.
- Approval use
- Approved for deposit-market and conduct context.
View the original source from Australian Competition and Consumer Commission
HF-SRC-014
Treasury
Prudential Standard APS 120 Securitisation
Australian Prudential Regulation Authority
- Publication date
- In force 1 January 2024
- Access date
- 31 July 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Securitisation funding, capital relief and implicit support
- Bounded finding
- Funding-only treatment, regulatory-capital-relief requirements, significant credit-risk transfer and implicit-support constraints.
- Evidence direction
- Strong challenge to assumed capital relief and bank-supported liquidity in a securitised alternative.
- Material limitations
- Applicability depends on final structure.
- Approval use
- Approved for structural-option research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-015
Treasury
The Financial Claims Scheme: Protecting depositors and policyholders
Australian Prudential Regulation Authority
- Publication date
- Current guidance
- Access date
- 31 July 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- FCS boundary, funding and protection wording
- Bounded finding
- Eligible deposit protection, Government initial funding, liquidation recovery and possible industry special levy; no routine product-specific insurance premium.
- Evidence direction
- Rejects the insurance-premium pass-through assumption and constrains protection wording.
- Material limitations
- Does not classify HomeFund or price a private guarantee.
- Approval use
- Approved for FCS boundary and funding guidance.
View the original source from Australian Prudential Regulation Authority
HF-SRC-016
Treasury
Prudential Standard APS 117 Capital Adequacy: Interest Rate Risk in the Banking Book
Australian Prudential Regulation Authority
- Publication date
- In force 1 October 2025
- Access date
- 31 July 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- IRRBB, behavioural assumptions, tenure and hedge modelling
- Bounded finding
- New-product IRRBB assessment, earnings and economic-value measurement, behavioural-assumption review, sensitivity testing, data and governance requirements.
- Evidence direction
- Supports rigorous tenure and hedge modelling; challenges unsupported behavioural or contractual-value claims.
- Material limitations
- Does not determine the economic value of HomeFund or prescribe a HomeFund pricing method.
- Approval use
- Approved for IRRBB and tenure-model research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-017
Comparable products
Prudential Standard APS 121 Covered Bonds
Australian Prudential Regulation Authority
- Publication date
- In force 1 January 2023
- Access date
- 1 August 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Australian covered-bond structure, mortgage collateral, governance and issuance constraints
- Bounded finding
- Australia has an established framework for ADI-issued covered bonds supported by registered cover pools, with governance, stress, capital, collateral and statutory asset-limit controls.
- Evidence direction
- Strong structural comparator; challenge to novelty and simplicity.
- Material limitations
- Does not establish retail demand, HomeFund economics or that any HomeFund structure would qualify as a covered bond.
- Approval use
- Approved for bounded comparable-product and structural-options research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-018
Comparable products
ASIC health check on capital protected products
Australian Securities and Investments Commission
- Publication date
- 2013
- Access date
- 1 August 2026
- Source type
- Primary regulator review and media release
- Jurisdiction
- Australia
- Proposition tested
- Consumer and conduct performance of capital-protected retail investments
- Bounded finding
- ASIC identified complexity, protection-language, value and sales-practice concerns in capital-protected and capital-guaranteed retail structured products.
- Evidence direction
- Strong conduct challenge.
- Material limitations
- Historical and based on products that were often derivative-based and structurally different from HomeFund.
- Approval use
- Approved for bounded comparable-product and conduct research.
View the original source from Australian Securities and Investments Commission
HF-SRC-019
Comparable products
Investing in Bonds
ASX
- Publication date
- Current guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Official exchange investor guidance
- Jurisdiction
- Australia
- Proposition tested
- Retail bond ownership, maturity and investor-to-investor sale
- Bounded finding
- Quoted bonds may be sold before maturity at market price, and face value due at maturity is distinct from early market value.
- Evidence direction
- Supports transfer-with-tenure mechanics; challenges par-liquidity assumptions.
- Material limitations
- General guidance does not establish market depth, spreads or liquidity for a new HomeFund issue.
- Approval use
- Approved for bounded comparable-product and liquidity research.
HF-SRC-020
Comparable products
ASIC grants conditional relief to improve access to capital for investors in frozen mortgage funds
Australian Securities and Investments Commission
- Publication date
- 2009
- Access date
- 1 August 2026
- Source type
- Primary regulator historical market intervention
- Jurisdiction
- Australia
- Proposition tested
- Mortgage-fund liquidity under stress
- Bounded finding
- Mortgage funds froze or restricted redemptions during market stress, demonstrating mismatch between long-dated mortgage assets and investor withdrawal expectations.
- Evidence direction
- Strong liquidity challenge.
- Material limitations
- Historical crisis evidence; managed-fund structures differ from an issuer-obligation HomeFund note.
- Approval use
- Approved as historical liquidity-stress evidence only.
View the original source from Australian Securities and Investments Commission
HF-SRC-021
Comparable products
Australian Credit Fund Product Disclosure Statement update
La Trobe Financial Asset Management
- Publication date
- Updated March 2026
- Access date
- 1 August 2026
- Source type
- Current issuer product disclosure
- Jurisdiction
- Australia
- Proposition tested
- Current retail mortgage/private-credit return, protection and liquidity terms
- Bounded finding
- Current mortgage-credit investment products may offer income linked to private credit while remaining non-deposits, non-FCS protected and subject to capital and withdrawal risk.
- Evidence direction
- Strong alternative-product and risk-allocation comparator.
- Material limitations
- Issuer product material; account structures, returns, notice periods and withdrawal terms vary and may change.
- Approval use
- Approved for bounded current-product comparison only.
View the original source from La Trobe Financial Asset Management
HF-SRC-022
Comparable products
NAB Securitisation Reporting
National Australia Bank
- Publication date
- Current program reporting; no single publication date
- Access date
- 1 August 2026
- Source type
- Official bank secured-funding and investor reporting
- Jurisdiction
- Australia
- Proposition tested
- Current major-bank RMBS structure and mortgage-pool reporting
- Bounded finding
- A major Australian bank issues and reports RMBS using identified mortgage pools, classes, ratings, coupons and weighted-average lives.
- Evidence direction
- Strong direct-mortgage-linkage comparator and complexity challenge.
- Material limitations
- Wholesale program material does not establish retail suitability, demand, protection or HomeFund economics.
- Approval use
- Approved for bounded institutional and structural comparison.
HF-SRC-023
Comparable products
APRA finalises changes to phase out Additional Tier 1 capital instruments
Australian Prudential Regulation Authority
- Publication date
- 9 December 2025
- Access date
- 1 August 2026
- Source type
- Primary prudential regulator announcement
- Jurisdiction
- Australia
- Proposition tested
- Durability and consumer implications of complex retail bank funding instruments
- Bounded finding
- APRA is phasing out AT1 instruments under a revised capital framework, demonstrating that an established retail bank security can create complexity and stability concerns despite market adoption.
- Evidence direction
- Negative precedent and governance challenge.
- Material limitations
- AT1 is loss-absorbing regulatory capital and materially different from the intended HomeFund structure.
- Approval use
- Approved as bounded negative-precedent evidence only.
View the original source from Australian Prudential Regulation Authority
HF-SRC-024
Comparable products
Notice to Members 02-69: Certificates of Deposit
Financial Industry Regulatory Authority
- Publication date
- 2002
- Access date
- 1 August 2026
- Source type
- Self-regulatory organisation guidance
- Jurisdiction
- United States
- Proposition tested
- Transferable deposit interests, secondary market and early-sale risk
- Bounded finding
- Brokered certificates of deposit can permit secondary-market sale while the underlying deposit remains outstanding, but a market is not assured and early sale can cause loss.
- Evidence direction
- Strong liquidity-mechanics comparator.
- Material limitations
- United States-specific and historical; US deposit-insurance and distribution arrangements do not determine Australian treatment.
- Approval use
- Approved for bounded liquidity-mechanics comparison.
View the original source from Financial Industry Regulatory Authority
HF-SRC-025
Comparable products
Brokered CDs: Investor Bulletin
United States Securities and Exchange Commission, Investor.gov
- Publication date
- Current bulletin; no publication date stated on cited page
- Access date
- 1 August 2026
- Source type
- Primary regulator consumer bulletin
- Jurisdiction
- United States
- Proposition tested
- Retail comprehension of brokered-CD liquidity, fees and market value
- Bounded finding
- A secondary market may not exist and an early sale may occur below the original amount despite maturity principal protections.
- Evidence direction
- Strong conduct and liquidity challenge.
- Material limitations
- United States-specific; does not establish Australian legal, FCS or market treatment.
- Approval use
- Approved for bounded consumer and liquidity comparison.
View the original source from United States Securities and Exchange Commission, Investor.gov
HF-SRC-026
Comparable products
Debentures, principal protected notes and term deposits
Canada Deposit Insurance Corporation
- Publication date
- Current guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Primary deposit-insurer guidance
- Jurisdiction
- Canada
- Proposition tested
- Deposit-insurance treatment of market-linked or principal-protected products
- Bounded finding
- Certain term deposits, GICs and index-linked deposits can receive deposit-insurance coverage where principal is repayable and eligibility requirements are met; non-deposit notes are treated differently.
- Evidence direction
- Supports deposit-form comparison and classification discipline.
- Material limitations
- Canadian CDIC law and eligibility rules do not determine Australian FCS treatment.
- Approval use
- Approved for bounded international protection and classification comparison.
View the original source from Canada Deposit Insurance Corporation
HF-SRC-027
Comparable products
Investing in Market Growth GICs
TD Canada Trust
- Publication date
- Current product page; no publication date stated
- Access date
- 1 August 2026
- Source type
- Current issuer product information
- Jurisdiction
- Canada
- Proposition tested
- Current principal-protected enhanced-return deposit design
- Bounded finding
- A major bank offers fixed-term, principal-protected market-linked deposits with constrained early access and formula-based upside.
- Evidence direction
- Strong product comparator; challenge to the need for investment-form HomeFund.
- Material limitations
- Issuer product material; formulas, terms, insurance eligibility and availability can change.
- Approval use
- Approved for bounded current-product comparison only.
HF-SRC-028
Comparable products
FCA Handbook PERG 2.6 — Specified investments and structured deposits
Financial Conduct Authority
- Publication date
- Current handbook; no single publication date
- Access date
- 1 August 2026
- Source type
- Primary regulator handbook guidance
- Jurisdiction
- United Kingdom
- Proposition tested
- Legal distinction between deposits and structured deposits
- Bounded finding
- Structured deposits can preserve repayment of deposit principal at maturity while linking interest or a premium to an external reference.
- Evidence direction
- Strong structural comparator.
- Material limitations
- United Kingdom legal framework; the cited section must be read with the complete handbook definitions and does not determine Australian classification.
- Approval use
- Approved for bounded international structural comparison.
HF-SRC-029
Comparable products
Occasional Paper No. 9: Two plus two makes five? Survey evidence that investors overvalue structured deposits
Financial Conduct Authority
- Publication date
- 2015
- Access date
- 1 August 2026
- Source type
- Primary regulator consumer research
- Jurisdiction
- United Kingdom
- Proposition tested
- Consumer valuation and comprehension of protected enhanced-return products
- Bounded finding
- Retail consumers systematically overvalued structured deposits and overestimated returns; enhanced disclosure only partly corrected comparison errors.
- Evidence direction
- Strong consumer-comprehension challenge.
- Material limitations
- Historical UK study and product designs differ from HomeFund; stated responses do not establish Australian behaviour.
- Approval use
- Approved for bounded consumer and conduct research.
HF-SRC-030
Comparable products
The balance principle
Finance Denmark
- Publication date
- Current industry guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Industry-body market and legal-structure guidance
- Jurisdiction
- Denmark
- Proposition tested
- Matched mortgage funding and bond cash-flow linkage
- Bounded finding
- Danish mortgage financing closely matches mortgage-loan and issued-bond cash flows through a dedicated legal and institutional model.
- Evidence direction
- Strong mortgage-linkage comparator.
- Material limitations
- Industry-body source and specialised Danish framework; it is not directly transferable to an Australian major bank.
- Approval use
- Approved for bounded international structural comparison.
HF-SRC-031
Comparable products
The Danish mortgage bond market is dominated by few market participants
Danmarks Nationalbank
- Publication date
- 2024
- Access date
- 1 August 2026
- Source type
- Central-bank market analysis
- Jurisdiction
- Denmark
- Proposition tested
- Liquidity and concentration in a mature mortgage-bond market
- Bounded finding
- Even a large and established mortgage-bond market can have concentrated participation and liquidity sensitivities.
- Evidence direction
- Strong challenge to assumed secondary-market depth.
- Material limitations
- Danish mortgage institutions, law and market structure differ from Australia.
- Approval use
- Approved for bounded international liquidity comparison.
HF-SRC-032
Comparable products
CHT Borrowings are Fully Guaranteed by CMHC
Canada Mortgage and Housing Corporation
- Publication date
- Current program guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Primary government housing-agency program guidance
- Jurisdiction
- Canada
- Proposition tested
- Government-guaranteed mortgage-funding security
- Bounded finding
- Canada Mortgage Bonds receive an explicit CMHC guarantee of timely principal and interest within a national housing-finance program.
- Evidence direction
- Strong protection-provider and housing-funding comparator.
- Material limitations
- Government-supported Canadian program; not transferable to a privately sponsored Australian product.
- Approval use
- Approved for bounded international protection comparison.
View the original source from Canada Mortgage and Housing Corporation
HF-SRC-033
Comparable products
Primary Benefits of the Legal Framework
Canada Mortgage and Housing Corporation
- Publication date
- Current program guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Primary government-administered covered-bond framework guidance
- Jurisdiction
- Canada
- Proposition tested
- Bank obligation, mortgage cover pool and absence of government guarantee
- Bounded finding
- Canadian registered covered bonds provide legal cover-pool protections and funding diversification but are not guaranteed by CMHC or the Canadian Government.
- Evidence direction
- Strong covered-note and protection-boundary comparator.
- Material limitations
- Canadian legal framework; does not establish Australian retail demand or prudential treatment.
- Approval use
- Approved for bounded international structural comparison.
View the original source from Canada Mortgage and Housing Corporation
HF-SRC-034
Comparable products
Funding Government Lending
Ginnie Mae
- Publication date
- Current agency guidance; no publication date stated
- Access date
- 1 August 2026
- Source type
- Primary United States government-agency guidance
- Jurisdiction
- United States
- Proposition tested
- Government-backed mortgage-security payment protection
- Bounded finding
- Ginnie Mae guarantees timely principal and interest on eligible mortgage-backed securities under a United States government framework.
- Evidence direction
- Strong international protection and mortgage-linkage comparator.
- Material limitations
- United States agency and sovereign-support model; the guarantee does not protect secondary-market value and is not transferable to a private Australian product.
- Approval use
- Approved for bounded international protection and liquidity comparison.
HF-SRC-035
Comparable products
Pfandbrief banks expand mortgage lending and sales in 2025 financial year
Association of German Pfandbrief Banks
- Publication date
- 2026
- Access date
- 1 August 2026
- Source type
- Industry-body current market reporting
- Jurisdiction
- Germany
- Proposition tested
- Scale and continuing role of mortgage covered bonds
- Bounded finding
- Mortgage Pfandbriefe remain a large and active secured bank-funding market supported by a mature legal framework.
- Evidence direction
- Strong established-structure comparator.
- Material limitations
- Industry-body source and primarily institutional German market; does not establish Australian retail transferability or economics.
- Approval use
- Approved for bounded international market comparison.
View the original source from Association of German Pfandbrief Banks
HF-SRC-036
Structural options
Corporations Act 2001
Commonwealth of Australia
- Publication date
- Compilation effective 1 July 2026
- Access date
- 1 August 2026
- Source type
- Primary legislation
- Jurisdiction
- Australia
- Proposition tested
- Deposit-product definition, ADI debenture disclosure exemption, debenture trustee and naming rules, managed investment schemes and financial-products regulation
- Bounded finding
- The Act creates materially different regimes for deposits, securities and managed investment schemes. Australian ADI debenture offers are exempt from Chapter 6D disclosure under section 708(19), while the preliminary reading of Chapter 2L indicates its trust-deed requirements may not automatically apply to that exemption. Managed schemes and basic banking products have separate governance and disclosure frameworks.
- Evidence direction
- Strong structural-classification and conduct control.
- Material limitations
- Application depends on exact terms, regulations, ASIC instruments and exemptions. The Chapter 2L interpretation requires external legal confirmation.
- Approval use
- Approved for bounded structural-classification and conduct research.
HF-SRC-037
Structural options
Banking Act 1959
Commonwealth of Australia
- Publication date
- Current compilation accessed 1 August 2026
- Access date
- 1 August 2026
- Source type
- Primary legislation
- Jurisdiction
- Australia
- Proposition tested
- Protected accounts, depositor priority, Financial Claims Scheme, covered bonds and asset limits
- Bounded finding
- Protected-account treatment depends on an identifiable account holder and an ADI obligation to pay the net credit balance. The Act separately establishes covered bonds as ADI obligations secured by cover-pool SPV assets and imposes an 8 per cent cover-pool asset limit.
- Evidence direction
- Strong protection, classification and structural constraint.
- Material limitations
- Product-specific eligibility, ranking and transfer treatment require formal legal analysis and consideration of current regulations.
- Approval use
- Approved for bounded legal-structure and protection research.
HF-SRC-038
Structural options
ASIC Corporations (31-day Notice Term Deposits) Instrument 2025/172
Australian Securities and Investments Commission
- Publication date
- Commenced 2025
- Access date
- 1 August 2026
- Source type
- Legislative instrument
- Jurisdiction
- Australia
- Proposition tested
- Basic-deposit-product treatment for qualifying notice term deposits
- Bounded finding
- The instrument modifies relevant Corporations Act treatment for qualifying 31-day notice term deposits with terms up to five years and prescribes customer information about notice, delayed access and alternative products.
- Evidence direction
- Supports the deposit baseline and informed-access disclosure.
- Material limitations
- Applies only where detailed eligibility conditions are satisfied and does not establish FCS status or HomeFund viability.
- Approval use
- Approved for bounded deposit-form and consumer-access research.
View the original source from Australian Securities and Investments Commission
HF-SRC-039
Structural options
Prudential Standard APS 910 Financial Claims Scheme
Australian Prudential Regulation Authority
- Publication date
- In force 1 October 2023
- Access date
- 1 August 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Account-holder identity, Single Customer View and FCS operational requirements
- Bounded finding
- ADIs must identify unique protected-account holders, aggregate balances, maintain Single Customer View data and generate it within the required timeframe, creating material constraints for pooled or transferable-deposit structures.
- Evidence direction
- Strong operational and FCS constraint.
- Material limitations
- Does not determine whether a proposed product is a protected account.
- Approval use
- Approved for bounded FCS-operational and transferable-deposit research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-040
Structural options
RG 274 Product design and distribution obligations and ASIC DDO information
Australian Securities and Investments Commission
- Publication date
- Current guidance, including RG 274 issued 10 September 2024
- Access date
- 1 August 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Product design, target-market and distribution obligations
- Bounded finding
- DDO requires issuers and distributors of covered retail products to define target markets, align distribution, monitor outcomes and respond to review and reporting information; basic banking products are included through the regulatory framework.
- Evidence direction
- Strong consumer-governance requirement.
- Material limitations
- Applicability to an ADI debenture offered under section 708(19) requires legal confirmation.
- Approval use
- Approved for bounded conduct and distribution-governance research.
View the original source from Australian Securities and Investments Commission
HF-SRC-041
Structural options
RG 69 Debentures and notes: Improving disclosure for retail investors
Australian Securities and Investments Commission
- Publication date
- Issued 8 February 2012
- Access date
- 1 August 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Retail debt disclosure, terminology, security, liquidity and issuer information
- Bounded finding
- ASIC expects clear retail disclosure for debentures and notes, including risks, security, liquidity and issuer information.
- Evidence direction
- Supports a prospectus-equivalent voluntary note-disclosure standard.
- Material limitations
- Historical guidance and formal scope must be tested for an ADI offer relying on section 708(19).
- Approval use
- Approved for bounded retail-note disclosure research.
View the original source from Australian Securities and Investments Commission
HF-SRC-042
Structural options
Do you need an Australian financial services licence?
Australian Securities and Investments Commission
- Publication date
- Current guidance accessed 1 August 2026
- Access date
- 1 August 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Advice, dealing, market making, registered-scheme operation and custody
- Bounded finding
- Financial-product advice, dealing, market making, registered-scheme operation and custody generally require relevant AFS authorisation unless an exemption applies.
- Evidence direction
- Strong operating-model and licensing constraint.
- Material limitations
- Exact authorisations and exemptions depend on the activities, entities, distribution model and final product.
- Approval use
- Approved for bounded licensing and operating-model research.
View the original source from Australian Securities and Investments Commission
HF-SRC-043
Structural options
Prudential Standard CPS 230 Operational Risk Management
Australian Prudential Regulation Authority
- Publication date
- In force 1 July 2026
- Access date
- 1 August 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- New-product operational risk, critical operations and service providers
- Bounded finding
- APRA-regulated entities must assess operational risk associated with new products, services and technology, maintain critical operations and manage material service-provider risk.
- Evidence direction
- Strong implementation and scale constraint.
- Material limitations
- Does not prescribe a HomeFund operating model or confirm that any option is viable.
- Approval use
- Approved for bounded operating-risk and implementation research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-044
Structural options
AASB 9 Financial Instruments
Australian Accounting Standards Board
- Publication date
- Current compilation applying to 2026 reporting periods
- Access date
- 1 August 2026
- Source type
- Australian Accounting Standard
- Jurisdiction
- Australia
- Proposition tested
- Liability measurement, effective interest, derecognition and issuer repurchase
- Bounded finding
- Financial liabilities are initially measured at fair value with applicable transaction costs; amortised cost uses the effective interest method; derecognition requires qualifying expiry or transfer; and issuer repurchase of its own debt extinguishes the liability.
- Evidence direction
- Strong accounting and funding-tenure control.
- Material limitations
- Product-specific classification, embedded features and elections require auditor and accounting-policy confirmation.
- Approval use
- Approved for bounded accounting and treasury research.
View the original source from Australian Accounting Standards Board
HF-SRC-045
Structural options
AASB 132 Financial Instruments: Presentation
Australian Accounting Standards Board
- Publication date
- Current compilation accessed 1 August 2026
- Access date
- 1 August 2026
- Source type
- Australian Accounting Standard
- Jurisdiction
- Australia
- Proposition tested
- Financial-liability classification
- Bounded finding
- A contractual obligation to deliver cash is a financial liability, and classification follows contractual substance rather than the product label.
- Evidence direction
- Strong classification control.
- Material limitations
- Final terms may contain options, contingent returns or other features requiring more detailed analysis.
- Approval use
- Approved for bounded accounting-classification research.
View the original source from Australian Accounting Standards Board
HF-SRC-046
Structural options
AASB 7 Financial Instruments: Disclosures
Australian Accounting Standards Board
- Publication date
- Current compilation applying to 2026 reporting periods
- Access date
- 1 August 2026
- Source type
- Australian Accounting Standard
- Jurisdiction
- Australia
- Proposition tested
- Contractual maturity, liquidity and market-risk disclosure
- Bounded finding
- Entities disclose contractual maturity and liquidity risk using relevant contractual cash flows, including the earliest period in which a counterparty can require payment, and disclose material market-risk sensitivity.
- Evidence direction
- Strong challenge to long-tenure claims where early puts or practical redemption rights exist.
- Material limitations
- Financial-reporting disclosure does not determine prudential maturity or product viability.
- Approval use
- Approved for bounded accounting and liquidity research.
View the original source from Australian Accounting Standards Board
HF-SRC-047
Structural options
AASB 10, AASB 12 and AASB 13
Australian Accounting Standards Board
- Publication date
- Current compilations applying to 2026 reporting periods
- Access date
- 1 August 2026
- Source type
- Australian Accounting Standards
- Jurisdiction
- Australia
- Proposition tested
- SPV control, structured-entity disclosure and fair value
- Bounded finding
- Control determines consolidation, interests in structured entities can require disclosure, and fair value is an exit price in an orderly market rather than original principal.
- Evidence direction
- Strong SPV, consolidation and early-market-value control.
- Material limitations
- Each covered, securitised or managed structure requires facts-and-circumstances analysis and auditor confirmation.
- Approval use
- Approved for bounded structured-entity and fair-value research.
View the original source from Australian Accounting Standards Board
HF-SRC-048
Structural options
ATO interest-income guidance
Australian Taxation Office
- Publication date
- Current guidance accessed 1 August 2026
- Access date
- 1 August 2026
- Source type
- Primary tax-administration guidance
- Jurisdiction
- Australia
- Proposition tested
- Deposit and fixed-interest investor income
- Bounded finding
- Interest from bank accounts and term deposits is ordinarily assessable, with timing depending on receipt, crediting, accrual and any applicable financial-arrangement rules.
- Evidence direction
- Supports the customer tax baseline.
- Material limitations
- Exact treatment depends on the taxpayer and instrument; structure-specific advice is required.
- Approval use
- Approved for bounded investor-tax comparison.
HF-SRC-049
Structural options
Division 230 TOFA and Division 974 debt-equity rules
Commonwealth of Australia and Australian Taxation Office
- Publication date
- Current law effective 1 July 2026 and current ATO guidance
- Access date
- 1 August 2026
- Source type
- Primary tax legislation and guidance
- Jurisdiction
- Australia
- Proposition tested
- Issuer and investor financial-arrangement treatment and debt-equity classification
- Bounded finding
- Gains and losses from financial arrangements can be recognised over the life of an arrangement under accruals, realisation or elected methods, while debt-equity classification depends on economic substance and effective repayment obligations.
- Evidence direction
- Strong tax-structure requirement.
- Material limitations
- Application, elections, exclusions and investor treatment are structure and taxpayer specific.
- Approval use
- Approved for bounded issuer and investor tax-structure research.
View the original source from Commonwealth of Australia and Australian Taxation Office
HF-SRC-050
Structural options
GSTR 2002/2 Goods and services tax: GST treatment of financial supplies and related supplies and acquisitions
Australian Taxation Office
- Publication date
- Current guidance accessed 1 August 2026
- Access date
- 1 August 2026
- Source type
- Primary tax-administration guidance
- Jurisdiction
- Australia
- Proposition tested
- GST on deposits, debt securities, arranging, broking and related services
- Bounded finding
- Deposits and debt securities generally involve input-taxed financial supplies, while separate arranging, broking, rating, registry and coordination services may have different treatment and can create unrecovered GST cost.
- Evidence direction
- Strong all-in-cost requirement.
- Material limitations
- Exact GST treatment and input-tax-credit recovery depend on the supplies, entities, acquisitions and thresholds.
- Approval use
- Approved for bounded GST and all-in-cost research.
HF-SRC-051
Structural options
Managed investment trusts
Australian Taxation Office
- Publication date
- Current guidance, last updated 23 June 2025
- Access date
- 1 August 2026
- Source type
- Primary tax-administration guidance
- Jurisdiction
- Australia
- Proposition tested
- Managed-fund distributions, attribution, withholding and cost base
- Bounded finding
- Managed-trust investors can receive attributed income and capital components, annual statements and cost-base adjustments, and foreign-resident withholding can apply.
- Evidence direction
- Strong tax-reporting and complexity comparator.
- Material limitations
- MIT and AMIT status, attribution and character depend on the trust, assets and investor.
- Approval use
- Approved for bounded managed-structure tax comparison.
HF-SRC-052
Structural options
RG 168 Product Disclosure Statements: Disclosure and other obligations
Australian Securities and Investments Commission
- Publication date
- Issued 3 December 2025
- Access date
- 1 August 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Retail PDS content, preparation, lodgment and ongoing use
- Bounded finding
- ASIC expects compliant, clear and useful PDS disclosure supported by governance around preparation, lodgment and ongoing use.
- Evidence direction
- Strong managed-product and voluntary disclosure comparator.
- Material limitations
- PDS requirements do not automatically apply to every structural option.
- Approval use
- Approved for bounded retail-disclosure and governance research.
View the original source from Australian Securities and Investments Commission
HF-SRC-053
Structural options
RG 45 Mortgage schemes: Improving disclosure for retail investors
Australian Securities and Investments Commission
- Publication date
- Issued 5 March 2026
- Access date
- 1 August 2026
- Source type
- Primary regulator guidance
- Jurisdiction
- Australia
- Proposition tested
- Retail mortgage-scheme disclosure and advertising
- Bounded finding
- ASIC maintains specific benchmarks and disclosure principles for retail mortgage schemes, reflecting their credit, liquidity, valuation and operating complexity.
- Evidence direction
- Strong challenge to managed or securitised simplicity.
- Material limitations
- Applies to mortgage schemes rather than ordinary bank deposits or notes.
- Approval use
- Approved for bounded managed-mortgage comparator and conduct research.
View the original source from Australian Securities and Investments Commission
HF-SRC-054
Specialist governance and tax certainty
Prudential Standard CPS 220 Risk Management
Australian Prudential Regulation Authority
- Publication date
- In force 1 July 2019
- Access date
- 1 August 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Risk-management framework, risk appetite, material change, model and control governance
- Bounded finding
- APRA-regulated institutions must maintain a Board-approved framework covering material risks, risk appetite, policies, models, controls, conflicts, independent review and notifications, including material changes to business mix and complexity.
- Evidence direction
- Strong specialist-validation and governance requirement.
- Material limitations
- Does not approve HomeFund or prescribe product-specific treatment.
- Approval use
- Approved for bounded specialist-validation and governance research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-055
Specialist governance and tax certainty
Prudential Practice Guide CPG 220 Risk Management
Australian Prudential Regulation Authority
- Publication date
- Current practice guide
- Access date
- 1 August 2026
- Source type
- Primary prudential practice guidance
- Jurisdiction
- Australia
- Proposition tested
- Independent challenge and review of the risk-management framework
- Bounded finding
- APRA expects independent risk review and challenge and distinguishes annual reviews from periodic comprehensive reviews of the risk-management framework.
- Evidence direction
- Supports independent challenge and assurance.
- Material limitations
- Practice guidance is not a prudential standard and does not determine HomeFund treatment.
- Approval use
- Approved for bounded specialist-validation governance research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-056
Specialist governance and tax certainty
Prudential Standard APS 310 Audit and Related Matters
Australian Prudential Regulation Authority
- Publication date
- In force 1 January 2023
- Access date
- 1 August 2026
- Source type
- Primary prudential standard
- Jurisdiction
- Australia
- Proposition tested
- Independent auditor advice and access for APRA
- Bounded finding
- ADIs must appoint and support an auditor able to provide independent advice about operations, controls and information relevant to APRA.
- Evidence direction
- Supports external-auditor involvement and prudential assurance.
- Material limitations
- Does not require the appointed auditor to approve HomeFund.
- Approval use
- Approved for bounded audit and prudential-assurance research.
View the original source from Australian Prudential Regulation Authority
HF-SRC-057
Specialist governance and tax certainty
Public and multinational business advice and guidance program
Australian Taxation Office
- Publication date
- Current guidance
- Access date
- 1 August 2026
- Source type
- Primary tax-administration guidance
- Jurisdiction
- Australia
- Proposition tested
- Early tax engagement for complex transactions
- Bounded finding
- The ATO encourages early engagement on complex transactions to identify issues, determine appropriate advice products and resolve matters before a formal ruling application or implementation.
- Evidence direction
- Supports early ATO engagement before final structure selection.
- Material limitations
- Early engagement is not binding and does not replace a ruling.
- Approval use
- Approved for bounded tax-engagement planning.
HF-SRC-058
Specialist governance and tax certainty
TR 2006/11 Private rulings
Australian Taxation Office
- Publication date
- Current public ruling; an update has been separately exposed as draft
- Access date
- 1 August 2026
- Source type
- Primary tax public ruling
- Jurisdiction
- Australia
- Proposition tested
- Binding private rulings for a specified scheme
- Bounded finding
- A private ruling can bind the Commissioner for an applicant where the specified scheme and material facts are implemented as described.
- Evidence direction
- Supports issuer-specific tax certainty after the structure is sufficiently settled.
- Material limitations
- It binds only within its statutory scope and does not protect a materially different implementation.
- Approval use
- Approved for bounded tax-certainty planning.
HF-SRC-059
Specialist governance and tax certainty
CR 2001/1 Class Rulings
Australian Taxation Office
- Publication date
- Current foundational ruling on class rulings
- Access date
- 1 August 2026
- Source type
- Primary tax public ruling
- Jurisdiction
- Australia
- Proposition tested
- Binding tax certainty for a defined class participating in a scheme
- Bounded finding
- A class ruling can provide legally binding advice for a defined class of entities participating in a specified scheme, subject to the scheme being implemented as described.
- Evidence direction
- Supports potential investor-class tax certainty.
- Material limitations
- The Commissioner has discretion whether to issue one, and the scheme and class must be sufficiently defined.
- Approval use
- Approved for bounded tax-certainty planning.
HF-SRC-060
Specialist governance and tax certainty
PR 2007/71 Product Rulings
Australian Taxation Office
- Publication date
- Foundational public ruling on product rulings
- Access date
- 1 August 2026
- Source type
- Primary tax public ruling
- Jurisdiction
- Australia
- Proposition tested
- Product-ruling purpose, conditions and limitations
- Bounded finding
- Product rulings are discretionary public rulings for settled products entered into by multiple participants on materially common terms; they provide tax certainty but do not approve commercial viability or serve as marketing approval.
- Evidence direction
- Supports cautious consideration of a product ruling only after the structure is settled.
- Material limitations
- The ruling is historical and product-ruling policy and administration must be confirmed with the ATO.
- Approval use
- Approved for bounded tax-certainty planning.
What the evidence supports
The current evidence supports six bounded conclusions.
1
A consumer research question exists
Some consumers value stability and income and consider return, risk, fees and access together.
This supports testing a possible gap. It does not establish demand for HomeFund.
2
Comprehension is a viability gate
Bank branding, protection language and familiar interfaces can cause customers to infer rights or flexibility that may not exist.
Purchase intention cannot count as informed demand where it depends on misunderstanding.
3
Hard contractual tenure may have bank value
A defined maturity can differ economically from an at-call balance.
Its value must be incremental after behavioural, funds-transfer-pricing, liquidity and hedge value are preserved.
4
The return must fit a two-sided corridor
The minimum return an informed customer requires must not exceed the maximum return the bank can economically support.
No corridor means no product.
5
Structure changes customer rights
A term deposit, unsecured note and covered note create different FCS, ranking, mortgage, disclosure, liquidity and operating outcomes.
No legal form currently passes all gates.
6
Existing products may dominate
A purpose-branded term deposit or another established investment may deliver clearer customer or bank value with less complexity.
Simplification or rejection remains a valid result.
What remains unresolved
The missing evidence is more important than the source count.
| Question | Current status | Evidence still required |
|---|---|---|
| Do informed consumers want HomeFund? | Validation required | Qualitative, quantitative and behavioural testing using actual cell rights and alternatives |
| What return is required? | Open | Minimum informed return after full comprehension, fees, tax, issuer risk, term and early-value disclosure |
| Is there an unmet market of useful scale? | Open | Representative demand, source-of-funds and segment evidence |
| Which legal structure applies? | Validation required | External legal classification of exact versioned terms |
| Does the FCS apply? | Open by structure | Protected-account and holder analysis for Cell A; no FCS assumed for note cells |
| What is the bank’s incremental funding value? | Bank-specific validation required | Source attribution, matched curves, FTP, hedge reconciliation, costs and stress testing |
| Can liquidity work fairly? | Validation required | Transfer design, valuation, market capacity, stress depth and informed acceptance of loss |
| What are the APRA outcomes? | Bank-specific validation required | Structure-specific LCR, NSFR, IRRBB, capital, resolution and encumbrance analysis |
| What are the accounting and tax outcomes? | Specialist validation required | Auditor, accounting-policy and structure-specific tax conclusions |
| Can the operating model scale? | Open | Registry, servicing, assurance, resilience, conduct and minimum-issue-scale analysis |
| Does mortgage purpose create incremental value? | Open | Comprehension, assurance and customer-value testing without ownership or additionality inference |
| Is there a viable business case? | Not commenced | Reconciled customer, Treasury, specialist and operating evidence |
No public source can answer an individual bank’s marginal commercial question, and no project decision can substitute for observed customer evidence.
Decision and challenge discipline
Decisions control the research. They do not validate the proposition.
The decision register contains sixteen controlled entries.
Settled foundations
- HomeFund is the working name.
- The initial sponsor assumption is a major Australian bank.
- Consumer value must be assessed before bank value.
Settled design and roadmap directions
- investment-product positioning is the starting point, subject to classification;
- the initial asset scope is the overall Australian residential mortgage book;
- investors do not select or own individual mortgages;
- the bank is intended to retain mortgage underwriting and credit-loss risk;
- return value is intended to come from funding stability rather than investor first-loss exposure; and
- future non-mortgage variants remain outside the initial scope.
Validation-required intent and provisional assumptions
- bank-provided principal protection remains an intent requiring a defined mechanism;
- approximately 5 per cent remains a research hypothesis only;
- secondary-market sale or bank buyback remain candidate mechanisms, with unconditional at-principal buyback rejected for the initial design;
- interface reuse remains a hypothesis; and
- housing-related social benefit remains provisional and unsupported without additionality evidence.
Open matters
- no investment term structure is approved; and
- no customer-paid insurance or protection charge is approved.
HF-DEC-001 · Settled
The working consumer product name is HomeFund.
Qualification: Naming and trademark clearance remain outside this foundation.
HF-DEC-002 · Settled
The initial sponsor assumption is a major Australian bank.
Qualification: No specific bank has approved or sponsored the proposition.
HF-DEC-003 · Settled
Consumer value must be assessed before bank value.
Qualification: A bank-positive outcome is insufficient without demonstrated consumer value and fair outcomes.
HF-DEC-004 · Settled design direction
HomeFund is positioned as an investment product.
Qualification: Legal, regulatory, prudential, tax and accounting classification is open.
HF-DEC-005 · Settled design direction
Initial asset scope is the bank’s overall Australian residential mortgage book.
Qualification: The meaning of economic allocation, legal linkage or ring-fencing is open.
HF-DEC-006 · Settled design direction
Investors do not select or own individual mortgages.
Qualification: Product terms must not imply beneficial ownership unless a future approved structure creates it.
HF-DEC-007 · Settled design direction
The bank is intended to retain mortgage underwriting and credit-loss risk.
Qualification: Capital, provisioning, resolution and loss-allocation treatment require validation.
HF-DEC-008 · Settled design intent; validation required
Investor principal is intended to be protected by the sponsoring bank.
Qualification: The protection mechanism, enforceability, issuer exposure, insolvency treatment and FCS status are open.
HF-DEC-009 · Provisional
Approximately 5% p.a. is the initial target-return hypothesis.
Qualification: It is not a promise, forecast or approved rate. Full economics and sensitivity testing are required.
HF-DEC-010 · Settled design direction
Return value is intended to come from funding stability and mortgage-book economics, not investor first-loss exposure.
Qualification: Treasury transfer pricing, all-in funding cost and margin benefit are unverified.
HF-DEC-011 · Provisional
Secondary-market sale and/or bank buyback are candidate liquidity mechanisms.
Qualification: Price, capacity, stress behaviour, disclosure, conduct and balance-sheet impacts are open.
HF-DEC-012 · Hypothesis
Existing bank investment or trading interfaces may be reusable.
Qualification: Technology, licensing, operating-model and customer-comprehension fit are unverified.
HF-DEC-013 · Settled roadmap boundary
Future variants may examine cards, business lending, construction and housing infrastructure.
Qualification: They are excluded from the initial product design and initial repository foundation.
HF-DEC-014 · Provisional benefit
Supporting inclusive home ownership is a desired brand and social outcome.
Qualification: Causal impact, additional lending and permissible claims must be evidenced.
HF-DEC-015 · Open
No investment term structure has been approved.
Qualification: Three-, five- or ten-year examples from earlier discussion are not approved product rules.
HF-DEC-016 · Open
No customer-paid insurance or protection charge has been approved.
Qualification: Need, provider, coverage, prudential recognition, pricing and fairness require investigation.
A settled project decision can define the research boundary while the product outcome remains unvalidated.
Adversarial record
The adversarial register contains eighteen challenges. None is closed.
HF-ADV-001 — Product-classification contradiction
Validation requiredHF-ADV-002 — Funding advantage may disappear
Validation requiredHF-ADV-003 — Capital protection conflicts with market liquidity
Validation requiredHF-ADV-004 — “Dedicated to mortgages” may be misleading
Validation requiredHF-ADV-005 — Deposit confusion and conduct risk
Validation requiredHF-ADV-006 — Whole-book exposure may not simplify all management
Validation requiredHF-ADV-007 — Claimed social benefit may not be additional
Validation requiredHF-ADV-008 — Three-way product promise may be irreconcilable
Validation requiredHF-ADV-009 — Static target return destroys funding economics
Validation requiredHF-ADV-010 — Internal transfer can be productive conversion or destructive cannibalisation
Validation requiredHF-ADV-011 — Liquidity promise removes stable tenor
Validation requiredHF-ADV-012 — Existing funding and hedging tools already capture much of the value
Validation requiredHF-ADV-013 — Bank protection provides no free capital or insurance benefit
Validation requiredHF-ADV-014 — Contractual-tenure value may be double counted
Validation requiredHF-ADV-015 — A simpler existing product may dominate HomeFund
Validation requiredHF-ADV-016 — Transferability may destroy protected-deposit value
Validation requiredHF-ADV-017 — ADI disclosure exemption may weaken customer protection
Validation requiredHF-ADV-018 — Specialist opinions may validate different products
Validation required
A settled project decision can define what to investigate while the underlying product outcome remains Validation required or Open.
Validation Cells A–C
The cells are controlled questions for specialists and customers, not approved products.
Cell A
Purpose-branded term deposit
- Role
- Mandatory baseline and potential kill comparator.
- Research question
- Can a familiar deposit structure deliver sufficient informed customer and bank value without destructive cannibalisation?
- Key unresolved matters
- Exact FCS treatment, term and access, mortgage-purpose assurance, pricing and source mix.
Cell B
Senior unsecured retail note
- Role
- Leading investment-form validation cell, not selected.
- Research question
- Can hard maturity, investor transfer and a retail holder base justify non-FCS issuer risk, market-value exit and higher disclosure and operating costs?
- Key unresolved matters
- Classification, ranking, licensing, disclosure, market capacity, customer premium, accounting and tax.
Cell C
Mortgage-covered retail note
- Role
- Conditional secured validation cell, not the default.
- Research question
- Do informed customers value cover-pool linkage enough to justify encumbrance, collateral, SPV, assurance and retail operating costs?
- Key unresolved matters
- Covered-bond framework, capacity, dual recourse, collateral, APRA treatment, accounting, tax and customer comprehension.
Only a cell assessed on one common assumptions schedule and reconciled term-sheet version may progress.
What must happen next
Further progress requires evidence collection, not a product build.
Publication provenance
The website is a derived publication layer.
The canonical project record is the approved Markdown in the private repository.
- External source
- Controlled evidence record
- Canonical synthesis, decision or challenge
- Approved page source pack
- Static public page
Public pages:
- simplify and organise approved findings;
- expose their copy version, review date and canonical source SHA;
- map claims to controlled source, challenge and decision IDs;
- add no new evidence;
- do not replace the evidence, decision or challenge registers; and
- must be regenerated or reviewed when a material canonical position changes.
The public evidence dataset is generated at build time from an allowlisted set of approved fields.
Raw canonical files, private registers, source packs and working notes are not included in the public bundle.
Full disclaimer
HomeFund is an independent evidence-led product investigation.
It is not:
- a financial product;
- an offer or invitation;
- investment, legal, tax or personal advice;
- a bank-sponsored or regulator-approved initiative;
- a statement that any deposit, note or covered structure qualifies for the Financial Claims Scheme;
- a promise of principal protection, return or liquidity;
- a demand forecast;
- a target-market determination;
- a business case;
- a pilot; or
- a commitment to issue or launch a product.
Published source findings remain subject to their recorded dates, jurisdictions, methods and limitations.
The project may conclude that a simpler product is preferable or that HomeFund should not proceed.
Current conclusion
The evidence is sufficient to continue disciplined validation and insufficient to approve HomeFund.
The project has moved beyond an unsupported idea.
It has not reached a validated proposition.
The next milestone is not a build. It is a reconciled evidence decision across informed customers, bank economics, specialists and operations.
Until that work is complete, HomeFund remains a transparent question:
Can a major Australian bank create a clear, fair and commercially viable retail investment that provides longer-term funding for residential mortgages?