How it could work

HomeFund would be a claim on a bank, not ownership of mortgages.

At its simplest, an investor would provide money to an issuing bank for a defined term. The bank would issue a legal claim, attribute or secure the funding against residential mortgage activity according to the chosen structure, continue to manage the mortgages and make the promised payments under the product terms.

The bank would retain mortgage underwriting, arrears and credit-loss risk. The investor would not select individual loans or receive borrowers’ mortgage repayments directly.

That common description is only the starting point. A term deposit, a senior unsecured note and a mortgage-covered note create materially different rights, protections, insolvency outcomes and early-exit risks.

No structure has been selected. The diagrams on this page explain controlled research options, not approved product terms.

Start with the legal relationship

The customer’s first question is not “which mortgages?” It is “what does the bank owe me?”

Under the current design direction, the investor would not become a lender to individual home-loan customers.

The investor would hold a claim created by the HomeFund legal structure. Depending on the structure, that claim could be:

  • a deposit account claim against the authorised deposit-taking institution;
  • a senior unsecured debt claim against the issuing bank; or
  • a bank debt claim supported by an identified residential mortgage cover pool.

The residential mortgage loans would remain assets of the bank or the relevant banking group entity. Borrowers would continue to owe their repayments to the bank under their existing loan contracts.

HomeFund therefore involves two separate relationships:

Investor relationship

Investor

The investor provides funds and receives the rights stated in the HomeFund terms.

Issuing entity

Issuing bank

Creates the investor claim and continues to hold and manage the mortgage relationship.

Mortgage relationship

Residential mortgage borrowers / mortgage portfolio

Home-loan customers continue to borrow from and repay the bank. Their contracts do not become contracts with HomeFund investors.

The connection between those relationships must be defined, evidenced and described without implying rights that the investor does not have.

The proposed flow

One balance-sheet flow sits beneath three different legal structures.

Cash / funding flow

Contractual or reporting obligation

  1. Cash / funding flow

    Step 1 — The investor commits funds

    The investor chooses an available HomeFund issue or term and provides money to the bank.

    The minimum amount, term, return, fees and eligibility have not been approved.

  2. Contractual obligation

    Step 2 — The bank creates the legal claim

    The exact claim depends on the validation cell:

    • a deposit;
    • a senior unsecured note; or
    • a mortgage-covered note.

    The product name does not determine the legal form.

  3. Cash / funding flow

    Step 3 — Treasury receives and manages the funding

    The funds enter the bank’s funding and balance-sheet management process.

    A longer contractual term may give Treasury greater certainty over when the liability matures. That benefit is not automatic and must be measured after recognising the source of the money, displaced deposits, hedging, liquidity and every product cost.

  4. Reporting or structural obligation

    Step 4 — The mortgage connection is applied

    The bank could:

    • state a residential mortgage-funding purpose;
    • allocate and assure an equivalent amount against eligible mortgage funding;
    • support the obligation with an identified mortgage cover pool; or
    • use a different asset-interest structure.

    Only the first three levels remain active in the initial structural work. Direct or securitised mortgage exposure is not the current starting direction.

  5. Bank operating responsibility

    Step 5 — The bank continues to manage the mortgages

    The bank continues to:

    • approve and price home loans;
    • collect repayments;
    • manage arrears;
    • recognise provisions and credit losses;
    • hold required capital and liquidity; and
    • operate under its ordinary prudential and risk frameworks.

    Under the current direction, mortgage losses remain with the bank rather than being passed through to HomeFund investors.

  6. Contractual payment obligation

    Step 6 — The bank makes the product payments

    The investor receives the return promised by the chosen legal claim, subject to its terms.

    The return is paid by the bank. It is not a direct distribution of interest from selected mortgages.

  7. Contractual or market outcome

    Step 7 — The claim matures, transfers or is otherwise dealt with

    At maturity, the bank would owe the amount specified in the legal terms.

    Before maturity, access would depend on the structure and the available mechanism. An early transfer price may be below the original investment, and a buyer or bank repurchase may not be available.

What does not flow directly to the investor

Mortgage purpose is not mortgage cash-flow ownership.

Under the current active directions, the investor would not directly receive:

  • a share of a borrower’s monthly repayment;
  • a selected mortgage’s interest margin;
  • ownership of a home loan;
  • ownership of the borrower’s property;
  • a right to choose borrowers or loan types;
  • a right to service or enforce mortgages;
  • a first-loss or pass-through mortgage exposure; or
  • proof that the bank made additional home loans because HomeFund existed.

Those features would require a materially different structure and risk allocation.

This distinction matters because phrases such as “mortgage linked”, “housing backed” and “funding home lending” can describe very different legal and economic arrangements.

One proposition, three validation cells

The customer promise changes with the legal form.

Cell A — Purpose-branded term deposit

The investor places money in a fixed-term deposit with the bank. The bank applies controlled mortgage-funding attribution and pays the agreed deposit return.

Potential strength
The claim is familiar and may provide the clearest path to eligible-deposit and Financial Claims Scheme treatment, subject to confirmation for the exact account and holder.
Primary weakness
It may be only a more expensive term deposit. If customers transfer persistent, lower-cost balances already held by the bank, the product may create little or no incremental funding value.
Before maturity
Access would follow the deposit terms. Early withdrawal, notice, adjustment or refusal rights would need to be stated clearly. Transfer to another investor is not assumed.
Current status
Mandatory baseline / potential kill comparator

Cell B — Senior unsecured retail note

The investor purchases a fixed-term senior obligation of the issuing bank. The bank attributes the proceeds to residential mortgage funding under the chosen control framework.

Potential strength
It provides a clearer investment form and hard contractual maturity. Investor-to-investor transfer may be possible without changing the issuer liability.
Primary weakness
It would likely be an issuer exposure outside the Financial Claims Scheme. A sale before maturity would occur at market value and could be below the original investment.
Before maturity
A buyer, price and market depth would not be guaranteed. Any bank repurchase would be separate from investor transfer and subject to explicit terms and capacity.
Current status
Leading investment-form validation cell

Cell C — Mortgage-covered retail note

The investor purchases a bank obligation supported by an identified residential mortgage cover pool.

Potential strength
The mortgage connection and security could be stronger and more verifiable than a purpose statement or internal allocation.
Primary weakness
The structure adds collateral, encumbrance, legal, reporting, valuation, assurance and operating complexity. It must compete with the bank’s existing covered-bond capacity and economics.
Before maturity
Transfer would still occur at market value unless the terms state otherwise. Cover-pool support would not itself guarantee early access at the original amount.
Current status
Conditional validation cell

These cells are not three versions of the same product. They are different legal claims that must be assessed under the same customer, Treasury, legal, prudential, accounting, tax, conduct and operating assumptions.

Four meanings of “linked to mortgages”

The strength of the claim depends on the linkage level.

  1. Level 1 — Purpose statement

    Active structural research

    The bank states that the funds are intended to support residential mortgage funding.

    What it may provide
    A clear purpose and public reporting.
    What it does not provide by itself
    Segregated assets, security, ownership, borrower cash flows or proof of additional lending.
  2. Level 2 — Controlled allocation and assurance

    Active structural research

    The bank identifies eligible mortgage funding or assets equal to the relevant amount and maintains an auditable allocation and reporting process.

    What it may provide
    Stronger evidence that the funding has been attributed consistently.
    What it does not provide by itself
    Security over mortgages or a beneficial interest in mortgage assets.
  3. Level 3 — Mortgage cover pool

    Active structural research

    An identified pool of residential mortgage assets supports the bank obligation under a legally defined covered structure.

    What it may provide
    A stronger legal and collateral connection, subject to confirmation of ranking, over-collateralisation, substitution and enforcement rights.
    What it does not provide
    Ownership of individual mortgages or a guarantee that an early sale occurs at principal.
  4. Level 4 — Direct asset or securitisation interest

    Comparator, not initial direction

    The investor holds a direct or trust-based interest in mortgage assets or mortgage cash flows.

    What it may provide
    The strongest direct asset connection.
    Why it is not the initial direction
    It would materially change the product, risk transfer, legal form, accounting, tax, disclosure and operating model. It is retained as a comparator rather than an active starting cell while the bank is intended to retain mortgage credit risk.
Stronger linkage may create stronger rights, or disproportionate cost and complexity.

A stronger mortgage link is not automatically better. It may create rights customers value, or it may add cost and complexity without improving informed consumer outcomes.

Where the return would come from

The product return would be a bank obligation, not a pass-through mortgage yield.

The bank earns interest from its mortgage portfolio and incurs the costs of deposits, debt, hedging, liquidity, capital, operations and credit losses.

HomeFund tests whether a defined retail liability could create enough funding value for the bank to pay an informed customer return after recognising:

  • the source of the invested money;
  • the cost and behavioural value of any displaced deposit;
  • matched-term alternative funding costs;
  • funds-transfer and liquidity pricing;
  • hedging;
  • legal, distribution and administration costs;
  • protection and collateral costs;
  • transfer or market-support costs; and
  • stress outcomes.

Mortgage portfolio income and bank-wide funding economics

minus displaced funding value

minus hedging and liquidity

minus operating, legal and distribution cost

minus protection, collateral and market-support cost

equals maximum economically supportable customer return

Customer payment is a contractual bank obligation. It is not direct mortgage-interest pass-through.

The customer return would be set by the product terms for a specific issue or deposit. It would not automatically move with a particular mortgage rate or the average interest charged to home-loan customers.

The original approximately 5 per cent concept remains only a controlled consumer-research cell. It is not an approved return, forecast or pricing rule.

The commercial condition remains:

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

Where that corridor does not exist, the issue should not proceed in that form.

What “principal protection” could mean

Protection at maturity and value before maturity are different questions.

Comparison of eligible-deposit protection, issuer promise, cover-pool support and early market value
Protection or value conceptRelevant structureWhat may be protected or owedWhat remains exposedValidation required
Eligible-deposit protectionPurpose-branded term depositFor a purpose-branded term deposit, principal rights would arise under the deposit contract.Financial Claims Scheme treatment would depend on whether the exact account is an eligible protected account, the account holder, the issuing authorised deposit-taking institution and the applicable scheme limits and rules.This treatment cannot be assumed for either note structure.
Issuer promiseSenior unsecured noteFor a senior unsecured note, principal due at maturity would be an obligation of the issuing bank.Its value would depend on the contractual terms, legal ranking, bank solvency and resolution or insolvency outcomes.A promise by the bank is not separate insurance against failure of that same bank.
Cover-pool supportMortgage-covered noteFor a mortgage-covered note, the investor may have the bank obligation plus rights associated with a defined cover pool or security structure.Cover-pool support does not create ownership of individual mortgages or automatically protect an early transfer price.The exact priority, recourse, collateral coverage and enforcement mechanics require specialist confirmation.
Early market valueAny structure exited before maturityNone of these maturity arrangements automatically protects the price of an early transfer.Interest-rate changes, bank credit conditions, market liquidity and remaining term could cause the market value to fall below the original investment.“Principal due at maturity” must never be presented as “principal available at any time”.

The matrix compares distinct rights and exposures. It does not present any outcome as unconditionally protected.

Holding, transferring, repurchasing and redeeming are different

“Liquidity” is not one mechanism.

Hold to maturity

The investor retains the claim until its contractual maturity and receives payments according to the terms.

Who supplies cash
The bank pays according to the terms at contractual maturity.
Issuer liability
The liability continues until its contractual maturity and then ends according to the terms.
How price is determined
Payments are determined by the terms rather than an early market transaction.
Effect on contractual tenor
This is the clearest way to preserve the intended term, but it may not suit customers whose circumstances change.
Principal-at-par status
The bank owes the amount specified in the legal terms at maturity.

Early withdrawal from a deposit

The customer seeks access under the deposit terms.

Who supplies cash
The bank, where access is available under the deposit terms.
Issuer liability
The deposit liability ends or reduces according to those terms.
How price is determined
Notice, loss of interest, adjustment, hardship treatment or restrictions would depend on the exact deposit design.
Effect on contractual tenor
Early access shortens the intended term.
Principal-at-par status
It is not an investor-to-investor sale, and access at principal is not assumed.

Investor-to-investor transfer

One investor sells the note to another investor.

Who supplies cash
The buyer supplies cash to the seller.
Issuer liability
The issuing bank’s liability and maturity may remain unchanged, while ownership and price change.
How price is determined
The price is determined by the transaction and may be above or below the original amount.
Effect on contractual tenor
The bank’s contractual liability may continue to the original maturity.
Principal-at-par status
A buyer, price and market depth would not be guaranteed.

Issuer repurchase

The bank purchases its own obligation from the investor.

Who supplies cash
This supplies cash to the investor.
Issuer liability
The purchase may extinguish the liability.
How price is determined
Any bank repurchase would be subject to explicit terms and capacity.
Effect on contractual tenor
Repeated or expected repurchases can reduce the funding benefit and create conduct, accounting, liquidity and stress risks.
Principal-at-par status
A bank repurchase at principal is not unconditional.

Redemption

The legal obligation ends and the bank pays the amount required by the terms.

Who supplies cash
The bank pays the amount required by the terms.
Issuer liability
The legal obligation ends.
How price is determined
The amount is determined by the terms.
Effect on contractual tenor
A customer right to redeem early can shorten the effective term and must not be confused with market transfer.
Principal-at-par status
Any payment at principal depends on the final legal terms.
The initial direction does not permit an unconditional bank buyback at principal.

What could happen before maturity

Four scenarios show why legal tradability is not assured liquidity.

Scenario 1 — A normal investor transfer

Event
A buyer is available and agrees a price.
Investor choice
The seller receives the market price. The new investor holds the claim.
Bank obligation
The bank’s contractual liability may continue to the original maturity.
Residual risk
The transaction depends on a buyer and an agreed market price.

Scenario 2 — The market price is below principal

Event
Interest rates, the bank’s credit spread, remaining term or market conditions have changed.
Investor choice
The investor may sell at a loss, wait, or use another mechanism if one is available under the terms.
Bank obligation
Principal due at maturity does not protect an early market price.
Residual risk
The market value may remain below the original investment before maturity.

Scenario 3 — No acceptable buyer is available

Event
A legally transferable note can still have little practical liquidity.
Investor choice
The investor may need to hold the claim, accept a lower price or wait for a later opportunity.
Bank obligation
The bank is not automatically required to intervene.
Residual risk
A buyer or acceptable price may not be available.

Scenario 4 — The bank offers a limited repurchase

Event
The bank may choose to purchase within stated limits, windows or conditions.
Investor choice
The investor may accept the offer if it is available under its stated terms.
Bank obligation
That decision must be distinguished from a customer right.
Residual risk
Capacity may be reduced or suspended, particularly under stress, unless the final legal terms provide otherwise.

A fair design must explain who supplies cash, how price is set, what happens to the issuer liability and what changes in stress.

What the investor would need to see

The product cannot be understood through a headline rate and a mortgage label.

Before investing, a customer would need one coherent explanation of:

  • Legal form

    The exact deposit or security and the issuing entity.

  • Return

    The rate or formula, payment timing, fees and circumstances in which payments change or stop.

  • Principal

    Who owes it, when it is due, its ranking and every condition attached to the maturity promise.

  • Financial Claims Scheme position

    Whether the exact product is eligible, ineligible or still awaiting confirmation.

  • Mortgage linkage

    The implemented linkage level, the allocation or collateral method, reporting and the rights the investor does and does not receive.

  • Term

    The maturity date, earliest permitted exit and the consequences of leaving early.

  • Transfer and repurchase

    Who may buy, how price is determined, whether a market maker exists, capacity limits and stress conditions.

  • Issuer and resolution risk

    What happens if the issuing bank weakens, enters resolution or fails.

  • Tax and accounting for the investor

    The expected treatment of income, disposal, transfer and any discount or premium, subject to specialist advice and individual circumstances.

  • Alternatives

    A fair comparison with savings, term deposits, bank debt, diversified fixed income, mortgage or private-credit funds and no investment.

If those matters cannot be shown together in a form customers can accurately explain, the mechanics are not sufficiently clear.

What the bank would need to operate

A simple customer proposition can require a substantial controlled operating model.

The bank would need to coordinate:

Product and legal

Legal form, terms, disclosure, customer rights, target-market and conduct controls.

Treasury

Issue timing, pricing, funding attribution, liquidity, hedging, transfer pricing and cannibalisation measurement.

Finance and accounting

Liability classification, interest expense, issuance and repurchase accounting, hedge treatment and general-ledger reconciliation.

Prudential and capital

Liquidity and stable-funding treatment, maturity recognition, asset encumbrance, resolution implications and regulatory reporting.

Mortgage allocation or collateral

Eligibility criteria, data lineage, substitutions, reconciliations, cover-pool controls or purpose-allocation assurance.

Registry and payments

Investor records, interest or distribution payments, maturity processing, ownership transfer and tax reporting.

Valuation and liquidity

Price methodology, dealing process, market-maker or repurchase capacity, limits, suspension controls and stress procedures.

Customer servicing

Statements, reporting, complaints, hardship or early-access handling and clear explanations when market value differs from principal.

Independent assurance

Validation that customer wording, legal rights, Treasury treatment, accounting, tax and operations all refer to the same versioned product.

All functions converge onOne controlled product version

Existing bank infrastructure may support parts of this model. That does not prove the model is simple, low cost or viable.

Where the mechanics could fail

The page is useful only if the flow can be rejected.

Rejection or simplification is a valid outcome.

Stop or redesign

The legal form and customer story do not match

An investment is described like a protected deposit, or mortgage-purpose language implies rights that the legal terms do not provide.

Stop or redesign

The mortgage link cannot be evidenced

The bank cannot maintain an auditable allocation, reporting or collateral process proportionate to the customer claim.

Stop or redesign

Maturity protection is confused with early value

Customers continue to believe they can always recover the original amount before maturity.

Stop or redesign

The liquidity design removes the funding benefit

Early redemption or expected bank repurchase shortens the effective term or creates stress outflows.

Stop or redesign

The return source cannot be explained fairly

Customers interpret the return as mortgage interest pass-through or assume that mortgage performance directly determines their payment when the legal claim says otherwise.

Stop or redesign

The operating model is disproportionate

Registry, valuation, collateral, disclosure, servicing and assurance costs exceed the value created.

Stop or redesign

Specialists validate different versions

Legal, Treasury, accounting, tax, prudential and consumer conclusions rely on inconsistent assumptions.

Stop or redesign

A simpler product provides the same value

A conventional term deposit or existing bank debt product delivers clearer customer rights at lower cost.

Current mechanics conclusion

The common flow is understandable. The final rights are not yet settled.

HomeFund can be described at a high level:

  1. an investor provides funds to a bank;
  2. the bank creates a defined legal claim;
  3. Treasury manages the liability and applies the chosen mortgage-linkage controls;
  4. the bank retains and manages mortgage credit risk;
  5. the bank makes the contractual product payments;
  6. principal is due according to the maturity terms; and
  7. early access depends on a separate, explicitly defined mechanism.

That sequence does not select a legal structure or validate the proposition.

The decisive questions remain:

  • Is the claim a deposit, unsecured note or covered note?
  • What mortgage linkage can be verified?
  • Who provides protection and under what conditions?
  • What happens before maturity?
  • Can customers understand the distinction between maturity value and early value?
  • Does the mechanism create incremental bank value after every cost?
  • Do all specialists assess the same product?

Until those questions are answered, HomeFund remains three controlled validation cells rather than one product.