I've seen three numbers this fortnight that don’t sit comfortably together.
The first is 55%. That’s the share of mortgage offset accounts ASIC found that customers had opened and that were never linked to their loan. We’re talking eight banks, circa 70% of a $2.5 trillion home loan market, and $55 million+ repaid to more than 250,000 people. ASIC Chair Sarah Court called it "a systemic issue that is widespread across the sector". (ASIC, REP 837)
The second is 119,949. That’s the preliminary complaint count for 2025/26 published yesterday by AFCA (Australian Financial Complaints Authority). It’s a record, up 19%, and the third straight year above 100,000. Banking and finance rose 23%, super 42%, and investments and advice 56%, largely thanks to the Shield and First Guardian wreckage. (AFCA)
The third is $52. Way to go Jetstar, today in less than three hours you went from zero to 10,000+ searches on this. Why? Because you’re our budget carrier and now (as well as charging for water) you’re adding overhead locker storage fees to fares.
Nobody buys an offset account
They buy the feeling that their savings are quietly working against their mortgage while they sleep. More than half the time, in ASIC's sample, the thing was never plugged in.
I have repeatedly seen an issue like this be labelled a data integrity or system issue. It isn't. It's a promise invented and shipped by marketing, then quietly drowned by operations. The distance between those two floors kills reputations.
Complaints used to be noise. Now they're a map
Here's the bit your Board or C-suite might skate past but should slow down to read. ASIC named claims and complaint handling failures as a 2026 enforcement priority in November 2025. AFCA has now published, category by category, precisely where those failures sit.
Read the two side by side and you have a regulator hit list, in public, with your name or brand on it.
Risk lives in the gap between what people expected and what they got
The E in the F.E.L.T. card I shared at comms webinar this week is for “expectations”.
In answering a hard media inquiry or facing a crisis most of us leap from "what happened?" to "what can we say?", which is reliably the fastest way to make things worse.
The better question is “what did people think they were getting?”. What was their actual experience and how do they feel about that?
By the time it's a Senate hearing, the gap has been there for years.