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COMMONWEALTH BANK OF AUSTRALIA: EXECUTIVE LEADERSHIP BRIEFING

The 2030 Report | CEO Memo | June 2030

FROM: Macro Intelligence Unit TO: CEO, CFO, Board of Directors RE: Strategic Adaptation in the Age of AI Banking Disruption DATE: June 2030 CLASSIFICATION: Confidential - C-Suite

EXECUTIVE SUMMARY FOR LEADERSHIP

CBA enters H2 2030 having weathered the initial shock of fintech disruption and AI-driven banking commoditization, but strategic questions loom larger than they have in decades.

The core franchise remains strong: 24% deposit share, $565B in assets, highest-quality mortgage book, best digital platform. However, structural headwinds are accelerating, and the historical playbook (scale + market share maintenance + dividend growth) is no longer sufficient.

This memo outlines the strategic dilemmas leadership must resolve in the next 18-24 months.

THE INTERNAL REALITY: GROWTH EXPECTATIONS VS. MARKET DYNAMICS

Internally, there is a gap between earnings guidance and realistic outcomes. Here's what leadership needs to acknowledge:

Consensus Expectation: FY2030-2032 earnings CAGR of +3-4% (total earnings growth of $10.2B → $11.2B)

Realistic Outlook: FY2030-2032 earnings CAGR of -2-3% (total earnings growth of $10.2B → $9.5B)

This gap is not due to management incompetence or market share loss—it's due to structural industry dynamics:

  1. NIM compression is structural, not cyclical. Fintech has permanently changed the deposit market. Customers now have 15-20 legitimate alternatives to CBA deposits (Macquarie Savings, Raize, ING, Westpac/NAB, international platforms). This creates perpetual downward pressure on deposit margins. Historically, banks assumed deposit margins would revert to 200+ bps when rates normalized. That's no longer realistic—the new structural margin is 160-180bps.

  2. Non-mortgage lending has been commoditized. Personal loans, auto loans, and SME revolving credit are now largely commoditized by AI platforms. CBA's auto loan market share fell from 28% to 21% in 4 years. This trend will continue. Lenders competing on personal loans now earn 220-240bps (vs. 350bps five years ago). This is a permanent margin compression.

  3. Mortgage lending is under structural pressure. Housing markets are softening, fintech players (including Apple, offering mortgages through Apple Pay in some markets) are entering mortgage origination, and regulatory pressure on lending standards is tightening. Mortgage share is stable, but mortgage ROA is falling (from 130bps to 105bps in 5 years).

The honest assessment: Without structural changes to business model, CBA's net interest income will fall 3-5% annually for the next 3-5 years.

STRATEGIC DILEMMA 1: COST CUTTING OR GROWTH?

Leadership must choose between two strategic paths:

Path A: Cost Rationalization (Conservative Scenario) - Accept that NIM compression is structural - Implement aggressive cost-cutting (target: 35% cost-to-income by FY2032) - Reduce headcount by 15-20% (8,000-12,000 FTEs) - Divest non-core operations (insurance, superannuation if returns fall below 10%) - Accept lower earnings growth and positioning as "mature, stable dividend stock" - Trade current premium valuation (16x earnings) for defensive valuation (13-14x earnings) with higher dividend yield (5-6%)

Path B: Transformation (Aggressive Scenario) - Accept near-term earnings pressure (FY2030-2032 earnings flat-to-down) - Invest heavily in digital/AI to create new revenue streams (wealth management, embedded finance, fintech partnerships) - Target: 38% cost-to-income by FY2033 (vs. 43% currently) through capex investment - Maintain market share in core mortgages; concede non-mortgage share to fintech partners - Accept 2-3 years of earnings pressure in exchange for optionality in FY2033+ - Potentially command 15-16x earnings if transformation narrative gains credibility

Our Assessment: Path B is strategically superior but operationally difficult and high-risk. Path A is easier to execute but leads to terminal value destruction (mature utility bank valuation).

Recommendation: Pursue Path B, but structure it as a phased, optionality-preserving approach (outlined below).

STRATEGIC DILEMMA 2: FINTECH ECOSYSTEM OR COMPETITIVE WALLS?

The critical strategic question: Is fintech a threat to defend against or an opportunity to partner with?

Current Defensive Posture: CBA maintains high branch presence, powerful brand, and regulatory advantages (large banks have better capital ratios, lower funding costs). The implicit assumption: these will defend market share against fintech.

This is strategically naïve. Fintech isn't a threat that can be "defended against"—it's a structural market shift. The bank that thrives in FY2032+ will be the one that harnesses fintech as a partner, not resists it as a competitor.

Strategic Shift Needed:

  1. Embedded Finance Integration: CBA should position itself as the "backend" for fintech players. For example:
  2. Partner with digital native wealth platforms (e.g., Spaceship, Raize) to provide deposit/lending infrastructure
  3. Take a 15-25% margin on these partnerships (vs. 100% margin on direct lending) but achieve 10-15x higher volume
  4. Offer API access to CBA's mortgage, lending, and payment infrastructure at scale (à la Square Payments, Stripe)

Financial Impact: Could add $200-400M annual net interest income by FY2033, but requires <$100M capex investment

  1. Wealth/Investing Platform: CBA's current wealth platform (CBA Invest) has only 8% penetration (vs. 40%+ for Commsec's historical platform). Why?
  2. Legacy UI, limited product range, fee compression
  3. But the distribution (24% deposit share = ~5M active customers) is the most valuable asset in Australian fintech

Strategic Opportunity: Rebuild wealth platform as world-class (partnering with external fintech if necessary), targeting 25%+ penetration by FY2033. This could add $150-250M annual non-interest income.

  1. Credit Risk Exposure for Fintech Lenders: CBA has data advantage (credit scoring, fraud detection AI). Rather than compete on lending, offer credit risk services to fintech:
  2. Credit decisioning AI (sold to fintech lenders)
  3. Risk scoring API (priced per transaction)

Financial Impact: $100-150M annual fee income, very high margin

Execution Risk: This requires a complete mental shift from "we are a bank defending market share" to "we are a financial infrastructure provider enabling an ecosystem." This is hard for a 150-year-old bank.

STRATEGIC INITIATIVE 1: THE HOUSING MARKET BUFFER

Given the tail risk of housing stress, CBA should proactively manage credit risk.

Current Posture: Mortgage provisions at 1.1x default rate (elevated but not aggressive). Loan-to-Value (LTV) average is 75% (healthy).

Recommended Posture (Stress-Test Scenario): - Build mortgage loss provision to 1.5-1.8x default rate by FY2031 (takes $1.2-1.5B additional provisioning) - This is painful (reduces reported earnings by $300-400M in FY2030-2031) - But it removes tail risk and provides optionality if housing stress accelerates - If housing stress doesn't materialize, provisions reverse (earnings tailwind in FY2032-2033)

Strategic Rationale: The cost of housing crisis risk ($2-4B potential loss) outweighs the cost of increased provisioning ($1.2-1.5B). Additionally, proactive provisioning sends signal to rating agencies and investors that management is prudent.

Market Impact: Stock likely falls 5-8% on announcement due to earnings headwind, but then re-rates higher as risk premium is removed.

STRATEGIC INITIATIVE 2: THE DIGITAL TRANSFORMATION ROADMAP

Current capex ($800M+ annually) is not generating sufficient ROI. Here's why:

  1. Incremental Capex Philosophy: CBA is taking existing banking infrastructure and adding "digital" features. This is like bolting on a Tesla motor to a 1990s car—it doesn't work.

  2. Execution Paralysis: Digital initiatives take 2-3 years to deploy (vs. 6 months for fintech startups), due to regulatory requirements, legacy system integration, and organizational complexity.

  3. Wrong Metrics: Success is measured by "% of digital transactions" (70%+) rather than "ROI of capex" (12-14%, barely above WACC).

Recommended Reset:

  1. Build vs. Buy Decision Framework:
  2. Build: Core platforms (mortgages, deposits, payments) where CBA has competitive advantage
  3. Buy/Partner: Peripheral services (wealth, small business lending, fintech integration) where others are better positioned

Example: Rather than spend $150M building superior wealth platform in-house, acquire a scaled fintech wealth platform ($300M) and integrate with CBA's distribution (faster, lower risk, higher ROI).

  1. Capex Reallocation:
  2. Current: 40% core banking, 30% fintech partnerships, 20% cybersecurity, 10% innovation
  3. Recommended: 50% core banking, 25% fintech partnerships, 15% cybersecurity, 10% innovation, 0% "nice to have"

Impact: Reduce total capex from $850M to $750M, but increase ROI from 12% to 16%+ IRR

  1. Outcome Metrics:
  2. Success = reduced cost-to-income ratio (target: 38% by FY2033)
  3. Success = new revenue streams from partnerships ($150-250M by FY2033)
  4. Success = 15-20% reduction in customer churn to fintech (from current 12% annual churn)

STRATEGIC INITIATIVE 3: THE DIVIDEND POLICY RESET

CBA's current dividend policy (65-70% payout ratio) is unsustainable given structural earnings headwinds.

Current Reality: - FY2029 dividend: $1.21/share (65% payout, $3.2B total) on $10.2B earnings - This is sustainable if earnings grow 3-4% annually - But if earnings are flat-to-down, payout ratio rises to 70-75% (requiring dividend cuts or earnings growth)

Recommended Reset:

  1. Phase 1 (FY2030-2031): Maintain Dividends
  2. Keep dividend stable at $1.20-1.25/share to maintain investor confidence
  3. Payout ratio rises to 70-75% (acceptable, given confidence in recovery)

  4. Use messaging: "Investing in digital transformation; dividend maintained during transition"

  5. Phase 2 (FY2032): Dividend Growth Resume

  6. If digital transformation delivers and earnings stabilize at $9B+, resume dividend growth (3-4% annually)
  7. Payout ratio falls back to 65-70%
  8. Use messaging: "Digital transformation delivering benefits; dividend growth resumes"

Investor Management: - Proactively communicate dividend sustainability in next earnings call - Provide scenario analysis (base case: stable dividend; upside case: modest growth; downside case: modest reduction) - Frame dividend policy as "sustainable through the cycle," not "unchanged forever"

COMPETITIVE POSITIONING: CBA VS. MACQUARIE

The most dangerous peer to CBA is not another traditional bank—it's Macquarie Group.

Macquarie is using data, AI, and infrastructure scale to build a financial ecosystem that bypasses traditional banking: - Macquarie Savings: 8%+ deposit rates (eroding CBA deposit base) - Macquarie Mortgages: AI underwriting, streamlined approval (competing on convenience) - Macquarie Investments: Superior wealth platform to CBA's offering - Macquarie Infrastructure: Capturing high-ROI asset infrastructure deals

The Risk to CBA: Macquarie could become the "Amazon of Australian Finance"—the one-stop platform where customers maintain deposits, mortgages, investments, and insurance.

CBA's Counter-Strategy: - Position as the "backbone of Australian finance" (provide infrastructure to multiple platforms, not just own platform) - Partner with complementary fintech (don't try to beat them) - Maintain unmatched distribution (24% deposit share = 5M active customers) as strategic moat - Use regulatory advantages (large bank capital ratios) to offer lower funding costs to partners

RISK MANAGEMENT: THE CONVERSATION LEADERSHIP MUST HAVE

  1. Housing Crisis: If unemployment rises 1.5-2% and house prices fall 15-20%, CBA could face $2-4B mortgage losses. Current provisions cover only $400-600M. Plan for tail scenario now.

  2. Fintech Disruption: If fintech accelerates deposit erosion (to 30% market share by FY2033), NIM falls to 160bps (vs. 168bps forecast). This is $600M earnings hit not in current model.

  3. Execution Risk: Digital transformation capex is high-risk. If ROI underperforms (16% IRR vs. 14% target), earnings could be depressed $200-300M in FY2033.

  4. Regulatory Risk: APRA could require higher capital ratios (due to housing concentration risk). This would force lower dividend payout or capital raise.

All of these risks are manageable with proactive planning, but they require honest conversation now, not surprises later.

RECOMMENDATION: THE THREE-YEAR ROADMAP

2030-2031: Transformation & Transition - Communicate digital transformation narrative (capex: $850M) - Maintain dividend; accept earnings pressure - Build housing market provisions; signal prudent risk management - Begin fintech partnership architecture (target: 3-5 significant partnerships)

2031-2032: Optionality & Evidence - Early wins from fintech partnerships visible in financial results - Cost-to-income ratio falling (toward 39-40%) - Wealth platform pentration rising (toward 18-20%) - Housing stress manageable; provisions stabilize - Earnings stabilizing

2032-2033: Growth Resume - Digital transformation capex declining (mission mostly complete) - Cost-to-income at 38%+ (target achieved) - New revenue streams (fintech partnerships, wealth, embedded finance) clearly visible - Earnings recovering to $9B+ with 3-4% growth trajectory ahead

This roadmap is transparent, achievable, and positions CBA for sustainable competitive positioning in the AI-enabled banking era.

The 2030 Report — Macro Intelligence "Strategic Insight for Demanding Leaders"