Everyday Rewards Will Pay Up to 400,000 Points on a Broker-Settled Loan. Offset Money Doesn’t Count Toward the Balance That Earns Them

On 4 November Woolworths Group announced that Everyday Rewards — a loyalty program it says has 10.9 million active members — had struck its first home loan broker partnership, with the home loan technology platform Middle. The offer opened on 5 November 2026. A borrower who settles an eligible loan through a broker connected by Middle can earn up to 250,000 points on settlement, plus 30,000 points a year for up to five years: up to 400,000 points in total, which Woolworths puts at about $2,000 in Everyday Rewards dollars.

That is the press release. The part that matters to your file sits in the Program Terms and Conditions, and it is a definition rather than a number.

Middle’s Program Terms and Conditions (Version 1.0, dated 01/11/2026) define the Eligible Loan Balance — the figure the points are calculated on — as “the outstanding loan balance of the Eligible Facility, excluding any amounts held in an offset account or sub-account linked to the Eligible Facility.” Middle’s own offer page puts the same thing in plain English: money in an offset account “can therefore reduce the points you earn.”

So the promotion is paid on a balance that an offset account shrinks. Which puts it on a collision course with a paragraph of ASIC guidance that has been sitting in RG 273 since June 2020.

What was actually announced

The settlement reward is tiered on the eligible loan balance. Middle’s published tiers are:

• $400,000 to $599,999 — 100,000 points
• $600,000 to $799,999 — 150,000 points
• $800,000 to $999,999 — 200,000 points
• $1,000,000 or more — 250,000 points

Using the conversion implied by Woolworths’ own figures (250,000 points ≈ $1,250; 30,000 points ≈ $150), those tiers are worth roughly $500, $750, $1,000 and $1,250 respectively.

The annual reward is 30,000 points a year for the first five years, and it is conditional: Middle’s page footnotes it to apply “when your eligible loan balance is $350,000 or more at each anniversary.” Worth noting for accuracy — Middle’s tier table shows the annual reward against the $400,000–$599,999 row and leaves the other rows blank, while the headline “up to 400,000 points” (250,000 + 150,000) implies it runs at the top tier too. The Program T&Cs say the number of Anniversary Rewards points is “specified in the Offer Details” and is based on the Eligible Loan Balance at each anniversary. If you are going to mention the annual reward to a client in a higher band, confirm it in the Offer Details first rather than reasoning from the banner.

Eligible lending covers residential purchases, refinancing to a new lender and investment property purchases across what Middle describes as a network of more than 60 lenders, including the four majors. Points are credited within 120 days of settlement, and within 120 days of each anniversary, once Middle confirms eligibility. The borrower needs an Everyday Rewards account linked before settlement, and where there are two or more borrowers one account is nominated — points are not split or duplicated.

Hannah Ross, Managing Director of Everyday Rewards, said in the release: “Our members are always looking at how they can earn the most points possible.” Julian Heath, Executive General Manager of Middle, said: “Comparing options across multiple lenders rather than relying on just one can make a real difference.”

RG 273 already has a paragraph for this

ASIC’s Regulatory Guide 273 deals with promotional offers directly, and the sequence of three paragraphs is unusually tidy for our purposes.

RG 273.63: “We expect that any promotional offer that is quantifiable will be considered as part of the cost of the credit product.”

RG 273.64: “The value of some promotional offers is not easily quantified.” ASIC then gives, as its example, exactly this kind of offer: “offers which include the provision of rewards points may be more valuable to certain consumers.”

RG 273.65: “You should also consider whether a lower interest rate, or other features such as an offset account, would provide more benefit to the consumer than the short-term benefit offered by the promotion.”

Read 273.65 next to the Eligible Loan Balance definition. ASIC’s guidance asks you to weigh an offset account against a promotion. This promotion is calculated on a balance that excludes offset funds. The two things ASIC asks you to compare are, in this particular offer, pulling in opposite directions on the same number.

None of that makes the offer a problem. It is a lawful consumer promotion, and a client who wants points is entitled to value them — RG 273.64 says as much. It does mean the comparison is not a throwaway line, and that the reasoning belongs on the file.

The arithmetic worth running once, so you can run it from memory

Take a $600,000 loan. At that balance the settlement reward is 150,000 points, about $750, and five years of annual rewards adds another 150,000 points, about $750. Call it roughly $1,500 of rewards value spread over five-plus years, with the back half contingent on the balance staying above $350,000 at each anniversary.

Now take a client who keeps $50,000 in an offset account. At an illustrative 6.00% per annum — an assumption for the arithmetic, not a quoted rate — $50,000 offset against the loan for a year avoids about $3,000 of interest. One year of using the offset is worth roughly double the entire five-year points haul.

The threshold is where this gets concrete. Because the Eligible Loan Balance excludes offset money, a client with $380,000 outstanding and $40,000 sitting in the offset has an Eligible Loan Balance of $340,000. That is below the $350,000 anniversary minimum, so the 30,000-point annual reward does not land that year — while the $40,000 in the offset is saving them roughly $2,400 a year at 6.00%. The client is $150 of points worse off and materially better off in cash. That is the right outcome; it is just worth being the one who explains it rather than the one who gets a confused phone call in month thirteen.

The same logic touches the settlement tier. If a borrower settles with savings already parked in the offset, the balance the reward is measured on is lower than the loan amount, which can land them a tier down — $250 of points between the $600,000 and $400,000 bands. Confirm in the Offer Details when the balance is measured before you promise a tier.

The five-year tail has a direct-dealing clause

Three exclusions in the Program T&Cs matter more to your workflow than the tiers do.

First, variations are out. Clause 1.2(c) excludes “a variation to an existing loan, including but not limited to a principal increase (top-up),” along with repricing and product switches. Standalone bridging-only lending that does not lead to a longer-term home loan is also excluded.

Second, and this is the one to read twice: clause 2.6 provides that if the client deals directly with the lender for a variation or internal refinance, they “will no longer be eligible to earn Anniversary Rewards” for that facility.

Third, a refinance of a loan previously established under the Program is excluded where the client received Everyday Rewards points within the preceding 24 months.

Put those together and the offer carries a five-year condition that rewards the client for not going direct to their lender on a variation. Brokers are, correctly, told to run annual reviews and to reprice. Repricing itself is excluded from earning points either way — but a client who calls their bank directly to do it may also forfeit the remaining annual rewards on that facility.

This is where the conflict priority rule deserves a mention. RG 273.9 states that “you are required to give priority to the consumer’s interests,” and RG 273.161 that “you should ensure that all your recommendations are made with the consumer’s interests as the primary consideration.” A retained points tail is a reason a client might prefer to come back through you. It is not a reason to discourage a client from a repricing conversation that would save them more than the points are worth. Those two things are easy to hold apart in principle and easy to blur in a hurried phone call, which is precisely why the file note matters.

What this is not

On the published terms, the points go to the borrower. Clause 1.5 credits points earned “to your nominated Everyday Rewards account,” and clause 1.7 requires multiple borrowers to nominate one account. Neither Woolworths’ release nor Middle’s offer page describes any reward to the broker. This is a client-facing incentive, not broker remuneration — and it should not be described to a client as something you are giving them.

Separately, and stated neutrally because it is simply how the platform is funded: the Program T&Cs define “Lender Commission” as commission “paid by a credit provider to us (directly or indirectly by your mortgage broker or their aggregator),” usually in the month following settlement. The documents do not state the amounts. If you are accredited through Middle, or considering it, the commercial terms of that arrangement are a question for your licensee and your aggregator, not something to infer from a loyalty announcement.

One more boundary: the offer runs through brokers connected to Middle. The Adviser reports the platform has more than 1,800 brokers using its digital workspace and has supported more than 200,000 customers; Middle is a credit licensee (ACL 536443) backed by MA Financial Group (ASX: MAF). If you are not on the platform, a client who has seen the Woolworths campaign may ask you why you cannot offer points. The answer is a channel answer, and it is better given calmly than defensively: the points attach to a particular lodgement path, your recommendation attaches to the loan, and the loan is the thing that costs or saves them money for the next three decades.

The file note

RG 273.104(b) expects that “you clearly record the recommendations you presented, including any alternatives that are not selected by the consumer.” RG 273.160 says “you should keep records of your reasoning behind any recommendation you make,” and RG 273.162 that “we expect you to keep records of how you have acted when providing credit assistance.”

Where a client raises the points — or where you mention them — a defensible note is short and specific:

1. That the client raised or was told about the Everyday Rewards offer, and the date.
2. The approximate value you quantified, and on which tier — RG 273.63 treats quantifiable promotional value as part of cost.
3. That you explained the points are calculated on a balance excluding offset funds, and what that meant for this client’s intended offset use.
4. The comparison you ran: the cost difference between the recommended product and the alternatives, against the promotional value — per RG 273.65.
5. Why the recommended product was still the recommendation, or, if the points did tip a close call between comparable products, that reasoning stated plainly.

The failure mode here is not recommending a loan because of points. It is recommending a perfectly good loan and leaving no record that the promotion was weighed at all, then being asked about it in a review eighteen months later.

What to review this week

• Read the Offer Details, not the banner. Confirm the balance measurement date, and whether the annual reward applies at the tier your client sits in.
• Check your offset clients. Anyone you have put into an offset strategy near the $350,000 line will not earn the annual reward. Know that before they ask.
• Script the channel question. One or two sentences on why points sit with a lodgement path and not with a loan recommendation.
• Add a line to your BID template. A promotional-offer field costs nothing and closes the 273.63/273.65 gap.
• Ask your licensee how they want a third-party consumer incentive treated in your comparison, your disclosures and your file notes.

What to watch next

Two things. First, whether other loyalty programs follow — The Adviser notes this partnership comes after Prospa’s March tie-up with Qantas Business Rewards, which suggests the model is being tested across the channel rather than one-off. Second, whether ASIC says anything. REP 840, published 13 October 2026, reviewed best interests duty and complaints; promotional offers were already in RG 273 before this launch, and nothing in the current guidance is new. But a consumer incentive that interacts arithmetically with an offset account is a reasonably novel fact pattern, and the industry’s handling of it is the kind of thing that turns up in a later review.

Clause 2.7 also lets Middle vary the Anniversary Rewards terms on “reasonable notice in writing.” A five-year promise with a variation clause is worth describing to clients as what it is.

The practical point

The cash rate went to 4.85% on 3 November, a 25 basis point increase carried six votes to three. In that environment a client who can see $2,000 of supermarket points is going to ask about them, and the honest answer is that $2,000 spread over five years is small next to what the rate and the offset do to the same loan. RG 273.64 says rewards points “may be more valuable to certain consumers,” and for some clients that is true. Your job is not to talk anyone out of points. It is to make sure the points are weighed against the things that move more money, and to leave a record that you did it.