Whilst what you say is true, I don't think it would be impossible to create a structure that achieves similar outcomes without being a licensed ADI. If I were

Whilst what you say is true, I don't think it would be impossible to create a structure that achieves similar outcomes without being a licensed ADI. If I were attempting to do a similar thing, rather than positioning the "bank" as a separate service, I'd be offering full "auspicing" as many national NGOs have traditionally done for locally-run activities, where the "bank" service is actually just automating internal financial procedures for authorising transfers of money that belongs to the incorporated body rather than accepting deposits on behalf of a separate group of people. edit: hah, just read the comments below and this seems to be exactly what they're doing