The appeal of infinite banking rests on a real feature of participating whole life: with many such policies, the full cash value can continue to earn dividends and guaranteed growth even while a policy loan is outstanding against it, because the insurer lends its own money and uses the cash value only as collateral. Proponents describe this as making your money "work twice," growing in the policy while also funding a purchase. There is a kernel of truth here. The problem is what the marketing leaves out.
The first issue is cost and time. Whole life insurance is far more expensive than term insurance, and even an overfunded policy designed to maximize cash value carries the cost of insurance, policy charges, and, in the early years, a large sales commission. Cash value therefore builds slowly at first, and it can take many years before the cash value simply equals the premiums paid in. A strategy that requires large premiums for a decade before it works well is a strategy with a long and costly runway, during which the same money invested elsewhere would usually have grown more.
The second issue is that the policy loan is a loan. It charges interest, and that interest is a real cost even if it is paid to the insurer rather than to a bank. If a loan is not repaid, the balance plus accrued interest reduces the death benefit, and interest can compound against the policy. If loans and unpaid interest grow large enough to exhaust the cash value, the policy can lapse, and a lapse or surrender with a large outstanding loan can trigger a taxable gain, because the loan is treated as money received. Overfunding also bumps against a federal limit: fund a policy too fast relative to its death benefit and it becomes a modified endowment contract, after which loans and withdrawals lose their favorable tax treatment, so the "overfunding" the strategy depends on has to be engineered carefully to stay under that line.
The third issue is opportunity cost, which is the one the marketing most often obscures. The comparison that matters is not "borrow from your policy versus borrow from a bank"; it is "put your money into an overfunded whole life policy versus invest it in ordinary accounts and borrow, when you need to, on its own terms." For most people with ordinary financing needs, the second path leaves more money, because it avoids the insurance costs entirely. Infinite banking can suit a specific type of person, one who has a genuine permanent life insurance need, has already used their tax-advantaged accounts, values the policy's guarantees and creditor protections, and will actually hold the policy for life, but that is a narrow profile, and the concept is marketed far more broadly than that profile warrants.