2022-05-17
The Securities Industry Association submitted feedback to the Reserve Bank of New Zealand regarding the August 2019 Exposure Draft of the Financial Market Infrastructures Bill. The Association argues that the proposed criminal liability regime for participants is disproportionate and recommends replacing it with civil pecuniary penalties or other non-criminal enforcement measures. Additionally, the submission highlights concerns that the new regulatory requirements may increase compliance costs for NZX Clearing Participants without necessarily enhancing risk mitigation.