2021-06-16
ANZ Bank New Zealand Limited submitted responses to the Reserve Bank of New Zealand regarding draft Banking Prudential Requirements, primarily supporting the New Zealand Bankers Association's position. The submission highlights specific concerns regarding the mandatory New Zealand law governance for AT1 and Tier 2 instruments, recommending a compromise to maintain offshore marketability while ensuring local subordination rules apply. Additionally, ANZ provided detailed feedback on market risk capital calculations, capital adequacy processes, and transitional provisions to clarify ambiguities and reduce compliance burdens.