2022-05-17
The Bank of New Zealand submitted feedback on the Financial Market Infrastructures Bill Exposure Draft, advocating for the inclusion of bilateral clearing systems within the regulatory scope and greater flexibility in rule change timeframes. The submission argues that proposed criminal sanctions for directors and corporations are disproportionate, recommending pecuniary penalties instead to avoid detaining qualified professionals and stifling innovation. Additionally, BNZ urges aligning the Bill's introduction with the Phase 2 review of the Reserve Bank of New Zealand Act to ensure policy consistency and mitigate implementation risks.