2023-07-31
Payments NZ Limited submitted comments to the Reserve Bank of New Zealand regarding the proposed Financial Market Infrastructures Standards under the FMI Act 2021. The submission argues that as a rules body rather than an infrastructure operator, many standards concerning credit risk, collateral, and cyber resilience are not applicable and requests a formal carve-out mechanism for irrelevant requirements. It further highlights the significant workload required to restructure its voluminous rule set for designation by the August 2023 deadline and seeks definitive guidance on the Reserve Bank's approach to this process.