2022-05-17
Visa Worldwide submitted comments to the Reserve Bank of New Zealand regarding the Exposure Draft Financial Market Infrastructures Bill, advocating for a risk-based regulatory approach. The submission argues that oversight should be proportional to systemic risk, recognizing that Visa operates as a B2B service provider to regulated financial institutions rather than a direct consumer-facing entity. Visa further urges the inclusion of principles-based, technology-neutral regulation and mutual recognition of existing international oversight to avoid duplicative costs and foster innovation.