2022-05-17
The New Zealand Bankers Association submits feedback to the Reserve Bank of New Zealand regarding the proposed formalization of bank breach reporting under Section 93 of the Reserve Bank Act. The submission advocates for a materiality threshold to exclude trivial breaches from mandatory public disclosure, arguing that this aligns with market discipline principles and reduces unnecessary compliance burdens. Additionally, the Association recommends that banks retain responsibility for drafting public disclosure notices and suggests specific criteria for assessing breach materiality to ensure clear and effective communication with depositors and investors.