2022-05-17

Bell Gully Submission on the Financial Market Infrastructures Bill Exposure Draft

Bell Gully submitted technical amendments to the Reserve Bank of New Zealand's exposure draft of the Financial Market Infrastructures Bill, focusing on definitions, statutory protections, and cross-border regulatory conflicts. The firm recommended clarifying the scope of 'participant' and 'insolvency event', ensuring automatic statutory protections for designated FMIs, and preventing directions that breach overseas laws. Additionally, Bell Gully proposed extending settlement protection periods for central counterparties and refining the interaction between the Bill and derivatives margin regulations to ensure legal certainty during statutory management.

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