2022-05-17
Paymark Limited submits comments on the Reserve Bank of New Zealand's Financial Market Infrastructures Bill, arguing that the legislation lacks a clear problem definition and imposes unnecessary regulatory burdens on retail payment systems. The submission contends that designating Paymark as a Financial Market Infrastructure would incur significant compliance costs without providing additional consumer protection or settlement finality benefits. Paymark advocates for a risk-based assessment framework, clearer definitions of payment systems, and alignment with the ongoing review of the Reserve Bank of New Zealand Act to avoid stifling innovation.