KiwiSaver Divests and Disarms

KiwiSaver default funds have been banned from investing in fossil fuels and certain weapons under new legislation. Via InvestorDaily.

Default funds will be banned from investing in fossil fuel production to negate the risk of New Zealanders’ retirement savings being invested in stranded assets as the world moves to reduce emissions. 

“No New Zealander should have to worry about whether their retirement savings are causing the climate crisis,” said Climate Change Minister James Shaw. 

“That’s why our government is moving default KiwiSaver funds away from fossil fuels, putting people and the planet first.”

KiwiSaver members are allocated to a default provider if they don’t actively choose a KiwiSaver fund when commencing their employment. Around 690,000 people remain in a default fund, with approximately 400,000 of those having not made an active choice to stay there. 

The New Zealand government also believes that the switch to more responsible investment will also improve member outcomes. 

“In 2017, the $47 billion NZ Superannuation Fund adopted a climate change investment strategy that resulted in it removing more than $3 billion worth of stocks that exceed thresholds for either emissions intensity or fossil fuel reserves, without negatively affecting performance,” said Commerce and Consumer Affairs Minister Kris Faafoi.

“So we know that moving away from investments in fossil fuels doesn’t have to mean lower returns.”

The changes will also prevent default fund providers from investing in weapons like cluster munitions and anti-personnel landmines (which are subject to the Convention on Cluster Munitions and the Ottawa Treaty respectively). While default fund providers were already moving away from investment in weapons, the changes now enshrine that requirement in default fund settings.

RBNZ Imposes Higher Capital

The Reserve Bank of New Zealand today released its final decisions following its comprehensive review of its capital framework for banks, known as the Capital Review. The trajectory will be over a longer period, with more flexibility, but the banks will still need to hold more capital.

Governor Adrian Orr said the decisions to increase capital requirements are about making the banking system safer for all New Zealanders, and will ensure bank owners have a meaningful stake in their businesses. The changes will be implemented over seven years, giving plenty of time for banks to manage a smooth transition and minimise any adjustment costs.

“Our decisions are not just about dollars and cents. More capital in the banking system better enables banks to weather economic volatility and maintain good, long-term, customer outcomes,” Mr Orr says.

“More capital also reduces the likelihood of a bank failure. Banking crises cause not only harmful economic costs but also distressful social issues, such as the general decline in mental and physical health brought about by higher rates of unemployment. These effects are felt for generations,” Mr Orr says.

The key decisions, which start to take effect from 1 July 2020, include banks’ total capital increasing from a minimum of 10.5% now, to 18% for the four large banks and 16% for the remaining smaller banks. The average level of capital currently held by banks is 14.1%.

Relative to the Reserve Bank’s initial proposals, the final decisions also include:

  • More flexibility for banks on the use of specific capital instruments;
  • A more cost-effective mix of funding options for banks;
  • A lesser increase in capital for the smaller banks consistent with their more limited impact on society should they fail;
  • A more level capital regime for all banks – with the four large banks having to measure the risks of their exposures (lending) more conservatively, more in line with the smaller banks; and
  • More transparency in capital reporting.

The adjustments to the original proposals reflect our analysis and industry feedback over the past two years. All of these changes will be phased in over a seven-year period, rather than over five years as originally proposed, in order to reduce the economic impacts of these changes.

Deputy Governor and General Manager of Financial Stability Geoff Bascand says the decisions were shaped by valuable public input and insight received through an unprecedented number of submissions as well as public focus groups. Three international experts also provided supportive perspectives on the proposals.

“We’ve listened to feedback and reviewed all the data, and are confident the decisions are the right ones for New Zealand,” Mr Bascand says.

“We have amended our original proposals in a number of ways so we achieve a high level of resilience at lower potential cost, with a smoother transition path for all participants. Our analysis shows that the benefits of these changes will greatly outweigh any potential costs.”

“Following the Global Financial Crisis, many regulators around the world have been taking steps to improve the safety of their banking systems. We’re confident we have the calibrations right for New Zealand conditions. These changes will be subject to monitoring, with the Reserve Bank reporting publicly on implementation during the transition period,” Mr Bascand says.

APRA On Changes To Capital For NZ Subsidiaries

The Australian Prudential Regulation Authority (APRA) has launched a review of the capital treatment of authorised deposit-taking institutions’ (ADIs’) investments in their banking and insurance subsidiaries. It is open for consultation until 31 January 2020. APRA intends to finalise the changes to the Prudential Standard in early 2020 with the updated Prudential Standard to come into force from 1 January 2021.

At first review, this looks like some of the Australian majors will large New Zealand subsidiaries will need to hold more capital (which costs), or shrink their off-shore operations in New Zealand. But more analysis will be required to determine the true impact relative to their Australian businesses and capital holdings.

This review was prompted in part by recent proposals by the Reserve Bank of New Zealand (RBNZ) to materially increase capital requirements in New Zealand. The RBNZ’s proposals and APRA’s processes are a natural by-product of both regulators working to protect their respective communities from the costs of financial instability and the regulators continue to support each other as these reforms are developed.

APRA is proposing to change the capital treatment for these exposures and this particular proposal is the most significant amendment to APS 111. In developing the proposal, APRA has considered long-established trans-Tasman arrangements provided for in the Australian Prudential Regulation Authority Act 1998 and the RBNZ’s enabling legislation, under which the agencies assist each other in the performance of their regulatory responsibilities. This is particularly important given the four major Australian banks are the shareholders of the major banks in New Zealand.

APRA’s capital requirements currently permit ADIs to leverage their investments in banking and insurance subsidiaries, whether domestic or offshore, and as such do not require dollar-for-dollar capital for these investments at the parent company level. This treatment raises the risk that capital held by the parent ADI is not sufficient to support risks to its depositors.  Any reforms by other regulators to materially increase their capital requirements, including those proposed by the RBNZ, could exacerbate this risk.

At current levels of equity investment, APRA estimates the existing treatment provides an uplift to the average Common Equity Tier 1 (CET1) Capital ratio across the four major Australian banks of around 100 basis points for their equity investments in New Zealand banking subsidiaries. As a consequence, capital available to support risks to Australian depositors could be overstated.

As APRA is more concerned about large concentrated exposures, it is proposing to limit the amount of the exposure to an individual subsidiary that can be leveraged to 10 per cent of an ADI’s CET1 Capital. This means capital requirements are increasing for large concentrated exposures, as amounts over the 10 per cent threshold would be required to be met dollar-for-dollar by the ADI parent company. APRA is less concerned about small equity exposures in banking and insurance subsidiaries and so capital requirements will decrease for small exposures. Amounts under the 10 per cent threshold would be risk weighted at 250 per cent and included as part of the related party limits detailed in APRA’s recently finalised Prudential Standard APS 222 Associations with Related Entities (APS 222).

The diagram outlines the boundaries between a full deduction approach (dark blue line), the current treatment (grey line) and the treatment proposed in this Discussion Paper (light blue line). These represent the boundaries that balance the size of the investment with the capital required under the limits in APRA’s prudential framework for equity investments (APS 111) and related entities (APS 222).

A full deduction approach will result in dollar-for-dollar capital for this investment, regardless of the size of the investment. The treatment under the current APS 111 is a 300 per cent (if the subsidiary is unlisted) or 400 per cent (if the subsidiary is unlisted) risk weight for this investment. The proposed treatment in this Discussion Paper for this investment will depend on the size of the investment; for an equity investment below 10 per cent CET1 Capital, the investment is risk weighted at 250 per cent, with amounts above the 10 per cent CET1 Capital threshold deducted from CET1 Capital. Under the proposed treatment, capital requirements are decreasing for small exposures and increasing for large concentrated exposures.

APRA has calibrated the proposed capital requirements so they are broadly consistent with the Basel treatment of a banking group’s equity investments in non-consolidated financial entities, and also with the current capital position of the four major Australian banks, in respect of these exposures (i.e. preserving most of the existing capital uplift).  

APRA is not proposing a full dollar-for-dollar capital requirement for an ADI’s equity investments in these subsidiaries, in recognition of the benefits of subsidiaries that are subject to prudential regulation, and that ownership of banking and insurance subsidiaries generally provides some beneficial diversification. However, as these exposures increase in size, the concentration risk associated such investments start to outweigh the diversification benefits. Requiring dollar-for-dollar capital for amounts above 10 per cent CET1 Capital reduces the risks to Australian depositors of increasing levels of these exposures.
 
The finalisation of the RBNZ’s proposed capital reforms, will, in all likelihood, require higher capital requirements for banks in New Zealand. Should Australian ADIs fund higher capital requirements in New Zealand by retaining the profits of their New Zealand subsidiary banks in those subsidiaries, no material additional capital, in aggregate, is likely to be required by Australian ADIs.

Other proposed changes to APS 111 include:

  • promoting simple and transparent capital issuance by removing the allowance for the use of special purpose vehicles (SPVs) and stapled security structures; and
  • clarifying and simplifying various parts of APS 111, which comprise the bulk of the proposed changes.

APRA does not consider its proposal to remove the use of SPVs and stapled security structures as material as these structures have not been a feature of ADI capital issuance since 2013 and, in the case of stapled security structures, less attractive for ADIs under the Basel III capital reforms.

APS 111 is open for consultation until 31 January 2020. APRA intends to finalise the changes to the Prudential Standard in early 2020 with the updated Prudential Standard to come into force from 1 January 2021. APRA is open to working with impacted ADIs on appropriate transition.

A Return To The 1970’s [Podcast]

Property expert Joe Wilkes and I discuss the latest trends over the ditch, and consider parallels to the 1970’s.

https://www.linkedin.com/in/joe-wilkes-33803818/

Digital Finance Analytics (DFA) Blog
Digital Finance Analytics (DFA) Blog
A Return To The 1970's [Podcast]
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NZ Reserve Bank Seeks Views on Expanded Stewardship Role For Cash

Cash system participants and the wider public are being asked for their views about the Reserve Bank of New Zealand taking a more active role in the cash system.

A consultation paper has been released today as part of the Bank’s ongoing Future of Cash – Te Moni Anamata programme which is considering the implications for New Zealanders of falling cash use for every-day transactions, including the impacts on the system that supplies, moves and stores it.

Assistant Governor Christian Hawkesby says the Reserve Bank is just one cog in a cash system machine which includes the banking system, armoured truck companies, retailers, and independent ATM providers. “We see roles for all parts of the system – along with interest groups, whānau and individuals – in ensuring people who want or need to access or use cash can do so.”

The consultation paper proposes that the Reserve Bank take on a stewardship role in the cash system, providing system-wide oversight and coordination. It also proposes two tools which, though not currently required, may be needed in the future to respond flexibly to changes in the cash industry and the evolving needs of the public:

  • The Reserve Bank be given the power to set standards for machines that process and dispense cash.
  • The Reserve Bank Act set out regulation-making powers that enable the government and the Reserve Bank to require banks to provide access to cash deposits and withdrawals.

“These proposals are not the complete answer, but they would help create a foundation for the Reserve Bank to be more than the issuer of notes and coins when it comes to how we use cash which is an important component of our social and economic activity,” Mr Hawkesby says.

Mr Hawkesby says the Reserve Bank is grateful to the large numbers of individuals, groups, banks and other cash system providers, business and community organisations, and public sector agencies who are participating in the Future of Cash programme and sharing their views.

“Nearly 2400 individuals and groups gave feedback on our earlier issues paper discussing the potential impacts from a fall in cash use, particularly for people who are already financially or digitally excluded for whatever reasons. Meanwhile 3100 people randomly selected from the electoral roll have responded to a scientific survey updating our understanding of how New Zealanders are using cash and how this use is changing. We expect to publish results from both these efforts in November, and these will also feed into final recommendations in respect of the proposals released today.

”The changes in our latest consultation document would have significant consequences for all participants in the cash system. Banks, cash-in-transit providers, independent ATM operators, and the broader retail sector would likely be particularly affected. We want to continue to hear views and feedback from everyone about the purpose and desired attributes for the mechanics of the cash system, and how we could collectively improve it,” says Mr Hawkesby.

The paper is published on the The Future of the Cash System – Te Pūnaha Moni Anamata page, and feedback closes on 6 November 2019.

NZ Insurers – Weak Governance And Risk Management – Report

The Reserve Bank of New Zealand (RBNZ) and Financial Markets Authority (FMA) today released their findings on life insurers’ responses to the joint Conduct and Culture Review.

Overall, the regulators were disappointed by the responses. Significant work is still needed to address the issues of weak governance and ineffective management of conduct risk, identified in the regulators’ report earlier this year.

Rob Everett, FMA Chief Executive, said: “While we’re disappointed, we’re not surprised as the responses confirm what we found in our original review. It’s clear that progress has been slow and not as far-reaching as required.

Some providers have started work to identify the customer and conduct issues they face, others have not provided any detail on this.”

Sixteen life insurers were asked to provide work plans outlining the steps they will take to improve their existing processes and address the regulators’ findings and recommendations.

There was wide variance in the comprehensiveness and maturity of the plans provided.

Adrian Orr, Reserve Bank Governor, said, “We’re disappointed the industry’s response has been underwhelming. The sector has failed to demonstrate the necessary urgency and prioritisation, around investment in systems, to provide effective governance and monitoring of conduct risk.”

There was also a wide variance in the quality and depth of the systematic review of policyholders and products. Some did not complete this exercise and others did not provide data on the number of policyholders affected or the estimated cost of remediation activities. Insurers that completed the exercise identified at least 75,000 customer issues requiring remediation, with a value of at least $1.4 million. Some of the new issues identified included:

  • Overcharging of premiums and benefits not being updated due to system errors, human errors and under-reporting of deaths
  • Poor customer conversations overlooking eligibility criteria and poor post-sale communications, which lead to declined claims and underpayment of benefits
  • Poor value products were identified, where premiums charged were not fair value for the cover provided.

Sales incentives and commissions

The FMA and RBNZ committed to report back on staff incentives and commissions for intermediaries. Previous reports by the FMA reflected the concerns with conflicted conduct associated with high up-front commissions and other forms of incentives, (like overseas trips) paid to advisers.

Although some insurers have committed to removing sales incentives for employees and their managers, not all committed to removing or altering indirect sales incentives.

Those providers that have removed sales incentives for employees don’t typically use external advisers to distribute products. Providers using external advisers told the regulators that changing long-held business arrangements and distribution models is difficult and will take time to implement.

Mr Everett said, “We’re ready to work with life insurers to ensure they prioritise their focus on serving the needs of their customers, while at the same time balancing the need to remunerate advisers for the important work they do to help these customers. But we do not think high up-front commissions create confidence that insurers and advisers are acting in the best interests of customers.”

Mr Orr said, “Good governance within insurance firms requires the effective management of conflicts of interest. We need to see much better systems and controls in place to manage the inherent conflicts where advisers or sales staff are offered incentives to sell or replace insurance policies.”

Next steps

Those companies that have not undertaken comprehensive systematic reviews of policyholders and products have been asked to complete further reviews of their systems to identify issues, and to develop mature plans to respond and remediate any of their findings. These plans must be completed by December 2019.

The FMA and RBNZ will continue to monitor how the insurers are responding to recommendations and implementing their work plans. Life insurers are currently not legally required to become more customer-focused and the FMA and RBNZ found that the sector has a weak appetite for change. Deficiencies in some of the plans received, and some insurers’ lack of commitment to implementing the regulators’ recommendations, further demonstrates the need for additional obligations to be included in the regulation of conduct of life insurers.

Pepper launches mortgage offering in NZ

Non-bank lender Pepper Money has launched mortgage lending operations in New Zealand, offering advisers in New Zealand the technology and tools to write its prime, near-prime and specialist loans. Via The Adviser.

Following more than a year of consultation with advisers and intermediaries, lending partners, regulators and borrowers, Pepper Money has today (16 September) opened its business in New Zealand.

This builds on the international reach of the non-bank lending group, which already operates in Australia, the UK, Spain, Ireland and Asia.

New Zealand-born Aaron Milburn, Pepper Money’s director of sales and distribution in Australia, will head up the New Zealand business from today. His new job title will be director of sales and distribution for Australia and New Zealand.

Speaking to The Adviser about the new business, Mr Milburn said that Pepper Money will primarily distribute through the third-party channel, as it does in Australia.

Mr Milburn added that while while the company may look to launch mortgages directly in future, “the initial plan – and for the foreseeable future – is to utilise the adviser network over there”.

He explained: “We will initially distribute through the adviser network in NZ through all of the major aggregators that operate in New Zealand. 

“Pepper’s business is 95 per cent driven through brokers in Australia and in the UK, and we see no need to change that model as we enter NZ.”

He continued: “We think that advisers do a wonderful job in New Zealand, and we would like to continue to support that area of distribution as we enter NZ, as we do in Australia.”

Mr Milburn told The Adviser that his first priority in his expanded role will be to launch the suite of products in New Zealand and “deliver what advisers have been asking for at our various feedback sessions and study tours”.

According to the director of sales and distribution for Australia and New Zealand, this largely focuses around filling a “significant gap in the near-prime space in New Zealand, where families are potentially paying too much or have been in the wrong products due to a lack of choice” and providing advisers with supporting tools to help deliver these products.

He explained: “We had advisers in New Zealand contacting Pepper asking us to go over there and really inject some competition into the market and make it easier for advisers and, ultimately, Kiwi families to realise their goals.”

Pepper Money will therefore also offer advisers the Pepper Product Selector (PPS) tool in New Zealand, which will enable brokers to “get indicative offers for their customers in under two minutes”, as well as a “fully online integrated submission platform for brokers,” the marketing toolkit, the social media toolkit and the Pepper Insights Roadshow.

Pepper Money to pay trail

Notably, while the majority of lenders in New Zealand went through a “no trail” period starting in 2006 (when payments went from 0.65 of a percentage point in upfront commission plus 0.20 of a percentage point in trail commission to an average of 0.85 of a percentage point in upfront only), several lenders have begun returning to trail commission to reduce instances of churn.

According to Mr Milburn, Pepper Money in New Zealand will be offering advisers an upfront and trail commission.

He told The Adviser: “Overwhelmingly, the feedback was that an upfront and trail model was preferred. 

“A number of banks have either re-implemented trail in NZ or are looking to in the near future, so we took the opportunity to put trail back into the New Zealand market with our products.”

Mr Milburn concluded that the new operation in New Zealand would build on the practice and service offerings built in Australia.

He said: “We will continue to deliver the level of service and solutions that we do today and continue to really focus on that technology improvement side of things. 

“We want to make it easier and faster for brokers to provide solutions for their customers and help build their brand out in the community and the focus will continue in the back end of 2019 to 2020.”