The Reserve Bank has today released submissions along with a Summary of Submissions (PDF 399 KB)
on the latest consultation paper in its Capital Review, which proposes several measures to ensure a safer banking system
for New Zealanders.
There was significant and wide-ranging media and public interest in the How much capital is enough? (PDF 545 KB)
paper, with written feedback from 161 submitters. Feedback has also been received from analysts and other interested
parties who did not make a formal submission.
“The Reserve Bank welcomes the large number of submissions on this consultation, as well as the effort and consideration
that has gone into them,” Deputy Governor Geoff Bascand says. “We believe this shows how important this issue is for
everyone, and we are pleased that a broader set of stakeholders has taken an interest in the Capital Review.”
In general, submitters support the Reserve Bank’s objective to ensure that New Zealand’s financial system is safe,
acknowledging the economic and well-being impacts of banking crises. Many submitters, particularly from the general
public, support the proposed higher capital requirements for banks. A number of submitters observe that higher capital
requirements could lead to higher borrowing costs for New Zealanders. Some submitters, in particular banks and business
groups, question whether the proposed increases are too large and too costly.
Central to the measures proposed in the consultation paper are increases in regulatory capital buffers for locally
incorporated banks. The changes include requiring bank shareholders to increase their stake so that they absorb a
greater share of losses should their bank fail, improving the quality of capital, and ensuring banks more accurately
measure their risk.
Increasing the amount and quality of capital can be reasonably expected to mean that banks can survive all but the most
exceptional shocks, Mr Bascand says. “We think the costs of doing so are outweighed by the benefits - someone’s cost is
for society’s broader benefit.”
The Reserve Bank is also consulting on changes to the quality of capital, constraints on modelling capital requirements,
and the implementation timeline.
It is continuing its stakeholder outreach programme, which includes conducting focus groups to understand the public’s
risk appetite, and engagement with iwi, social sector and industry groups, financial institutions and investors. It has
also engaged three external experts for an independent review of its proposals.
“The submissions on the proposals are just one part of the review,” Mr Bascand says. “All these inputs will help us to
make robust and well-calibrated policies and decisions that best represent society’s interests.”
In this context, Mr Bascand welcomed reports by two key international financial institutions and a major rating agency
last week that support the proposals to increase bank capital ratios.
Following its recent mission to New Zealand, the International Monetary Fund has released a Concluding Statement
that highlights the need for strengthening bank capital levels and that the proposals appear commensurate with the
systemic financial risks facing New Zealand. The Organisation for Economic Co-operation and Development’s latest Economic Survey of New Zealand
expects increases in capital will likely have net benefits for New Zealand. And Standard and Poor’s says that the
proposals should not have material impacts on overall credit availability.
The Capital Review began more than two years ago, when the Reserve Bank published an issues paper and opened the first
of four public consultations. It will publish its response to the submissions alongside final decisions, expected in
Implementation of any new rules will start from April next year. There will be a transition period of a number of years
before banks are required to meet the new requirements.
• The Summary of Submissions
collates the common themes and views. It is not intended to be an exhaustive summary of all points raised, and will not
provide the Reserve Bank’s response to the submissions. These will be published alongside final decisions, expected in
• There are four consultation papers published by the Reserve Bank as part of the Capital Review. The first, an ‘Issues Paper' (PDF 280KB)
, discussed at a high level the scope and key issues that should be covered by the Review.
• The second, ‘What should qualify as bank capital?' (PDF 1.20MB)
discussed the definition of regulatory capital instruments. Questions relating to the measurement of risk for bank
exposures were addressed in the third consultation paper, ‘Calculation of risk-weighted assets' (PDF 1.06MB)
• The most recent consultation paper, ‘How much capital is enough?' (545 KB)
asks for views on proposed capital requirements for banks, as well as the other proposals in the Capital Review to date.