Licensing Solutions for New Zealand Deposit Takers | Pre-licensing Assessment | New Zealand Deposit Taker Licence Application Support | Post-licensing Risk and Compliance Management

We offer a comprehensive set of solutions to help you obtain and maintain a New Zealand deposit taker licence issued by the Reserve Bank of New Zealand (RBNZ), tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• regulated deposit takers' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the deposit takers licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the deposit takers' licensing process, including but not limited to the following aspects:

• Deposit Takers Licence Guidance: Advising on a wide range of aspects associated with deposit takers licence as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the deposit takers licensing conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the deposit takers licensing regime
• Deposit Takers Licence Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Service Coverage

This page is about New Zealand deposit taker licensing. Under the Deposit Takers Act 2023, entities offering deposit-taking services to the public must hold a deposit taker licence issued by the Reserve Bank of New Zealand (RBNZ). This licence authorises deposit-taking activities and imposes ongoing prudential, governance, and compliance obligations. Depending on the business model, additional requirements may apply (e.g., Financial Service Providers Register (FSPR) registration for dispute resolution, AML/CFT compliance programme approval). We offer support for deposit taker licence applications tailored to:

• Retail Deposit Takers
• Wholesale Deposit Takers
• Mixed-Model Deposit Takers
• Offshore Deposit Takers expanding to New Zealand
• Financial Institutions integrating deposit-taking activities

You can find more information about our New Zealand deposit taker licensing solutions below:

 

New Zealand Depoist Takers’ Licensing Preparation

Pre-licensing Compliance Assurance

Our deposit takers' licence solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a deposit taker's licence
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the deposit takers' licensing process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your deposit takers licence, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Deposit Takers Licence Application Plan: We help you establish a roadmap to effectively meet the requirements for your deposit takers licence

 

Deposit Takers Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our deposit takers licensing solution covers:

• Compliance Model Selection: To help you best comply with the deposit takers licensing regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for deposit takes and lenders and other applicable regulated New Zealand deposit takers' obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Deposit Takers Licence and Entering a Regulated Environment

We help businesses transition from an unregulated environment to operating under the deposit takers licensing regime, helping them meet their obligations as a deposit taker's licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the deposit takers licensing regime requirements.

Our focus areas for this service include:

• New businesses
• Existing deposit takers operating in unregulated markets
• Regulated deposit takers that expand into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated deposit taking services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with regulated non bank deposit takers’ obligations globally.

 

New Zealand Deposit Taker Licensing and Wholesale Markets

Obtaining a New Zealand deposit taker licence may not be necessary or suitable for all deposit-taking businesses, particularly where activities are limited to wholesale clients. Wholesale-only deposit-taking models generally fall outside certain prudential requirements under the Deposit Takers Act 2023, as they do not involve retail deposits. We offer risk and compliance management solutions to assist wholesale deposit takers that:

• Operate exclusively in wholesale deposit-taking markets
• Qualify for an exemption from retail-focused prudential requirements
• Offer services to wholesale, professional, and eligible investors under New Zealand law

We help these deposit takers manage compliance obligations that may still apply, including:

• AML/CFT Act obligations and reporting requirements
• Governance, risk management, and internal controls
• Prudential reporting where applicable
• Restrictions on advertising and offers to retail clients without meeting retail requirements
• Oversight of outsourced service providers

 

Deposit Takers Licence Application

We assist with your licence application through ongoing engagement in the deposit takers’ licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your deposit taker's licence application.
• Application Form Completion: We assist you in completing the forms to ensure all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Deposit Takers Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving Deposit Takers Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our deposit takers licence solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for Deposit Takers Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the deposit takers licensing regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your deposit takers licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.

• Licensing Issues Handling: We address common licensing issues encountered during the deposit takers’ licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• For further information, please visit our Compliance Remediation Solutions page.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for licensed New Zealand deposit takers. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• Regulated New Zealand Deposit Takers' Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the deposit takers licensing regime and other regulatory compliance obligations. You can visit our Compliance Consultancy Service page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for Deposit Takers.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:
• Regulated New Zealand deposit takers' obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• Deposit Takers’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for deposit takers. For more information, visit our Specialised AML/CFT Solutions page for Deposit Takers.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for Deposit Takers Licence Holders

Deposit takers' licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in the different areas. The list below is not exhaustive:

Deposit Takers Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil regulated New Zealand deposit takers' obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the deposit takers’ licensing requirements.
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the New Zealand deposit takers licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Capital Adequacy Requirements: We assist deposit takers in developing capital adequacy monitoring controls where required under licensing frameworks, including credit unions, building societies, and non-bank lenders operating under prudential or financial licensing regimes.
• Liquidity Management Requirements: We help implement liquidity monitoring and cash flow stress testing controls for licensed deposit takers, particularly where operating under financial institution or protected deposit frameworks.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the New Zealand deposit takers licensing regime.
• Credit Contract Compliance: Where applicable, we can help you establish controls to comply with consumer lending and disclosure obligations applicable to deposit takers entering into regulated credit contracts, including hardship provisions and responsible lending requirements.
• Proportionality Framework Positioning: We help New Zealand deposit takers evidence how they fit within the RBNZ proportionality framework, align their governance, capital, liquidity, risk management and reporting to their categorisation, and prepare for standards issued under the DTA.
  (as per the requirements of the Deposit Takers Act 2023 s 77 and standards under ss 72–90 in the RBNZ guidance).
• Significant Influence, Ownership and Control Changes: We support New Zealand deposit takers with applications, notifications, and control frameworks for transactions or ownership changes that create or vary significant influence, including preparing board artefacts and RBNZ submissions.
  (as per the requirements of the Deposit Takers Act 2023 ss 39–52).

 

Deposit Takers Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with deposit takers' licensing obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more (as per the requirements of the Deposit Takers Act 2023 s 85, standards issued under ss 72–90 in the RBNZ guidance).
• Structures for Governance: We can help you establish effective governance structures to comply with New Zealand deposit takers' obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with New Zealand deposit takers' obligations for senior management and key staff conduct and competence.
• Maintaining Operational Resilience: We assist in developing continuity plans to meet New Zealand deposit takers' obligations for operational resilience, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the New Zealand deposit takers licensing regime.

 

Deposit Takers Licence and Market Integrity/Transparency Requirements

• Fair Conduct Programme and FMA Financial Institution Licensing (CoFI): We help New Zealand deposit takers that provide relevant services to consumers to obtain an FMA financial institution licence, design, publish, and operate a Fair Conduct Programme (FCP), and align training, product governance, incentives and monitoring to Subpart 6A of the FMCA (as per the requirements of the Financial Markets Conduct Act 2013 ss 388, 446C, 446E, 446G–446J (inserted by the Financial Markets (Conduct of Institutions) Amendment Act 2022)).
• Standards for Conduct and Disclosure: We can help you comply with deposit takers' licensing standards for conduct and disclosure.
• Product Suitability and Governance: We can establish tailored controls to help licensed deposit takers comply with product suitability and governance obligations, including risk management and governance arrangements across the product life cycle.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

Deposit Takers Licence and Resource Management Obligations

We can help you comply with the following requirements of the New Zealand deposit takers licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Fit and Proper Certification and Ongoing Notifications: We help New Zealand deposit takers implement fit and proper assessment frameworks for directors and senior managers, draft board attestations, and manage ongoing notifications to the RBNZ for appointments and changes (as per the requirements of the Deposit Takers Act 2023 ss 26–38 & s 81)
• Other focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, deposit taking or lending regulations.
• Competence and Accreditations of Advisors and Representatives: We can advise you on certifications and continuing professional development (CPD) requirements for compliance professionals and senior management.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.

 

Deposit Takers Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Deposit Takers’ licensing obligations
  • Deposit Takers’ AML/CFT obligations (STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
  • New Zealand deposit takers' obligations under financial market conduct regulations
• RBNZ Direction Compliance, Remedial Plans and Event Reporting: We help New Zealand deposit takers design internal escalation, notification and remediation protocols to comply with RBNZ directions, remedial plans, and contravention reporting duties, including drafting submissions and board attestations (as per the requirements of the Deposit Takers Act 2023 ss 98–124 & ss 115–117).
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the New Zealand deposit takers licensing regime, applicable operational standards, and more.

 

Related Services

We assist in obtaining deposit takers' licence equivalents in the following jurisdictions:

• Australia: For more information on the Australian equivalent of a deposit taker's licence, the ADI licence, you can visit our ADI Licence page.
• United Kingdom: For more information on the UK equivalent of a deposit taker's licence, the UK building society authorisation, you can visit our UK Building Society Authorisation page.
• United States: For more information on the United States equivalent of a deposit taker's license, the Federal Savings and Loan Association license, you can visit our Federal Savings and Loan Association Licence page.
• Singapore: For more information on the Singaporean equivalent of a deposit taker's licence, the Singapore Finance Company Licence, please visit our Singapore Finance Company Licence page.
• Other Jurisdictions: We also offer licensing solutions for finance company licensing in prominent financial centres and offshore tax havens, including but not limited to: