CAP 143
| Category: | Wealth aggregation |
| Business Goal: | BG-016 — Complete financial picture for every customer |
| System Domain: | SD06 — Risk Platform |
| Satisfying Modules: | MOD-101 Wealth intelligence engine |
| ADR: | ADR-041 |
Description¶
Two KiwiSaver health indicators are computed daily from the customer's transaction and external asset data, surfaced as in-app insights. Neither constitutes financial advice — both are factual observations derived from the customer's own data.
1 — Government member tax credit gap¶
The NZ government contributes $0.50 for every $1 a KiwiSaver member contributes, up to a maximum of $521.43 per year. To receive the full credit, a member must contribute at least $1,042.86 in the KiwiSaver financial year (1 July – 30 June).
This is widely under-utilised. Many KiwiSaver members — particularly those who are self-employed, took a contribution holiday, or only contribute via employer minimum — miss out on some or all of this government contribution.
What the bank surfaces:
"You've contributed $620 so far this year. Contributing $42 more per week would unlock the full $521 government match before 30 June."
The calculation is derived from observed contribution credits in the customer's transaction history (employer and voluntary). It does not tell the customer which fund to choose or how to invest — only whether they are on track to claim money the government has already allocated to them.
2 — PIR mismatch risk¶
The Prescribed Investor Rate (PIR) determines the tax rate applied to KiwiSaver investment income. The three rates are 10.5%, 17.5%, and 28%. Many NZ KiwiSaver members are on the wrong rate — a widespread, poorly understood problem that leads to incorrect tax withholding.
The income bands (under Income Tax Act 2007 s HL 21): | PIR | Taxable income (last 2 years, lower year) | |---|---| | 10.5% | ≤ $14,000 | | 17.5% | $14,001 – $48,000 | | 28% | > $48,000 |
What the bank surfaces:
"Your KiwiSaver tax rate (17.5%) may not match your income — your earnings suggest 28% may apply. Check with your provider."
The bank infers income from salary credits in the customer's transaction history. It does not file a PIR correction — it alerts the customer to check. The insight is framed as a risk flag, not a directive.
FMA boundary¶
Both indicators are observations about the customer's own data, not recommendations about investments, funds, or providers. They fall within the "class financial advice exemption" (general information) and do not require the bank to hold a Financial Advice Provider (FAP) licence for these specific outputs. Legal review of the exact display copy is required before release.