NZ Group 3¶
| Tier ID | NZ-G3 |
| Jurisdiction | NZ |
| Status | Current |
| Asset threshold | < NZD 2 billion |
| Capital methodology | Standardised |
| Liquidity framework | CFCR |
| OBR applicable | No |
| Disclosure tier | Dashboard |
| D-SIB eligible | No |
Notes
The entire former NBDT (Non-Bank Deposit Taker) sector now licensed under the DTA. Includes all credit unions, building societies, and smaller finance companies with assets below NZD 2 billion. Uses the simplified Cash Flow Coverage Ratio (CFCR) for liquidity — no LCR or NSFR required. Minimum absolute capital floor of NZD 5 million. Exempt from OBR pre-positioning, LVR/DTI lending standard, and the full IRRBB non-core standard. Disclosure is via quarterly Dashboard publications only — no full prudential disclosure statement and no mandatory audit requirement. The first likely target customer segment for this SaaS platform.
Profile¶
Group 3 is the base tier under the RBNZ Proportionality Framework, capturing all NZ deposit takers with total assets below NZD 2 billion. This tier absorbs the entire former NBDT (Non-Bank Deposit Taker) sector — hundreds of credit unions, building societies, and smaller finance companies previously regulated under the Non-bank Deposit Takers Act 2013. Under the DTA these entities are now licensed deposit takers subject to a proportionate subset of the full prudential framework.
This is the primary initial target customer segment for this SaaS platform.
Capital¶
Standardised approach. Minimum ratios: CET1 4.5%, Tier 1 7.0%, Total Capital 9.0% — same ratio floors as Groups 1 and 2 — but with a lower Prudential Capital Buffer (PCB) reflecting the reduced systemic risk profile. An absolute minimum of NZD 5 million capital applies regardless of ratio calculations. No LAC requirement. No AT1 (removed from NZ framework).
Liquidity¶
Group 3 uses the Cash Flow Coverage Ratio (CFCR) — a simplified, cash-flow-based measure — instead of LCR/NSFR. The CFCR requires deposit takers to hold sufficient liquid assets to cover net cash outflows over a specified horizon. Run-off rates are simplified: DCS-protected deposits (covered by the Deposit Compensation Scheme) attract a 3% run-off rate; uninsured deposits attract a single 50% run-off rate. This is materially simpler than the full LCR outflow rate schedule.
Implication for the platform: The liquidity module (MOD-032) computes LCR/NSFR for Groups 1 and 2. Group 3 clients need a CFCR calculation — this is a distinct calculation mode or a separate module. A gap exists in the current module set; a CFCR calculation capability should be planned.
Resolution¶
OBR pre-positioning does not apply to Group 3. MOD-143 (OBR pre-positioning) is not deployed for Group 3 clients.
Disclosure¶
Group 3 entities publish quarterly Dashboard statements only. There is no requirement for a full board-approved prudential disclosure statement and no mandatory audit requirement for the disclosure. The Dashboard is a lighter standardised template covering key prudential metrics.
Non-core standards¶
Group 3 entities are subject to a reduced set of non-core standards designated by RBNZ. Currently confirmed: Governance (proportionate committee structure), Risk Management (principles-based, exempt from comprehensive scenario analysis), and Cyber Resilience. IRRBB, Outsourcing, OBR, Operational Resilience, and Lending are not applicable.
Lending standard¶
Group 3 is exempt from the LVR/DTI lending restriction standard. This reflects the non-systemic nature of Group 3 entities and the limited macroprudential risk they pose.
Platform relevance¶
A Group 3 deployment is the most common configuration for the platform's initial customers. Key differences from Groups 1/2:
- CFCR liquidity calculation instead of LCR/NSFR/MFCR (module gap to address)
- No OBR module (MOD-143 not deployed)
- No IRRBB full standard (CLQ-007 not applicable)
- No LVR/DTI lending standard enforcement
- Dashboard disclosure output, not full Pillar 3
- Simplified ICAAP scope (no full scenario analysis requirement)
- Simplified governance module configuration
Applicable non-core standards¶
- Governance
- Risk Management
- Cyber Resilience
Tier-specific regulations¶
No regulations are tagged as exclusive to this tier. All regulations applicable to this jurisdiction apply under their default scope.
Tier-specific policies¶
Policies that apply exclusively to this tier (not all tiers in the jurisdiction):
| Code | Title | Status |
|---|---|---|
| CLQ-004 | Interest Rate Risk in the Banking Book (IRRBB) Policy | Draft |
Compiled 2026-05-22 from source/entities/entity-tiers/NZ-G3.yaml