Capital Disclosure & Reporting Policy¶


Code	`CLQ-006`
Domain	Capital & Liquidity
Owner	Chief Financial Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD03
Review date	2027-03-25

Regulations: APS 330 Public Disclosure · DTA Disclosure Standard ¶

Purpose¶

Govern public Pillar 3 disclosure of capital adequacy, risk exposures, and remuneration under APRA APS 330 (AU) and RBNZ DTA Disclosure Standard (NZ). Ensures all public capital disclosures are accurate, consistent with the corresponding prudential returns, and published on the required schedule.

Scope¶

All Pillar 3 disclosures including capital composition, risk-weighted asset disclosures, liquidity disclosures, leverage ratio, remuneration disclosures, and the Basel III Quantitative Disclosure Templates (QDTs). Covers both NZ (RBNZ Disclosure Statement requirements) and AU (APRA APS 330) obligations.

Policy statements¶

The platform SHALL publish Pillar 3 disclosures on the schedule required by APRA APS 330 and the RBNZ Disclosure Standard: at minimum quarterly for material capital and liquidity disclosures, and annually for the full Pillar 3 disclosure package.

All Pillar 3 disclosure figures SHALL be sourced from the same governed risk engines that produce the prudential returns (MOD-033 for RWA and capital ratios; MOD-036 for return figures). No Pillar 3 figure SHALL diverge from the corresponding prudential return figure without a documented reconciling explanation.

A cross-reconciliation SHALL be performed between all Pillar 3 disclosures and the corresponding prudential returns before publication. Any unreconciled difference SHALL be investigated and resolved before publication proceeds.

Pillar 3 disclosures SHALL be reviewed and signed off by the CFO and CRO before publication. Sign-off SHALL confirm that all figures are accurate, cross-reconciled to the prudential returns, and consistent with the most recent ICAAP assessment.

Pillar 3 disclosures SHALL be published on the platform's public website and lodged with APRA and RBNZ as required by the applicable instruments.

Changes to Pillar 3 disclosure requirements arising from regulatory updates SHALL be implemented under the regulatory change management process (REP-006) before the first affected disclosure period.

The platform SHALL not make material changes to the presentation or methodology of Pillar 3 disclosures without documenting the reason for the change and disclosing the change and its quantitative impact in the affected disclosure.

All Pillar 3 disclosure documents, supporting data packs, reconciliation records, and sign-off records SHALL be retained for 7 years.

Satisfying modules¶

Module	Name	Mode	Description
MOD-001	Double-entry posting engine	`AUTO`	Every capital position is derived from posted ledger entries — no manual override path exists
MOD-033	RWA & capital ratio engine	`CALC`	Pillar 3 disclosure figures sourced from the same engine — no reconciliation gap

Part of Capital & Liquidity · Governance overview Compiled 2026-05-22 from source/entities/policies/CLQ-006.yaml