Regulatory Reporting Policy¶


Code	`REP-001`
Domain	Regulatory Reporting
Owner	Chief Financial Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD10
Review date	2027-03-25

Regulations: RBNZ Prudential Returns · DTA Capital Standard · DTA Liquidity Standard · DTA DCS Standard · DTA Disclosure Standard · APRA Reporting Standards · Corporations Act 2001 ¶

Purpose¶

Govern the platform's regulatory reporting obligations register, define reporting ownership and accountability, establish submission tracking and sign-off controls, and define the escalation process for reporting breaches or near-misses.

Scope¶

All regulatory reporting obligations across NZ and AU, including prudential returns, AML/CFT reporting, depositor compensation scheme reporting, disclosure artefacts, statistical returns, and ad-hoc regulatory requests.

Policy statements¶

The platform SHALL maintain a current and complete register of all regulatory reporting obligations. Each obligation SHALL record: regulatory instrument, reporting frequency, regulator, data sources, submission deadline, accountable owner, validation controls, and sign-off authority.

All regulatory reports SHALL be sourced from governed system data pipelines and calculation logic that is traceable to authoritative ledger, customer, or model outputs. Manual data assembly outside governed pipelines is prohibited.

Every regulatory submission SHALL include: full data lineage, preparation timestamp, accountable owner, validation results, sign-off evidence, and submission reference and regulator acknowledgement where applicable.

The reporting engine SHALL maintain a submission log for every regulatory return. The log SHALL record: submission timestamp, submitting system or individual, submission reference, validation outcomes, and confirmation of receipt from the regulator where applicable.

All regulatory submissions SHALL pass data quality and reconciliation gates prior to submission. Submissions failing validation SHALL be blocked and SHALL NOT proceed.

Every regulatory return SHALL have a designated owner responsible for completeness, accuracy, and timeliness. A sign-off authority SHALL be assigned for all material returns. Prudential returns SHALL require CFO sign-off. AML/CFT returns SHALL require CCO sign-off.

Regulatory changes SHALL be incorporated into reporting inventories, obligation mappings, report specifications, and traceability matrix entries prior to the first affected reporting period.

Any regulatory reporting breach — including late submission, incomplete data, or material error — SHALL be reported to the Chief Compliance Officer within one business day of identification.

Near-misses — submissions at risk of breach but submitted on time — SHALL be recorded and analysed. Repeated near-misses SHALL trigger formal remediation actions and control improvements.

Satisfying modules¶

Module	Name	Mode	Description
MOD-008	Dormancy & escheatment engine	`AUTO`	Unclaimed money return filed with IRD (NZ) / ASIC (AU) automatically on schedule
MOD-036	Prudential return builder (RBNZ / APRA)	`AUTO`	Regulatory returns produced automatically on schedule — no manual data assembly
MOD-053	Case & complaint management module	`LOG`	Complaint register maintained automatically — feeds regulatory complaints report
MOD-080	Statutory financial reporting & ERP integration	`AUTO`	Regulatory reporting feeds drawn from the same Snowflake data as internal management accounts — single source of truth for all statutory obligations.
MOD-086	Funds transfer pricing engine	`CALC`	NIM attribution by business line is produced daily from TP-adjusted loan and deposit balances — management accounts reflect the true cost and benefit of funds for each product segment.
MOD-097	Usage event collector	`LOG`	All billable usage events are logged with tenant, module, resource type, and timestamp — provides the immutable audit trail for SaaS billing and internal cost accounting.
MOD-098	Cost attribution engine	`CALC`	Produces daily attributed cost and running billing period totals per licensee — the authoritative source for SaaS invoices and internal gross margin reporting.
MOD-099	Infrastructure cost reports	`LOG`	Infrastructure cost history is retained as queryable Snowflake records — provides audit trail for AWS and Snowflake spend by service, period, and attributed tenant.
MOD-143	Open Bank Resolution pre-positioning	`LOG`	OBR resolution-state activation and partition events are logged as regulatory records for RBNZ examination.
MOD-146	Restricted activities enforcement	`LOG`	All restricted activity classification decisions, consent records, and product enablement events are logged as regulatory records.
MOD-170	Regulatory Submissions Portal	`AUTO`	The unified submission calendar aggregates all return statuses across MOD-036, MOD-037, MOD-057, and MOD-060, updated within 1 hour of any status change, satisfying the automated regulatory reporting visibility requirement.

Part of Regulatory Reporting · Governance overview Compiled 2026-05-22 from source/entities/policies/REP-001.yaml