NZ: Deposit Takers (OBR Pre-positioning) Standard¶


Regulator	RBNZ
Jurisdiction	NZ
Status	Draft — not yet in force
Applicability	Platform

The DTA Open Bank Resolution (OBR) Pre-positioning Standard is a non-core standard under the Deposit Takers Act 2023, replacing BS17. OBR allows a failed bank to reopen for business within one business day by applying a partial freeze to eligible depositor and creditor liabilities — the frozen portion absorbs losses, while the unfrozen portion remains immediately accessible to depositors.

The standard applies where RBNZ has included OBR as a resolution tool in the deposit taker's resolution plan. For Totara Bank, OBR pre-positioning is part of the RBNZ resolution framework. The platform must be capable of: applying a configurable haircut (frozen/unfrozen split) to all eligible account balances atomically; displaying the unfrozen available balance to the customer; and logging all OBR activation events for RBNZ examination.

The OBR Standard requires the Single Depositor View (SDV) maintained under the DCS Standard — the same MOD-125 and MOD-142 infrastructure serves both. An exposure draft is expected around mid-2026. The standard takes effect 1 December 2028.

Compliance register¶

This register maps every material obligation under the Standard to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — RBNZ activation decision, board governance, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

OBR partition mechanism¶

Ref	Obligation	Scope	Policy	Platform controls	Build
OBR-1	Maintain IT systems capable of applying a partial freeze to customer liability accounts within one business day of RBNZ activation	🤖 Automated	OPS-001	MOD-143 (AUTO) — resolution-state activation triggers immediate operational controls; channel mode switches and account partition flags applied atomically across all eligible accounts via the OBR pre-positioning module	🔨
OBR-2	Calculate and apply the haircut (frozen portion) to each eligible account correctly	🤖 Automated	OPS-001	MOD-143 (CALC) — per-account frozen/available balance split computed from the configured haircut percentage; MOD-125 (CALC) — joint account holder proportional balance shares feed the OBR partition calculation for joint accounts	🔨
OBR-3	Ensure unfrozen (available) balance is displayed to customers and accessible immediately after OBR activation	🤖 Automated	OPS-001	MOD-143 (AUTO) — available balance field is updated atomically on partition activation; customer-facing balance display reads the available balance field, not the total balance	🔨
OBR-4	Log all OBR activation events and partition changes as immutable regulatory records	📊 Evidenced	REP-001	MOD-143 (LOG) — OBR resolution-state activation and partition events are logged as regulatory records for RBNZ examination; records cannot be altered or deleted	🔨

Single Depositor View (SDV) — OBR readiness¶

Ref	Obligation	Scope	Policy	Platform controls	Build
OBR-5	Maintain SDV consistent with DCS Standard requirements (supports both OBR and DCS execution)	🤖 Automated	REP-007	MOD-142 (CALC) — per-customer total covered deposit balance calculated in real time; MOD-125 (CALC) — joint account proportional balances available for SDV; see nz-dta-dcs for full SDV register	🔨

OBR readiness testing and disclosure¶

Ref	Obligation	Scope	Policy	Platform controls	Build
OBR-6	Conduct periodic OBR readiness tests on a schedule agreed with RBNZ	🏛 Institutional	OPS-001	Annual OBR readiness testing is scheduled and owned by the Chief Technology Officer in conjunction with the Chief Risk Officer. MOD-143 activation test mode supports controlled non-production simulation.	—
OBR-7	Notify RBNZ of any material change that could affect OBR readiness	🏛 Institutional	OPS-001	Institutional change governance obligation. MOD-150 technology risk register auto-classifies material infrastructure changes; RBNZ notification is a Chief Technology Officer / Chief Risk Officer process.	—
OBR-8	Disclose OBR status to depositors on activation	🤖 Automated	OPS-001	MOD-143 (AUTO) — customer notification of OBR resolution-state activation dispatched via MOD-063 notification orchestration on activation trigger	🔨

Institutional obligations (not platform scope)¶

Obligation	Owner	Platform evidence input
RBNZ resolution plan preparation and OBR inclusion decision	RBNZ (external)	Platform OBR-readiness is evidenced by MOD-143 activation capability; RBNZ makes the resolution plan decision
OBR Implementation Plan design and RBNZ approval	Chief Risk Officer / Chief Technology Officer	MOD-143 implements the technical execution layer; plan authorship and RBNZ approval are institutional
Annual OBR readiness testing (non-production activation simulation)	Chief Technology Officer	MOD-143 provides test mode capability; test scheduling and outcome reporting are institutional
Ensuring outsourcing arrangements do not impede OBR execution	Chief Operating Officer	MOD-150 third-party health monitoring provides vendor SLA visibility; OBR contractual obligation review is institutional (see nz-dta-outsourcing)

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊	Institutional 🏛	N/A
OBR partition mechanism	4	3	1	0	0
Single Depositor View	1	1	0	0	0
Readiness testing and disclosure	3	1	0	2	0
Total	8	5 (63%)	1 (13%)	2 (25%)	0 (0%)

All attributed modules are currently build_status: Not started — the compliance position will update as modules are built and deployed. Controls are designed against the anticipated standard; the exposure draft is expected mid-2026.

Policy	Title
OPS-001	Business Continuity Policy
REP-001	Regulatory Reporting Policy
REP-007	DCS & Depositor Reporting Policy

See nz-dta-dcs for the DCS/SDV register which shares the same platform infrastructure as OBR pre-positioning.

Official documentation¶

Policies referencing this standard¶

(None yet)

Compiled 2026-05-22 from source/entities/regulations/nz-dta-obr.yaml