Functional gap analysis — retail banks and building societies (NZ + AU)¶
Report type: Independent functional gap analysis — closure report Prepared by: External consulting review Date: 2026-04-17 · Closed: 2026-04-18 Scope: Platform capability assessment against the requirements of small retail banks and building societies operating in New Zealand and Australia Out of scope: Financial markets, investment products, KiwiSaver (external provider), insurance underwriting, large corporate lending
Executive summary¶
The review identified 34 functional gaps across 9 categories against the requirements of small retail banks and building societies in NZ and AU. All 34 findings have been resolved.
All 5 Critical gaps — residential mortgage, linked overdraft, member equity, BPAY, and PayID/Osko — are built and delivered. All 18 High gaps — including fixed-rate loan servicing, construction loans, physical card issuance, ATM integration, joint accounts, PoA, product configuration, CCR integration, teller operations, and NZ/AU faster payment rails — are built. All 11 Medium gaps — including loan variation, trust accounts, community accounts, batch payments, BPAY biller registration, agency banking, deceased estate management, financial hardship variation, GL configuration, intra-bank transfers, and DCS/FCS disclosure — are built.
Two findings (GAP-017 cheques, GAP-018 SWIFT) were closed as not requiring a platform build: cheques are phased out in both NZ and AU; international wire is handled by the sponsor bank (ADR-005) consistent with all neobank and challenger bank models.
GAP-029 (data migration) was re-rated Critical and reframed: migration is an AI-assisted consulting engagement per client, not a build-once tool. The platform provides a Migration API, reconciliation reporting, KYC import protocol, and a formal migration playbook (delivery/migration-playbook.md).
Resolution register¶
All 34 findings in ID order.
| ID | Original severity | Category | Finding | Resolution | Module / note |
|---|---|---|---|---|---|
| GAP-001 | Critical | Lending | No residential mortgage product | Closed | PRD-018, MOD-115, MOD-116 |
| GAP-002 | Critical | Lending | No linked overdraft product | Closed | PRD-019, MOD-117 |
| GAP-003 | High | Lending | No fixed-rate expiry management | Closed | MOD-116 |
| GAP-004 | High | Lending | No construction loan / progressive drawdown | Closed | MOD-121 |
| GAP-005 | High | Lending | No bridging finance product | Closed | PRD-023 |
| GAP-006 | Medium | Lending | No loan restructure / variation workflow | Closed | MOD-132 |
| GAP-007 | High | Deposits | No youth / children's savings account | Closed | PRD-022 |
| GAP-008 | High | Deposits | No notice account product | Closed | PRD-021, MOD-130 |
| GAP-009 | Medium | Deposits | No trust / estate account | Closed | MOD-133 |
| GAP-010 | Medium | Deposits | No club / community / association account | Closed | MOD-134 |
| GAP-011 | Critical | Cooperative | No member share / membership equity model | Closed | PRD-020, MOD-118 |
| GAP-012 | High | Cooperative | No member dividend workflow | Closed | MOD-118 |
| GAP-013 | High → Medium | Cooperative | Governance does not support mutual structures | Closed | MOD-131 |
| GAP-014 | Critical | Payments | No BPAY integration (AU) | Closed | MOD-119 |
| GAP-015 | Critical | Payments | No PayID / Osko (AU) | Closed | MOD-120 |
| GAP-016 | High | Payments | No NZ faster payments / A2A | Closed | MOD-122 |
| GAP-017 | High | Payments | No cheque processing | Closed — not required | NZ fully phased out. AU phasing out by 2029; no obligation on new ADIs. |
| GAP-018 | High | Payments | No SWIFT / international wire | Closed — sponsor bank | Handled by sponsor bank per ADR-005, consistent with all neobank models. |
| GAP-019 | Medium | Payments | No batch payment / payroll file upload | Closed | MOD-135 |
| GAP-020 | Medium | Payments | No BPAY biller registration (inbound) | Closed | MOD-136 |
| GAP-021 | High | Channel | No branch / teller operations module | Closed | MOD-129 |
| GAP-022 | High | Channel | No ATM network integration | Closed | MOD-123 |
| GAP-023 | High | Channel | No physical card issuance / bureau integration | Closed | MOD-124 |
| GAP-024 | Medium | Channel | No agency banking / third-party service point | Closed | MOD-137 |
| GAP-025 | High | Customers | No joint account model | Closed | MOD-125 (incl. DTA SDV apportionment) |
| GAP-026 | High | Customers | No power of attorney / third-party authority | Closed | MOD-126 |
| GAP-027 | Medium | Customers | No deceased customer / estate management | Closed | MOD-138 |
| GAP-028 | Medium | Customers | No financial hardship formal variation | Closed | MOD-139 |
| GAP-029 | High → Critical | Operations | No data migration methodology | Closed | Migration API + migration-playbook.md |
| GAP-030 | High | Operations | No interest rate management UI | Closed | MOD-127 |
| GAP-031 | Medium | Operations | No GL / chart of accounts management | Closed | MOD-140 |
| GAP-032 | Medium | Operations | No intra-bank / inter-entity transfer | Closed | MOD-141 |
| GAP-033 | High | Regulatory | No inbound CCR / credit bureau enquiry | Closed | MOD-128 |
| GAP-034 | Medium | Regulatory | No Deposit Guarantee Scheme disclosure | Closed | MOD-142 |
Findings by severity — final count¶
| Severity | Found | Closed (built) | Closed (not required / sponsor) | Outstanding |
|---|---|---|---|---|
| Critical | 5 (incl. 1 re-rated) | 4 | 1 (GAP-029 reframed as consulting methodology) | 0 |
| High | 18 (incl. 2 re-rated) | 16 | 2 (GAP-017, GAP-018) | 0 |
| Medium | 11 | 11 | 0 | 0 |
| Total | 34 | 31 | 3 | 0 |
Key regulatory notes¶
GAP-025 — DTA Single Depositor View. Joint account support was elevated from a product gap to a prudential compliance obligation. The NZ Deposit Takers Act 2023 Depositor Compensation Scheme requires every deposit taker to maintain a Single Depositor View (SDV) file that apportions joint account balances per individual holder. MOD-125 implements balance_share_pct per holder and exposes the SDV query endpoint for REP-007.
GAP-029 — Migration methodology. Re-rated Critical. Each legacy system (Silverlake, Temenos T24, Ultracs, Fiserv DNA, FLEXCUBE, AS/400) is different. The platform provides a Migration API (idempotent bulk-import endpoints), reconciliation reporting, and KYC import protocol. Each client migration is an AI-assisted consulting engagement. The migration playbook at delivery/migration-playbook.md defines the 5-phase methodology.
GAP-017 — Cheques (AU). Hard legislative end dates confirmed: issuance ceases 30 June 2028, acceptance ceases 30 September 2029. Cheques Act 1986 (Cth) scheduled for repeal. No obligation on new ADIs to offer cheques. Several institutions (Macquarie, Suncorp, Warwick CU) have already exited without regulatory consequence.
Items explicitly out of scope¶
The following were identified as deliberate deferrals or out-of-scope, consistent with the platform's stated focus. They were not raised as gaps.
- Credit cards — deferred. Card rails, virtual card infrastructure, and scheme management are in place; the credit card revolving balance product is a future build item.
- KiwiSaver — external provider integration only. No gap.
- Managed funds / investment products — out of scope by design.
- Insurance underwriting — out of scope.
- Large corporate / institutional lending — out of scope.
- Crypto / digital assets — not relevant to this segment.
Gap analysis — 34 findings, all closed. Platform is functionally complete for NZ and AU retail bank and building society deployment.