Via email:
Dear Harry Smith,
You recently requested, under the Official Information Act (the OIA):
1. All internal communications, reports, recommendations and draft documents,
relating to the findings of the IMF Financial Sector Assessment Program (FSAP)
reports, including technical notes on Contingency Planning and Crisis Management
Framework, released in May 2017, and all communications with the IMF and
Ministers of the Crown in respect thereof.
2. All research, communications and recommendations in respect of Crown retail
deposit guarantees/insurance and wholesale bank guarantees since 1 January 2010.
3. All assessments, papers, advice (including internal and external legal advice),
drafts in respect of Open Bank Resolution (OBR), including required/proposed
amendments to the Reserve Bank of New Zealand Act 1989, and fulfilment of any
actions/recommendations determined by cabinet. This should include all working
papers in respect of the Regulatory Impact Assessments (RIA) for OBR and any
reassessment of that RIA as part of the revision of Financial Stability Department
document BS11 (Outsourcing Policy).
4. All information, reports, policies in respect of crisis management planning relating
to the failure of a large New Zealand bank, including scenario and strawman
assumptions.
5. Paper to Minister of Finance on additional funding required to implement FSAP
recommendations.
6. Paper to Minister of Finance seeking Cabinet approval to consult on OBR de
minimis model.
Before collecting information for a response to your request, you should be aware of the
Reserve Bank’s charging policy for the release of official information.
You can find more information here:
https://www.rbnz.govt.nz/research-and-
publications/official-information-requests#Charges
The Bank strongly advises that you refine the scope of your request. By doing so, you
reduce the potential of having your request declined under section 18(f) of the OIA as; the
information requested cannot be made without substantial collation or research.
Provisional searches for your request reveal:
For section 1 – 12 potential documents
The Reserve Bank has also already released some information publicly on this specific
matter. You can find the information at the below link.
Ref #7356991 v1.3
2
https://www.rbnz.govt.nz/regulation-and-supervision/financial-sector-assessment-
programme
For section 2 – 200+ potential documents
For section 3 – 450+ potential documents
The Reserve Bank has already released some information publicly on this specific section.
You can find the information at the below links.
https://www.rbnz.govt.nz/research-and-publications/official-information-requests/oia-obr
https://www.rbnz.govt.nz/regulation-and-supervision/banks/consultations-and-policy-
initiatives/completed-policy-development/review-of-the-outsourcing-policy-for-registered-
banks
Should you accept the information already published, the Bank will decline this part of your
request under section 18(d) as the information is or will soon be publicly available.
For section 4 – 500+ potential documents
As for sections 5 and 6, there is not enough detail for us to identify the documents within our
systems. Unless you have any other specifications, as in where the paper has been
referenced, details of the author, dates or paper reference numbers, it is likely these sections
of your request will be declined under section 18(e) as the document alleged to contain the
information requested does not exist or cannot be found.
Given the amount of potential documents that have been found in a provisional search, the
Bank has provided you with some options to mitigate the likelihood that your request is
declined.
Options available to you
You have the following options:
1. Refine the scope of your request so that resources required to respond to the request
are reduced - for example, by requesting information from a specific time period in
the same way you have requested information specifically from May 2017 in section
1.
You might also consider refining your request by asking specifically for single
documentation in either memo, ministerial advice, or email chain form rather than the
currently broad request which includes, “
All internal communications, reports,
recommendations and draft documents” and
“Al research, communications and
recommendations” and
“Al information, reports, policies.”
2. Partially accept some of the publicly available information the Bank has already
published to satisfy some of sections 1 and 3 of your request. The Bank will continue
to collate information to meet the other areas of your request, where possible.
If you accept either of the above options, this will reduce the possibility your request is
declined under section 18(f) of the Act, where the information collected cannot be made
available without substantial collation or research.
2 The Terrace, PO Box 2498, Wellington 6140, New Zealand
Telephone 64 9 366 2643 Online at
www.rbnz.govt.nz
3
To reiterate, any information that the Bank does release may be subject to our charging
policy. As such, information may only be released to you upon receipt of payment for the
information.
You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at
www.ombudsman.parliament.nz
or freephone 0800 802 602.
If you wish to discuss this decision with us, please feel free to contact me. I will be able to
assist you should you wish to change or refine your request in order to reduce or remove the
need to charge.
Regards,
Ngarangi Haerewa
Communications Adviser
2 The Terrace, PO Box 2498, Wellington 6140, New Zealand
Telephone 64 9 366 2643 Online at
www.rbnz.govt.nz
