Have you considered NZ fin reg?

Not to cause any concern or put a dampener on things but have you considered whether you’re in breach of the Banking (Prudential Supervision) Act 1989 for using the word bank in your name and carrying on activities in NZ? And when it comes down to launching in 2023, will you be prepared to comply with your AML/CFT Act and CCCFA obligations (of which there are many)? There’s also the COFI Act which comes into force in 2025, and various other pieces of financial regulation to operate as a bank in NZ (eg under the FSPA and FMCA) which are extremely onerous. I hope you are successful but just wanting to flag this now, given your ads suggest a 2023 launch.

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From what I’ve seen, when they use the word bank it often has an asterisks (*) then at the bottom of their website you’ll find this disclaimer, “ *Please note, Debut is not (yet) a registered bank under the Banking (Prudential Supervision) Act. This is about our future intentions. Investments with us are not supervised currently by the Reserve Bank of New Zealand.

Debut Limited
New Zealand Business Number: 9429049307894
Registered Financial Services Provider: FSP1002438”

So it seems they are a Registered Financial Services provider and are working on the registered bank part.

I would expect them to become registered banks and comply with the above law before they launch.

Thanks. We have actually done a fair bit of homework before setting out on this. :grinning: We’re continually working with some pretty clever folks, including our legal team, advisors and regulators to develop safe and compliant financial products for Kiwis.