The regulation driving the project is formally known as Banking Standard 11, or as we call it, BS11. When finished, it will enable ANZ — the country’s biggest bank — to operationally separate from all the technology systems and operational services it currently receives from the global ANZ group and be able to run the New Zealand bank independently.
Literally everything is at stake — compliance is a condition of our registration to operate as a bank in New Zealand. No pressure then.
The project has its origins a decade ago when the banking world was hit by the worst financial crisis since the Great Depression of the 1920s.
The collapse of the subprime mortgage market in the US developed into a full-blown international banking crisis. Governments had to step in across Europe and the US to prevent the collapse of the world financial system.
Down in Australia and New Zealand, things felt a little different. Our banks had largely avoided the risky lending that had caused so much mayhem in the Northern Hemisphere.
There were no registered bank collapses, and a government bail-out was limited to other finance companies. While the Global Financial Crisis (GFC) swept past and the global economic downturn took hold in its wake, in Australia and New Zealand it seemed like we got off lightly.
In the years that followed, regulators around the world vowed “never again”, and redrafted the rulebooks to ensure — as much as possible — that there would be no GFC II.
Despite the Southern Hemisphere banks generally being held as comparative case-studies in old-style financial responsibility, there was also work to be done.
In New Zealand, the Reserve Bank was concerned about overseas-owned banks' reliance on technology systems and operational services from their overseas parent banks, and what it would mean for the New Zealand banking system if those systems and services were suddenly not available.
Around 90 per cent of New Zealand’s banking is operated through overseas-owned banks.
In 2014, the Reserve Bank reviewed its BS11 policy. It significantly tightened the requirements for the bigger New Zealand banks to be able to achieve operational separation from group technology systems and support services.
The updated policy requires foreign-owned banks with $10b of liabilities or more to be able to separate from its global technology systems and services, and be able to operate independently by 9am the next business day in the event of a crisis.
For some very critical systems and services, the separation must be fully complete within six hours.
In 2017, banks were given a deadline of September 2022 to comply.
At ANZ, the NZ Board has brought this deadline forward to September 2021 to ensure compliance is completed and working well prior to the regulatory deadline.
This presents a monumental challenge for ANZ’s technology and operational teams.
In just five years, ANZ had to design and implement its own version of the relevant technology systems and services support we currently rely on from other ANZ group entities throughout the Asia-Pacific region.
It dwarfs our previous largest technology project; the merger of the ANZ and National Bank IT systems in 2012.
That was, at the time, the largest IT project in New Zealand’s history by a long way, costing $221 million and involving 290 people from New Zealand, Australia, Bengaluru, and Manila in the Philippines
ANZ’s BS11 project involves approximately 330 people, located in New Zealand, Australia, Singapore, Bengaluru and Chengdu.
Fifty-one per cent of the technology work is being done at ANZ’s locations in Wellington and Auckland, with 45 per cent done in Melbourne, 4 per cent in Singapore and 1 per cent in India.
The project will cost around $350m — most of which will be spent between now and completion.
Work on the transition to compliance with BS11 began on 1 October 2017. In scoping the project we identified 49 solutions that had to be developed, tested and working by September 2022.
Some are permanent changes and improvements to the way we do things, and others are back-ups which will only be required in the event ANZ NZ has to stand alone and operate separately from ANZ Group.
Along with new capital requirements and tougher regulatory oversight generally, BS11 will further reinforce New Zealand’s banks as being among the safest in the world.
In the event of a catastrophic economic or natural disaster that engulfs our support networks overseas, New Zealand’s biggest foreign-owned banks will be able to open their doors and continue to provide banking services to our customers.
●Mike Bullock is Chief Operating Officer of ANZ NZ
