It's not every year that a company faces a scandal which soaks up the news pages for not only days but weeks and months.
When the ANZ announced in mid-June that its long-standing former chief executive David Hisco was leaving following an investigation over expenses it could rightly have expected it to die down within a few days.
But after it emerged the bank had sold a luxury property to Hisco's wife for what seemed to be less than market value the questions just kept coming.
Yesterday acting ANZ New Zealand chief executive Antonia Watson described it as a "challenging" year for the bank reputationally.
Asked by the Herald what it was going to take for the bank to move on, Watson was frank.
"I think from here the most important thing is we are learning from them and own up to mistakes when we make them and move on."
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Watson said one of the key milestones in moving on will be the release of the Reserve Bank's section 95 review, which she expects to be made public in early December.
On June 24 the Reserve Bank requested the ANZ get two independent reports done to prove it is operating in a prudent manner.
Section 95 of the Reserve Bank of New Zealand Act 1989 gives the Reserve Bank the power to require a bank to provide a report by a Reserve Bank-approved, independent person.
These reviews can investigate such issues as risk management, corporate or financial matters, and operational systems.
The Reserve Bank said the first report would cover ANZ New Zealand's compliance with the its current and historic capital adequacy requirements.
In May the regulator revoked ANZ's accreditation to model its own operational risk capital requirement due to a "persistent failure" in its controls and attestation process.
ANZ is one of four big banks in New Zealand that are accredited by the Reserve Bank to use their own risk models – the internal models approach - in calculating their regulatory capital requirements.
It is now required to use the standardised approach for calculating appropriate operational risk capital.
But it is the second report which will potentially be far more telling. It will assess the effectiveness of ANZ New Zealand's director's Attestation and Assurance framework, focusing on internal governance, risk management and internal controls.
This appears to be where the Reserve Bank has the power to look more closely at what has been going on with the ANZ board and Hisco.
Yesterday, Watson said the attestation review was still ongoing.
"They are looking at our attestation process and regards to a number of these issues. It has been a very open process. We have been very happy to participate in it."
Not that the bank has really had any choice in the matter. But it will allow the ANZ to draw a line in the sand and move on.
Watson says it is looking forward to any recommendations that will come from it.
"... and we will be very happy to implement them."
Who will be ANZ's new CEO?
The other piece of the puzzle for the bank is naming a new chief executive.
It has said it will make an announcement by the end of the year on this and Watson confirmed it was still on track to do this.
ANZ Group's annual general meeting on December 17 could be a prime opportunity.
Watson said it was the board's call to make a decision on who would be the new chief but she has put her hand up for the job.
"I have applied and yes I am keen. I am very energised about coming to work to oversee two million customers and to look after their financial wellbeing and 8000 staff. I am absolutely keen."
Watson is well-liked within the bank and had the backing of ANZ New Zealand chairman Sir John Key when he announced Hisco's departure.
But counting against her is the fact that she was on the board of Arawata Assets, the ANZ subsidiary which sold Hisco's wife Deb Walsh the St Heliers property.
In amongst the section 95 review and the new chief executive announcement, the Reserve Bank is also expected to finalise its view on increased capital requirements for the whole banking sector.
The banking industry has pushed back strongly against the proposals, which are designed to strengthen the industry in the face of a potential financial crisis.
Reserve Bank governor Adrian Orr has promised to listen to feedback. Asked if she expected any softening of the proposals, Watson said she couldn't foreshadow the announcement.
"I think one thing we can be certain of is that banks will be required to hold more capital."
In preparation, ANZ New Zealand has only paid around 20 per cent of its earnings in the dividend to its parent this year rather than the usual 80 per cent. That still equated to $375 million.
"That is partly to meet some additional capital requirements we have during the year but partly just prudently setting ourselves up for the situation where we feel there will be more capital we need to hold."
Watson said more capital was the "almost guaranteed" outcome of the review.
"It's just a matter of how much and what it looks like."