Ex-RBNZ director Suzanne Snively, now chairing the RBNZ Act review advisory panel, explains to Gareth Vaughan where she feels the 1989 RBNZ Act went wrong and why she's keen for a broader approach today

Ex-RBNZ director Suzanne Snively, now chairing the RBNZ Act review advisory panel, explains to Gareth Vaughan where she feels the 1989 RBNZ Act went wrong and why she's keen for a broader approach today
Picture: RBNZ.

By Gareth Vaughan

Suzanne Snively says she feels as if she has been carrying a burden for 30 years.

And now she's chairing the Independent Expert Advisory Panel appointed by Finance Minister Grant Robertson to assist with the review of the Reserve Bank of New Zealand (RBNZ) Act, Snively appears to be revealing in the opportunity to address unfinished business.

Snively was a RBNZ director between 1985 and 1992 when the ground breaking RBNZ Act was born. But, as she told interest.co.nz, the RBNZ Act didn't go as far as she would've liked.

Snively recalls visiting the Bank of England (BoE) in London during her tenure as an RBNZ director when the RBNZ Act was being developed. She says the BoE hierarchy was impressed with the idea of central bank autonomy and independence, which the RBNZ Act established. But they raised concerns about the level of faith the New Zealand architects were placing in the market and competition.

"They said to me 'we're quite concerned about your focus on letting the market decide and using competition to decide the distribution of resources in the banking and finance system. We think it's really important that you widen the perimeter to include finance companies as well as banks.' And everything that I'd studied in economics myself said that was a good set of advice. And so I came back and attempted to have that considered as part of our own act," Snively recalls, saying she wanted finance companies to be brought within the RBNZ Act.

According to Snively, the response she got once back from London was that finance companies - an important source of capital for property developers - would be okay because they were using their own money. This, she was told, meant they would be very responsive to market conditions and didn't need RBNZ oversight. However Snively didn't agree. 

"The writing was on the wall in 1987 when the Act was being drafted that if you left things outside the perimeter it could be quite risky if you went into recession," says Snively (pictured).

Even with the best will in the world issuing debentures to the public or building faster when people aren't buying buildings is going to be tough during a recession, she says.

"On the other hand if you've actually been talking about balancing your assets and liabilities historically over a long period of time because it's part of the oversight of your regulator, then when a crisis is coming you're going to have a lot more warning before the crisis comes to start to think about the things that you might be doing to keep your books balanced," Snively says

This, she suggests, might've mitigated the problems so many finance companies got into around the time of the Global Financial Crisis, bringing Snively's fears to life.

"Quite frankly because of everything else being safe in New Zealand at that point in time, if it hadn't been for the finance companies the impact of the GFC would've been far less in New Zealand because our economy was strong in a number of good ways in the early part of the new millennium."

As detailed in interest.co.nz's Deep Freeze List, dozens of finance companies hit the wall between 2006 and 2010. A 2011 report by Parliament's Commerce Select Committee estimated between 150,000 and 200,000 deposit holders were affected, with losses estimated at more than $3 billion. The Select Committee received independent specialist advice from Anthony Molloy QC, who told them: "Meaningful consideration of investor protection legislation is impossible without first identifying the culture of the New Zealand market that has treated investors as prey, rather than as fellow citizens engaged in an enterprise from which all might profit to the benefit of the nation as a whole."

The RBNZ became the prudential regulator of surviving non-bank deposit takers (NBDTs) including finance companies, building societies and credit unions that borrow money from the public through the 2008 Reserve Bank Amendment Act. This went further through the 2013 NBDT Act including licensing powers.

From one extreme to another

More broadly Snively says the paradox of the late 1980s was that New Zealand had emerged from a controlled economy and controlled economic management under the Muldoon government, into a "new horizon" where it was possible to think about other economic ideas.

"And yet what that was replaced by was the concept that there's no alternative," she says.

"And the interesting thing about that was that it meant that you wanted to believe and work on the economic mechanism as though there was a free market and that competition would work to get the best outcomes. So we went from one form of central power and control to another form, which was meant to be free yet the structures around it were in many cases set in a way that were almost as constraining of thinking as we'd had previously."

Structures in the 1989 RBNZ Act Snively cites as examples of this include having the Governor as the single decision maker, and both head of the RBNZ and chairman of its board.

"And initially when the first draft of the Act was prepared there was no prudential supervision because the concept was that the market would prevail."

"The irony is the banks came and said they had to have, as a minimum, the Basel requirements [regulations] or they wouldn't be able to do business internationally. So that resulted in the definition of a trading bank, now called registered bank, and so the supervision perimeter at that point was set for any organisation in New Zealand which called itself a bank. And in order to be called a bank you needed to go to the Reserve Bank and meet their requirements," Snively says.

The importance of public trust

A key development in part two of the RBNZ Act review has been the Government's decision to introduce a deposit protection, or insurance, regime. Previously the RBNZ has been opposed to such a regime arguing it would increase moral hazard and make banks more susceptible to failure.

Snively says whilst the concept of moral hazard remains an important consideration, other factors must also be taken into account. These include social licence and public trust.

"You can have extremely well organised professional structures yet if the public doesn't understand them and doesn't trust them, when things turn and economies do have their economic cycles, the public can respond in ways that are extremely undermining of those structures. So as we've seen with banks worldwide now they don't have the public trust they once had. So I think public trust needs to be very much in there along with social licence as priorities that we concern ourselves about."

"One of the attributes of deposit protection is rightly or wrongly it builds public trust in the system. People will put their money in banks knowing that that money is going to be protected by insurance. That's something we've got to take into account when thinking about our policies going forward," says Snively.

"One of the other interesting things about deposit insurance is the number of New Zealanders who have told me that they've kept their money deliberately offshore because they have deposit insurance offshore who told me they would bring it onshore once New Zealand had deposit insurance in place." 

More people thinking about the RBNZ and its role a desired outcome

Ultimately through phase two of the RBNZ Act review Snively says she wants it to help foster a larger group of people in New Zealand who think about the central bank.

"Basically right now whenever I go and meet with my friends they all joke with me about my seriousness over the central bank. Basically the joke being; 'Suzanne we're sorry but most of us don't think about the central bank on a daily basis.' And I understand that. But the reality is that the central bank actually does have an impact on everyone's life."

"And so if New Zealanders themselves feel that they haven't got time to think about it, then they do need to think now about the consultation process to be sure that we've got a structure in place which is enabling people to think going forward, and to ask questions going forward," Snively says. 

"And that's why where I stand the structure of moving away from a single decision maker to a committee decision maker for monetary policy, of moving to a new board, where the role of the Governor is separate from the role of the Chair, from my perspective and my experience, that's very positive change. Because you're bringing a whole lot of thinkers into the picture now to be looking at things from different perspectives."

Snively's also an independent economic strategist, professional director and risk management advisor. She chairs Transparency International New Zealand, and is a former PwC partner.

A 30 year refresh

Robertson says the RBNZ Act is being reviewed because it has been in place for 30 years, during which time the scope, focus and intensity of regulation and supervision has evolved. Additionally changes to the RBNZ’s statutory framework have happened through a series of separate, targeted amendments rather than through a comprehensive work programme.

“Now is the right time to do that work to ensure we have a fit for purpose financial stability and regulatory framework for the coming decades," Robertson says.

See all our stories on phase two of the RBNZ Act review here.
And there's more detail on the RBNZ Act review on Treasury's website here. 

Phase one of the RBNZ Act Review focused on monetary policy.

*This article was first published in our email for paying subscribers early on Thursday morning. See here for more details and how to subscribe.

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19 Comments

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What on earth does that have to do with the article? Did you even read the article, or are you one of the many in finance who try to point out flaws in others, parroting opinions that are not your own.

Why don’t we turn the spotlight on you, as you do to many others. Respect for others in the market puts you in good standing to be listened to in a serious manner.

Right now you are just noise.

There is a desperate desire to appear intelligent and in control in a market with some people. It’s ok to say “I don’t know”, rather than “here’s what someone else has said” without understanding it through and through.

I wasn't going to reply, but I will. My thoughts exactly JLM as the post and links are unrelated, and contribute nothing, to the article. Any idiot can post links to random garbage, so how about actually critiquing the article if that isn't beyond you?

Yea. I saw your comment re: linkers and what they imply, was well explained.

I’ve made some mistakes he has in my past hence I don’t mind dishing the dirt. It helped me to grow and still does

A lot of readers like the comments that have links though. I used to call it out but seemed to be outnumbered.

Note, we do encourage readers/commenters to stick to comments related to the article they are commenting on. If you wish to post other comments, 90@9 and what happened today are the forums for broader comments and discussion. Cheers.

Given, the RBNZ governor has indicated negative interest rates are a prospect, the implications are a real concern to any legislative process involving the RBNZ.

Once again, can you find fault with the implication that any purchase price for sovereign debt with a positive coupon (inflation indexed or not) that derives a calculated negative yield implies the security, over the investment horizon, will return less than the purchase price? Hence, the buyer must expect to recover this calculated up front loss through an increase in the buying power of the future cash flows, as encapsulated in this observation:

Why buy German 10-years at -60 bps? Well, core inflation in Germany typically falls 330 bps in a recession. The current core is 1.2%. So that means deflation lies ahead and as such generates a de facto expected “real” yield of +1.5%. That’s why. Link

Policy setting isn’t included in any legislative process, that is the whole point of the RBNZ act so as to ensure independence. What you’re saying is that the governor better be careful to go for negative rates else risk a change to legislation to effect that.

What’s included in the 1989 act is the ability for a PTA to be set and rejected, and for the ability for the finance minister to direct the RBNZ on behalf of the crown to engage, fix or halt FX transactions, but again it is bound by the PTA. That’s really about where it stops.

Falling bond yields do not imply deflation. They are symptomatic of excess liquidity in the system. No liquidity = high rates overall = deflationary environment ahead

You imply that low interest rates cause deflation, and high interest rates cause inflation. That is a view shared by Turkey’s Erdogan, see how his monetary policy ideas are working out for him.

You seem to be missing the point entirely about interest rates. It’s not that deflation is ahead, it’s that the ocr doesn’t effect bank lending as well anymore due to a lack of aggregate demand for credit, due to demography. They will switch the way the set monetary policy as the OCR is becoming irrelevant. For all the weight you put on negative interest rates and what they mean, you’ve missed the point that they don’t work in the sense they don’t spur bank lending. You could put it to -3% and it wouldn’t do any more than what 1% would.

Policy setting isn’t included in any legislative process, that is the whole point of the RBNZ act so as to ensure independence

Independence for the central bank really means accountability, or lack thereof.

Falling bond yields do not imply deflation. They are symptomatic of excess liquidity in the system. No liquidity = high rates overall = deflationary environment ahead

I made the claim that those buying sovereign bonds with negative bond yields pay more than the bond will return over the investment horizon, hence their rational expectation to recover this upfront loss must be anchored to the future cash flows increasing their buying power up to and including redemption, or selling to a greater fool, prior to the terminal event, at a higher price. You must have noted claims that ~16 trillion USD equivalent bonds are trading with negative yields.

You imply that low interest rates cause deflation, and high interest rates cause inflation.

I beg to differ, since they are simply a symptom as Milton Friedmam claims:

Milton Friedman claimed already in the 1960s:

“As an empirical matter, low interest rates are a sign that monetary policy has been tight – in the sense that the quantity of money has grown slowly; high interest rates are a sign that monetary policy has been easy-in the sense that the quantity of money has grown rapidly. The broadest facts of experience run in precisely the opposite direction from that which the financial community and academic economists have all generally taken for granted”

Furthermore, I find myself in agreement with Professor Werner's analysis:

Our empirical findings on the correlation and statistical causation can be summarised as follows: (1) Nominal GDP growth is highly and positively correlated with short and long-term rates in all four countries; (2) Nominal GDP growth Granger-causes long-term rates in all countries examined, whereas the opposite holds only in one country (Germany, with two-directional causality); (3) Nominal GDP growth Granger-causes short-term rates in all four countries, whereas the opposite holds only in one country (the US, where a strong two-directional causality is found).

The data suggests overall that statistical causality runs from economic growth to long-term interest rates. Nominal GDP growth provides information on future interest rates better than interest rates inform us about future nominal GDP growth.

Our empirical findings reject the canonical view that interest rates somehow affect economic growth, and in an inverse manner. To the contrary, long-term and short-term interest rates follow the trend of nominal GDP, in the same direction, in all countries examined. This suggests that markets are not in equilibrium and the third factor driving GDP growth is a quantity – as shown by Werner, 1997, Werner, 2012a in the case of Japan (namely, the quantity of bank credit creation for the real economy - i.e., for GDP transactions, as the Quantity Theory of Credit postulates; Werner, 2013a). Link

A user friendly version of Werner's monetary musings can be read here.

Oh god, you’ve said it all now.

Good luck

I've had my share.

How about checking how we lose $20 Billion profit a year to Foreign Investors from asset sales.

Tenants in our own land.

1 years Foreign owned profits would take our largest NZ company Fonterra 40 years to earn.

Remarkable that we think asset sales and Foreign Capital somehow helps our economy.

The next decade will see $200 Billion profit go offshore.

That will take 400 years of Fonterra work to match.

NZ is in receivership status. A giant ponzu scheme.

Pity our children’s future.

So we went from one form of central power and control to another form, which was meant to be free yet the structures around it were in many cases set in a way that were almost as constraining of thinking as we'd had previously.

Sums up our modern world really.

A case of swapping masters? I reckon there is going to be a right battle for that space in time, probably within the next decade.

Thanks Gareth. Always good to hear from a well informed person with decades of experience on a particular subject, and somebody who considered both sides of an argument. It's a bit sad that being presently surprised by the quality of an news article is such a rear thing nowadays.

Morality is what is missing, and trying to fix the RBNZ act won't help anything without morality as a foundation. I say this because without the right foundation and legislative changes are simply a new obstacle to find a way of cheating/beating. It is a bit like I say about science being held up as the benchmark, when it is only as good as the person that designed the experiment. Even peers can miss flaws, or be drowned out in the noise.

As for social license, I would think if the average person knew how banks worked it would be withdrawn pretty quickly.

The issues Susan rightly raises are macro-prudential (deposit protection, bank supervision, non-bank FI supervision), functions generally not managed by the central bank in larger economies (APRA for example). With regards to actual monetary policy, the Reserve Bank Act was ground-breaking and an incredible success in my opinion.

According to Snively, the response she got once back from London was that finance companies - an important source of capital for property developers - would be okay because they were using their own money. This, she was told, meant they would be very responsive to market conditions and didn't need RBNZ oversight. However Snively didn't agree.

Wasn't Don Brash the CEO of the failed Broadbank finance company before he was appointed to his governership of the RBNZ?

Interesting article. We should all be a lot more focused on the activities of Central Banks.
For example when interest rates are lowered dramatically part of the explanation should include the expected impact on households as they will now pay more for imported goods vs the expected impact on exporters who will now be more competitive. True transparency would make this calculation explicit. For example after lowering the OCR 50 points the $nz dropped by 1.5 cents. Almost 3% vs the US dollar. This immediately translates to higher fuel prices etc. Whereas milk powder in $us is now 3% cheaper. There are many more similar transfers implicit in how monitary policy conducted. Trouble is hardly anyone understands this. And that seems to suit the bankers very well.
What to do? Even the current education system sees this kind of understanding a very low priority.