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Build a comprehensive understanding of the new CoFI regime, and learn how our Design and Innovation consultants can help you define good customer outcomes specific to your organisation.


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Fair Conduct Programmes

The CoFI Act’s primary purpose is to focus on treating consumers fairly. Financial Institutions caught by the regime will need to obtain an FMA licence and establish, implement and maintain fair conduct programmes (FCPs) that consider the fair conduct principle throughout the customer journey.

Paying due regard to consumers is a complex and often ambiguous problem in the regulatory environment. However, defining fair and quantifying tailored, good customer outcomes doesn’t have to be an insurmountable challenge. Placing the customer at the centre of the problem removes subjectivity to developing empathy-led FCPs that benefit all stakeholder agendas and priorities.

Key Outcomes

Licensed by the FMA in respect of their conduct towards consumers
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Establish, maintain, and implement a Fair Conduct Programme (FCP)
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Comply with new regulations on sales incentives

Who We Are

Our Design & Innovation team brings the depth of experience and multi-disciplinary expertise you need to transform your approach to innovation. From human-centered design and UX to product engineering and brand marketing, our people have played vital roles in start-ups, multinational conglomerates, and other high-growth environments. Assessing customer needs to create bold, transformative solutions that redefine what’s possible.

Learn more about us here.

Client Results

ANZ Bank: Designing a customer-led strategy to meet the needs of first-home buyers.

Buying a first home is a daunting, overwhelming experience with customers stepping into the unknown. ANZ Bank engaged Assurity Consulting to understand the journey to homeownership for first-home buyers and harness these insights to design a customer-led strategy to simplify complexity and guide customers through the

Read the case study here.

National Institute for Health Innovation: Elevating the consumer's voice.

The team at NIHI recognised that the customers’ needs have changed over the past decade, and new methods of application development – including Agile – have emerged. The NIHI team sought to blend clinical integrity and evidence-based features.

Read the case study here.

Talk to One of Our Consultants

Angela Roper
Client Solution Manager, Design & Innovation

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Akshay Rao

Principal Innovation Consultant

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Thomas Nye

Innovation Consultant

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Our Insights

De-risking CoFI Legislation

A new regulation that explicitly targets the customer experience can create uncertainty and put the value at risk for businesses, but it also creates opportunity and unlocks new growth levers. One such regulatory change impacting financial institutions is CoFI Legislation – Conduct of Financial Institutions (Commonly known as CoFI).

Read more.

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What problems are you really solving for your customer?

Statistically, design-led organisations increase their revenue and shareholder returns at nearly twice the rate of their industry counterparts. Many of us have read the case studies on the world’s leading companies like Google, Netflix, and Amazon, who have an unwavering focus on their customers.

Read more.

Additional Reading Resources

1.  Conduct of Financial Institutions (CoFI) Legislation - Financial Markets Authority (FMA). The FMA and Reserve Bank of New Zealand undertook joint reviews into the conduct and culture of banks and life insurers in New Zealand, in 2018 and 2019, respectively. More recently, the FMA also reviewed the conduct and culture of fire and general insurers. Those reviews found banks and insurers were not putting in place systems and processes to ensure consumers were treated fairly. Read more.

2. Conduct of Financial Institutions Regime - Ministry of Business, Innovation & Employment. The Financial Markets (Conduct of Institutions) Amendment Act 2022 was passed into law on 29 June 2022. The legislation introduces a new regime regulating the conduct of financial institutions that is planned to come into force in early 2025. Read more.

3. FMA Publishes Various CoFI Licensing Materials - MinterEllisonRuddWatts. The Financial Markets Authority (FMA) has released today a suite of materials to help financial institutions continue with preparations for the conduct regime under the Financial Markets (Conduct of Institutions) Amendment Act 2022 (CoFI). Read more.

4. What the New CoFI Regime Means for Financial Institutions - lane neave. The Financial Markets (Conduct of Institutions) Amendment Act 2022 (CoFI Act) received Royal assent on 29 June 2022, introducing a new regulatory regime for the conduct of retail banks, licensed insurers and licensed NBDTs (Financial Institutions) providing services to consumers in New Zealand with a focus on treating consumers fairly (CoFI Regime). Read more.

5. Financial Markets (Conduct of Institutions) Amendment Bill - New Zealand Parliament. This bill amends the Financial Markets Conduct Act 2013 to ensure that certain financial institutions and their intermediaries comply with a principle of fair conduct and associated duties and regulations. Read more.