25 June 2025

Speech by Samantha Barrass to NZSA

Image of Samantha Barrass, FMA CE

 (Notes may differ slightly from speech as delivered)

Setting the Standard – Actuaries are the architects of trust and conduct

Tēnā koutou katoa and thank you for the warm invitation to today. 

It’s great to be here today. I want to acknowledge Helen Mexted and the New Zealand Society of Actuaries team for the effort and thought that went into making this an engaging event.  

There has been a noticeable pick up in discussions and engagement between your Society and the FMA, and I want to thank all of those who have helped make this happen. There is huge value in open lines and channels of communication between our two organisations.  

The Society also joined the Council of Financial Regulators Insurance Forum, a platform that brings regulators and industry stakeholders together to connect and discuss sector priorities   

I hope you all found the earlier FMA session with Jane, Davide, Sadia and Nicolette useful. From our perspective, we have appreciated being part of today. 

For us to be an effective regulator, we must have good relationships with the industry so we can support good practice and reduce the risk of poor outcomes. 

From a regulatory perspective we have been able to form a clear view of the outcomes we want, which we know consistently lead to better results for consumers, businesses, and the broader economy - I’m pleased to share some of this with you today.  

Now - I have found myself speaking just before lunch in the most strategic slot of the day. It’s where your appetite for ideas is in direct competition with your appetite for kai.  

So, I’ll do my best to keep this brief to help feed your appetite for both. I’ll also join you for the kai and a korero. 

I want to speak today about the role of regulator and actuary, how conduct and trust is key to a fair and well-functioning financial system, and I’ll unpack what some of the FMA’s priorities are for the year ahead.  

So, let’s move onto the main agenda – starting off with trust. 

Strengthening Trust and Outcomes in Financial Services 

Trust in the financial sector is crucial – we all have a shared responsibility to ensure the system works for everyone.  

Every day, your research, analysis, and use of statistics guides critical decision-making within the organisations you serve – decisions that ultimately shape people’s lives and wellbeing.   

And it’s much the same for regulators.  

The FMA is focusing on the things that matter. That is, thinking about the end results we want to achieve and ensuring the work we do reflects that. 

History teaches us that virtually any financial risk can be managed – if the price is right. The challenge with this lies in identifying those risks early, understanding their complexity, and making decisions informed by evidence, data and insights. 

This is why the relationship between regulators and actuaries is not just beneficial – it’s essential.  And to truly understand why, demands more open dialogue with the sector. 

So, in that spirit, let’s talk. 

And I do apologise if this may be a bit ‘one way’ from me for the next 10 minutes, there will be plenty of time at the end for questions and two-way discussion.   

Delivering on economic priorities 

It will be no surprise to you that the FMA has been supporting many changes across the financial system, mostly driven by the Government’s economic priorities – which is to build a vibrant and trusted financial sector.  

Fundamentally, the FMA’s core mandate broadly remains as it always has been , about ensuring our regulation supports growing the economy and enables innovation.   

As a kaitiaki of financial markets, supporting the delivery of Aotearoa’s wider economic priorities is an immensely important role. We believe that New Zealanders should have access to the leading-edge financial services and products that will enhance their lives.  

This demands a commitment to more adaptive regulation – expanding our engagement is one way we can enhance this and help shift our mindset. 

 I’m proud of the progress we’ve made.  You will see the FMA has expanded our engagement with the Fintech sector – tapping into new sources of knowledge to help us evolve as regulators.  

The Minister for Commerce and Consumer Affairs writes an annual Letter of Expectations to the FMA; This year is no different. Meeting this year's expectations involves a focused commitment to: 

  • Providing clear and practical guidance
  • Removing unnecessary regulatory barriers and simplifying licensing
  • Enabling quicker access to innovative financial products and services
  • Responding to misconduct proportionately using the full suite of regulatory tools
  • Working with the Reserve Bank and MBIE on capital market reforms
  • Improving digital tools to address scams and cyber threats. 

We are applying this focus more broadly across our work. While 2024 laid the groundwork for several new regulatory regimes, such as CoFI and Contracts of Insurance Act, our focus is moving beyond implementation, and towards strengthening the monitoring of our expanded regulatory remit.  

Technology is rapidly changing insurance 

Part of the FMA's role is to promote innovation and flexibility while also ensuring consumers understand what they are buying.  

We know actuaries are trusted advisors – and it’s likely you will be brought into discussions early.  This is vital in a world where technology is evolving daily, and the way people interact with, seek advice and purchase financial products is changing.  

The technology is moving fast – particularly in the AI space – and we know that many of the institutions you serve are beginning to explore ways to enhance efficiency or even augment advice delivery.  

While this is not new territory for the financial sector, we have observed the uptake of technology remains low among financial advice providers. While we’ve been encouraged by some early engagement from financial advice providers looking to explore digital advice models, only 36 Financial Advice Providers currently offer a full digital advice facility.  

We are using tools like the FMA’s regulatory sandbox to engage with innovators early – so we can understand risks, test boundaries, and build fit-for-purpose guidance over time.  

You will see the FMA continue to promote and enhance our support for fintech across the spectrum of the financial system. This supports our priority to enable innovation while protecting consumers. 

We see this as key to improving access to the leading-edge financial services and products.    

The Actuarial profession’s role 

As the FMA continues to support economic growth, it’s essential we deepen our conversations about new and emerging risks and how they’re managed.  

This relies on collaboration and mutual respect – not only between regulators and actuaries, but also with customers and the wider public. 

This is important as financial stability is not a given – it’s something we must actively safeguard. As actuaries, you are the first line of defence to the stability of life , non-life and health insurers. Our 2019 Life Insurer Conduct and Culture report highlighted the critical role you play as kaitiaki of policyholders. 

You all hold a key role in modelling and assessing risk, supporting financial product design and pricing, and supporting long-term financial sustainability – all vital to our financial system. 

And it’s not just about numbers – every transaction, every policy, and every promise is built on trust.  And behind every model is a person, a family, a business. 

From my perspective, and I may be corrected in question time – is that actuaries are the architects of trust and conduct.  

By this I put to you all that the impartial advice you provide about financial risks, solvency, and the health of your financial institutions influences the rhythm and tone for every other part of your organisation – including conduct. 

Financial Conduct Report (FCR) 

This leads me to the FMA’s recently released Financial Conduct Report – our first ever. It’s hot off the press and we spoke to media this morning. 

At the FMA, we prioritise meaningful regulation by focusing on achieving impactful outcomes that truly matter and benefit New Zealanders – this starts with conduct. 

Good conduct is the foundation of a vibrant and trusted financial sector, fostering the confident participation of businesses, investors and consumers. Poor conduct, however, can undermine confidence, damage reputations, and discourage participation in our financial markets.  

The FCR highlights where we see the greatest risks and opportunities for consumers and for the integrity and resilience of New Zealand’s financial markets. 

By publishing this report, we want to be transparent about the key issues on the FMA’s radar and how we intend addressing them through our priority focus areas to support better outcomes for consumers and markets. 

This transparency is designed to spark a meaningful dialogue between us and the industry, embodying our Outcomes-Focused Approach. 

While we encourage Boards, Executives and Leaders to use the FCR to understand the FMA’s regulatory priorities for the coming year we encourage you all to consider it too. 

I hope this provides you with information and insights to consider how you can help your institution get better outcomes for consumers and the market. 

The Financial Conduct Report will be updated annually, informed by insights from our monitoring work to help us shape our regulatory priorities. 

These evolving priorities are increasingly shaped by the Conduct of Financial Institutions (CoFI) regime, that was implemented in March 2025, that directly led to the development of the Financial Conduct Report. 

Conduct of Financial Institutions 

CoFI requires financial institutions to ensure that consumers receive products and services that meet their needs and perform as expected.  

This is a key tool we are using to help advance our work to reduce harm to consumers. CoFI represents a significant expansion of the FMA’s role, beyond licensing, to include day-to-day oversight of retail banking and insurance conduct.  

Our initial monitoring work was published in April, through the Fair Conduct Programme Insights Report, which showed that many firms are: 

  • Embedding the Fair Conduct Principle into governance frameworks
  • Tailoring it to their business models
  • Linking it with wider risk and conduct systems 

This is a positive sign and signals to us a strong commitment across the sector to prioritising fair treatment of customers. The actuarial profession has a key role in ensuring products and services are reviewed regularly remain relevant to consumers.  We look forward to continuing this work with industry and I would be very keen to hear any thoughts you have from experiences from CoFI so far. 

In the first years of the regime, like almost all new regulatory regimes, we will take an educative and collaborative regulatory approach. Supervision will remain risk-based, with more intensive engagement for firms, products, or practices that pose higher risks to consumers. 

Like the FCR, the Fair Conduct Programme Insights Report will continue to be a tool we use to monitor and take the temperature of market conduct.  

Climate-Related Disclosures (CRD) 

Another growing area of importance is Climate-Related Disclosures – an area where actuaries are on the front lines. 

You will all be aware of recent changes this space, and I want to begin by recognising the considerable efforts of Climate Reporting Entities.  

One of the essential functions of financial markets is to price risk accurately. This supports informed, efficient capital-allocation decisions. To do this well, entities need to provide accurate, comparable and timely disclosure.  

Most climate statements we have seen reflect reasonable efforts to meet disclosure requirements. We will continue to maintain a constructive approach to monitoring but will continue to signal where we are looking to see improvements and entities building on what has been done the previous year.  

This will continue to remain a strong focus for the foreseeable future, and we continue to work closely with the External Reporting Board and MBIE as the policymaker in this area.  

We continue to have positive engagement with industry so far on the issue, including with Helen and the Society team. 

This constructive engagement comes at a pivotal time, as the Contracts of Insurance Act 2024 introduction is on the horizon.  

Contracts of Insurance Act 2024 

From our perspective the Contracts of Insurance Act 2024 changes modernise our insurance laws and enable better alignment with other recent consumer protection laws, promoting more fairness. 

This consolidates five existing pieces of legislation into a single, modern framework.  

The key requirements include: 

  • Contracts must be in plain language
  • Consumers must act honestly and take reasonable care not to make a misrepresentation
  • Insurers must respond proportionately to non-disclosure or misrepresentation
  • Insurers must pay claims within a reasonable timeframe
  • Intermediaries must promptly pass on critical information and payments 

This affects all of us – consumers, advisors and institutions – by introducing fairer expectations across the insurance system. 

Overall, I think this will provide better outcomes and facilitate more transparency between institution and customer. 

Access to financial advice 

Fairness doesn’t stop at the point of sale or claim – it means ensuring people can access the advice they need to make informed decisions. That’s why access to affordable and quality advice, is a strategic priority for us.  

While licensing and monitoring have lifted standards, we’re still hearing the message that some barriers to access remain – especially for consumers with limited means or less complex needs.  

That’s why we’ve launched a formal Access to Advice Review – to examine the challenges and opportunities for advice accessibility, and to ask how the industry (and the way FMA regulates) can evolve to better serve the public good. 

The review of access to financial advice is focusing on understanding the challenges and opportunities to improve accessibility of financial advice, such as: 

  • Consumer preferences and demographics
  • Industry business models 
  • Digital advice and innovation
  • Ease of provision of financial advice. 

Our focus is squarely on understanding what’s working, what’s not, and whether there are emerging barriers that need to be addressed. We expect to publish an industry report in early to mid-2026 summarising what we’ve heard through this process.  

I’m not sure what the next steps might look like, but this may include follow-up work or publishing further guidance where clarity is needed.  

An actuary's role in reducing harm 

I acknowledge that for both industry and regulators the degree of change in the last decade has been immense. I hope at some level this has resonated with you.  

In a sector of increasing complexity, your voice and expertise has never been more important. So, thank you for allowing me to start this conversation. 

I view your decisions, your insights, and your integrity as key to writing the next chapter of fairness and stability in New Zealand’s financial system. 

Starting with your core responsibilities – identifying emerging risks and opportunities, safeguarding client assets, and upholding clear and ethical disclosure standards – you already play a critical role. 

But when we overlay Fair Conduct Programmes against the Financial Conduct Report, the implications for actuaries are broad.  

I do believe you will find yourself contributing to work that directly impacts many of the FCR outcomes we are starting to monitor, such as: 

  • Addressing challenges and opportunities to improve the accessibility of financial advice
  • Supporting proactive reviews of existing products
  • Ensuring consumer and investor interests remain central to all decision-making
  • Shaping conduct that positively impacts consumers in vulnerable circumstances. 

So in summary, I encourage each of you to reflect on these changes, consider what they mean for your role, and think about how you can support your institutions in navigating them. 

Thank you again for the opportunity to speak. I look forward to continuing our korero with some of you over kai.  

I’m now happy to take any questions you may have, or to hear your thoughts or insights.