Cloudbank Digest — RBNZ's $209m levy consultation opens +34 more · 19 Jul
Sunday, 19 July 2026 · 35 stories
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Watchlist — key dates ahead
18 Aug 2026Judo Bank releases FY26 full-year results, first look at scale of its Q4 bad-debt provisioning (AU).
1 Sep 2026Australia's Scams Prevention Framework's core obligations for banks, telcos and platforms take effect, backed by up to A$50m per-breach penalties and a private right of action.
2 Sep 2026RBNZ's next Monetary Policy Statement and OCR review.
11 Sep 2026RBNZ submissions close on Deposit Takers Act crisis-preparedness package and tranche-3 exposure-draft standards (recovery/exit planning, loss-absorbing capacity, Continuity of Access to Deposits).
Late Sep 2026RBNZ expected to release findings from the Keeping Cash Local consultation.
30 Sep 2026Heartland shareholders vote on the $620m TSB Bank acquisition and merger, after Toi Foundation trustees decide on the sale (expected August).
1 Oct 2026RBA's ban on card surcharges (Visa, Mastercard, eftpos and Amex) takes effect in Australia, estimated to save consumers and businesses up to A$1.8bn a year.
16 Oct 2026Submissions close on RBNZ's proposed prudential levy consultation on banks, insurers and FMIs; levy to take effect August 2027.
Treasury and RBNZ are preparing to consult banks, non-bank deposit takers, insurers and financial market infrastructure providers on a new prudential levy designed to recover roughly $209 million of RBNZ regulatory costs over four years, separate from the existing AML/CFT levy.
Fintech giant Stripe, together with private equity firm Advent International and reportedly Block, offered roughly $53bn — about $60.50 a share, a 28% premium — to acquire PayPal, with PayPal's board said to be reviewing the offer around 20 July.
Fintech BlinkPay added Kiwibank to its open-banking-powered payment gateway, letting Kiwibank personal and business customers pay merchants directly from their bank account with settlement confirmed in seconds, following an earlier proof-of-concept with BNZ.
1 Regulatory — NZ horizon & global signals
New Zealand first; global banking, finance & payments items included where there's an NZ read-across.
Regulatory — NZ horizon & global signalshigh
RBNZ prudential levy consultation set to open, banks and insurers to fund $209m of regulatory costs
Industry-funded regulation · Announced Budget 2026 (28 May); sector consultation opens late Jul, runs to Oct 2026; Cabinet decisions early 2027; levy effective mid-2027
Treasury and RBNZ are preparing to consult banks, non-bank deposit takers, insurers and financial market infrastructure providers on a new prudential levy designed to recover roughly $209 million of RBNZ regulatory costs over four years, separate from the existing AML/CFT levy.
Why it matters — A distinct new cost line for deposit takers on top of the AML/CFT levy already locked in. The consultation will fight over cost-recovery scope, allocation methodology and whether banks can pass costs to customers — a live political flashpoint, with the Finance Minister warning banks not to pass it on while other ministers say customers will pay regardless.
Bank of England eases capital and leverage rules even as it flags rising systemic risk
Global capital-rule recalibration · Financial Stability Report published mid-Jul 2026 (FPC met 26 Jun)
The Bank of England's Financial Policy Committee has trimmed its system-wide Tier 1 capital benchmark to around 13% of risk-weighted assets from 14%, cut the minimum leverage ratio from 3.25% to 3%, and made buffers more releasable in stress — even as it warned of a higher chance of overlapping shocks hitting the system at once.
Why it matters — A major peer prudential regulator is deliberately loosening capital settings to free up lending capacity while flagging higher tail risk — a striking contrast to RBNZ's traditionally conservative settings, and useful ammunition for NZ industry bodies already pushing RBNZ to revisit its own capital stack as Deposit Takers Act standards are finalised.
European Commission unveils banking reform plan to unlock capital trapped by cross-border fragmentation
Supervisory simplification and proportionality · Communication published 17 Jul 2026
The European Commission proposed giving home-country supervisors more power over EU banking groups' capital and liquidity, aiming to free an estimated €225bn in capital and €250bn in liquidity currently ring-fenced at subsidiary level, alongside plans to harmonise deposit protection and AML rules from July 2027.
Why it matters — Part of a broader global push — alongside the BoE's capital easing — toward simplifying bank supervision to support competitiveness and lending capacity. Strengthens the case NZ industry bodies are already making to RBNZ and MBIE for proportionate, less fragmented rulemaking as the twin-peaks model and Deposit Takers Act standards bed in.
Canada's OSFI fast-tracks bank licensing for fintechs and crypto custodians
Competition-driven licensing reform · Programme launched 25 Jun 2026
Canada's prudential regulator OSFI launched a streamlined approval pathway to speed up federal bank licensing for provincial institutions converting to federal credit unions and for emerging models such as fintechs and crypto-asset custodians.
Why it matters — A G7 prudential regulator actively fast-tracking new entrants, including crypto custodians, sharpens the contrast with New Zealand's own slow, costly path to registered-bank status — a long-standing complaint from would-be challenger and digital banks — and adds pressure on RBNZ/MBIE as they weigh bespoke licensing for stablecoin and token-based payment providers.
China's banking regulators issue 49 fines in a single week as AML enforcement intensifies
AML enforcement tempo under centralised supervision · Fines issued first week of Jul 2026
Chinese banking regulators issued 49 fines against 20 banks in the first week of July, averaging roughly 3.12 million yuan a day, continuing a first-half 2026 trend that saw total fines exceed 1 billion yuan — up more than 20% year-on-year — with credit and fund-flow monitoring failures most penalised.
Why it matters — A live example of the enforcement tempo possible under a single, centralised supervisory regime — directly relevant as DIA settles into its new role as New Zealand's sole AML/CFT supervisor, and a signal of what reporting entities should expect as thematic reviews mature.
Focused on banking & payments, but includes cross-industry moves with read-across to financial institutions and their operations.
AI & automation — banking, payments & beyondhigh
Nubank publishes production results for AI customer-support agents across its 100m+ user base
Retail banking AI customer service at scale · Disclosed 13 Jul 2026
Nubank's engineering team disclosed large-scale A/B test results for AI agents handling card delivery, debt management, credit-limit queries and product explanations, reporting a 37-point jump in transactional AI Net Promoter Score and a 29-point rise in self-service rate for the card-delivery use case.
Why it matters — One of the few publicly quantified, population-scale case studies of AI customer-service agents rather than a vendor claim or pilot, giving NZ retail banks a rare benchmark for expected CX and cost gains.
FIS and Anthropic build a financial-crimes AI agent; BMO and Amalgamated Bank first to deploy
Core-banking vendor AI for financial crime · Announced 4 May 2026; broader rollout targeted H2 2026
Core-banking vendor FIS partnered with Anthropic to build an agentic AI tool that assembles evidence across a bank's systems, screens activity against known money-laundering typologies and escalates the highest-risk cases to investigators, compressing AML reviews from hours to minutes. BMO and Amalgamated Bank are the first live users.
Why it matters — FIS underpins core systems for hundreds of mid-size and community banks globally, so this is a template many NZ-relevant vendors and banks will watch — it signals AML/KYC investigation, not just onboarding, is now a live agentic-AI battleground, with auditability built in from the start.
Fiserv launches agentOS, an AI 'operating system' for banking, co-built with six banks and OpenAI
Core-banking AI platform infrastructure · Launched 14 May 2026; general availability targeted Aug 2026
Payments and core-banking vendor Fiserv unveiled agentOS, built with OpenAI on AWS Bedrock, to let banks deploy and govern AI agents across core, payments, issuer processing and servicing workflows. Six financial institutions co-developed it, two are running agents in beta, and early pilots reportedly cut commercial-loan onboarding and reporting from around ten minutes to seconds.
Why it matters — As a dominant global core-banking and card-processing vendor, Fiserv shipping a governed, bank-wide agent layer — rather than a single point-solution — sets a reference architecture NZ banks' vendor and infrastructure teams will benchmark against.
AI & automation — banking, payments & beyondmedium
Linux Foundation launches x402 Foundation to standardise AI-agent payments, with Visa, Mastercard, Stripe and Amex founding members
Agentic-commerce payments infrastructure standard · Launched 14 Jul 2026
The Linux Foundation formally stood up the x402 Foundation, an open-governance body to steward a protocol letting AI agents send and receive payments — cards or stablecoins — directly over standard web requests; 40 organisations joined, including 17 premier members spanning card networks, cloud providers and stablecoin issuers.
Why it matters — A vendor-neutral payments rail purpose-built for AI agents is a prerequisite for the agentic-commerce use cases banks are already piloting; its governance model will shape how NZ banks' card and payments teams plan for machine-initiated transactions over the next 12-24 months.
AI & automation — banking, payments & beyondmedium
Goldman Sachs leads $110m round for Taktile, a startup automating bank credit and AML decisions with AI agents
Vendor funding for agentic decisioning in regulated banking · Announced 24 Jun 2026
Regtech startup Taktile raised US$110m, led by Goldman Sachs Alternatives, to expand a platform that delegates high-stakes bank decisions — loan approvals, money-laundering alert triage, claims payouts and onboarding — to AI agents operating under regulatory guardrails, taking total funding to US$184m.
Why it matters — A major bank-owned investor backing an agent-first decisioning vendor rather than building purely in-house is a signal for NZ banks and fintechs weighing buy-versus-build for onboarding and AML alert automation, and underscores investor appetite for governed, non-black-box decisioning.
AI & automation — banking, payments & beyondmedium
Morgan Stanley opens its wealth-management data platforms to external AI agents
Agentic access to wealth/banking platforms · Announced 3 Jun 2026
Morgan Stanley will let corporate clients' autonomous AI agents pull data directly from its stock-plan administration platforms, bypassing traditional human-facing interfaces, with a handful of clients already given early access ahead of a wider rollout to roughly 3,400 administration clients.
Why it matters — Moves agentic AI from bank-internal tools to letting external client agents query bank platforms directly — a distinct governance and API-security question (authentication, liability, data leakage) NZ wealth and business-banking platforms will face as corporate customers adopt their own AI agents.
BlinkPay brings real-time account-to-account payments to Kiwibank customers
NZ real-time payments build-out · Announced 13 Jul 2026
Fintech BlinkPay added Kiwibank to its open-banking-powered payment gateway, letting Kiwibank personal and business customers pay merchants directly from their bank account with settlement confirmed in seconds, following an earlier proof-of-concept with BNZ.
Why it matters — The first concrete commercial proof that open banking rails can deliver genuine real-time account-to-account payments in NZ ahead of the RBNZ-led real-time payments programme — a live pressure test that could shape merchant appetite and set expectations for what the government-backed rail needs to match.
Visa launches internal stablecoin platform targeting 200 million-plus merchants
Card networks embed stablecoins into core rails · Announced 16 Jul 2026
Visa unveiled an internal platform letting banks and fintechs mint, move and manage stablecoins across its network of roughly 15,000 financial institutions and 200 million-plus merchant locations, launching first with the newly formed Open USD (OUSD) coin.
Why it matters — A card giant embedding stablecoin rails directly into its existing merchant and issuer network — rather than treating stablecoins as a bolt-on crypto product — signals stablecoin settlement is moving from pilot to default infrastructure, raising the stakes for banks weighing their own tokenised-deposit responses.
Canada locks in by-law for its Real-Time Rail, targets Q4 2026 launch
Global real-time payments build-outs · By-law in force 24 Aug 2026; launch targeted Q4 2026
Payments Canada secured final approval of the by-law and rules governing its long-delayed Real-Time Rail, clearing the last regulatory hurdle before a phased commercial launch later this year, though full bank and fintech access won't arrive until 2027.
Why it matters — Canada's decade-long, cost-and-governance-plagued path to real-time payments is a close analogue for New Zealand's own RBNZ-led programme — its phased-access approach and slipping timelines are a useful cautionary benchmark for NZ bank executives watching their own rail's design choices.
The Clearing House said its RTP network — now covering more than 1,100 US banks and $1.3 trillion processed in 2025 — will add domestic correspondent-banking functionality from September, a first step toward supporting 'one-leg-out' international transfers.
Why it matters — Extending domestic instant-payment rails to handle the US leg of cross-border wires foreshadows how real-time domestic schemes globally, including any future NZ rail, could eventually plug into international settlement, intensifying pressure on correspondent-banking margins.
MBIE consults on delegated access and trust-account rules for NZ open banking
Open banking scope widening · Consultation closed 19 Jun 2026
MBIE ran a technical consultation on how NZ's open banking regime should handle delegated-access arrangements and professional trust accounts, issues flagged during an earlier April 2026 consultation on extending open banking to more business digital channels.
Why it matters — These technical carve-outs determine how far open banking data-sharing obligations reach into business and trust banking relationships — a compliance-scoping detail that matters for how much system rework banks face as the regime widens beyond the big four's initial go-live.
NZ card spending growth slows sharply as consumer caution deepens
June 2026 data, released 14 Jul 2026
Electronic card retail spending fell 1.4% month-on-month in June, with annual growth easing to 1.3% from 3.3% in May, even as manufacturing activity posted its strongest reading in five years — a sign household caution is deepening in pockets of the economy even as others firm.
Fed and RBA head into split-decision territory at their next meetings
Central bank divergence · FOMC meets 28-29 Jul 2026; RBA meets 10-11 Aug 2026
The US Federal Reserve heads into its 28-29 July meeting with markets pricing no change to the 3.5-3.75% range but roughly half of policymakers expecting a hike by year-end, while the RBA faces a similarly split call ahead of 11 August, with Westpac alone among Australia's big four still forecasting another 25bp rise.
Why it matters — Divergent paths among NZ's key external reference rates matter directly for bank wholesale funding costs and the NZD cross-rate, both live inputs into how far the big five NZ banks can move ahead of or behind the next RBNZ decision.
Fintech giant Stripe, together with private equity firm Advent International and reportedly Block, offered roughly $53bn — about $60.50 a share, a 28% premium — to acquire PayPal, with PayPal's board said to be reviewing the offer around 20 July.
Why it matters — A deal of this size would reshape global payments rails just as Stripe is separately trialling an Australian business-banking challenger — a serious escalation of competitive pressure on banks' merchant-acquiring and payments businesses, and a signal that scale consolidation among fintechs is accelerating.
BNPL retreat / non-bank lender consolidation · Announced mid-Jul 2026; wind-down effective 16 Aug 2026
ASX-listed BNPL provider Zip Co confirmed it will withdraw from New Zealand and begin an orderly wind-down of local operations from 16 August 2026 following a strategic portfolio review, while its Australian business continues to grow transaction volumes.
Why it matters — A BNPL name pulling out of NZ narrows the non-bank lending field just as open-data rules extend to BNPL/non-bank lenders in Australia — reduces one competitive vector NZ banks were watching, but signals thinner margins are forcing BNPL consolidation, which could resurface as a bank-embedded BNPL opportunity.
Bendigo and Adelaide Bank hit with capital add-on and $80m risk-system overhaul after AML failures
AML enforcement at a regional/digital-challenger bank · Reported mid-Jul 2026
Australian regulators ordered Bendigo and Adelaide Bank to hold an extra A$50m in capital and tighten risk controls after a review found financial-crime weaknesses tied to a community-branch case, prompting an A$80m, three-year investment in compliance systems even as its Up digital-banking arm nears profitability.
Why it matters — Shows AML/financial-crime enforcement reaching second-tier and digital-adjacent banks, not just majors — a template NZ regulators (DIA, RBNZ) may watch given NZ's own AML/CFT levy and supervision changes; also highlights that neobank growth doesn't exempt parent banks from legacy compliance costs.
Competitor watch — NZ, Australia & globalhighUpdate
JPMorgan closes in on becoming the first $1 trillion market-cap bank
Scale gap between global majors and NZ/AU banks · Reported 15 Jul 2026
Beyond its already-reported record Q2 net income of $21.2bn, JPMorgan's share price has pushed its market capitalisation to roughly $949bn, putting it within reach of becoming the first bank ever to hit a $1 trillion valuation, alongside a $4.6bn gain on its Visa stake.
Why it matters — Illustrates the widening capital and technology-investment gap between US majors and NZ/AU banks, reinforcing why local players increasingly benchmark against JPMorgan's AI and consumer-banking build-out rather than each other.
Monzo posts profitable FY26 results, presses ahead with London IPO plans
Neobank profitability at scale · FY2026 results reported late Jun 2026
UK neobank Monzo reported FY2026 revenue up 39% to £1.71bn and statutory pre-tax profit of £87.3m, with 15.2 million customers — about one in five UK adults — while continuing preparations for a London Stock Exchange listing targeting a £6-7bn valuation.
Why it matters — A rare demonstration that a consumer neobank can reach durable profitability at national scale — directly relevant as Revolut and Wise push further into NZ/AU personal and business banking, since it undercuts the assumption that challenger banks can't out-earn incumbents on unit economics.
Wise's FY26 results show Australia as a key driver of card-business growth
Cross-border neobank momentum in the region · FY2026 results reported 25 Jun 2026
Wise reported FY2026 active customers up 21% to 19 million and net revenue up 29% to $2.5bn, with card revenue climbing 40% to $392m on strong uptake in Australia, the EU and UK.
Why it matters — Confirms Wise's underlying growth as it sits opposite Revolut in the NZ/AU cross-border and SME-banking rivalry — the Australia-specific card growth signals Wise is defending share just as Revolut and Stripe push into the same corridor.
Customer-impacting fraud, scam typologies and the liability landscape — NZ-first, with global threat signals.
Fraud & scamshighUpdate
Australia's scam reimbursement rules take shape with $3,000 automatic-payout threshold and 50/50 liability split
Reimbursement/liability landscape · Draft rules released 28 May 2026; SPF takes effect 1 Sep 2026, full obligations from 31 Mar 2027
Treasury's draft rules for the Scams Prevention Framework propose that verified scam losses under A$3,000 be automatically reimbursed without full investigation, with liability generally split equally between at-fault entities — banks, telcos, platforms — unless one played a materially greater role.
Why it matters — The first specific mechanics of how liability will actually be apportioned and reimbursed under Australia's SPF, which NZ banks and regulators are watching closely as a possible template ahead of any NZ scam-code legislation. Consumer groups call the $3,000 bar too low; telcos warn it creates a fraud 'honeypot' — debates NZ policymakers will inherit if a similar model is proposed here.
NZ businesses lose an average $2.2m per deepfake scam as fraudsters impersonate suppliers and clients
Deepfake/AI-enabled fraud · Reported Jul 2026
New detail from Mastercard-commissioned research shows 18% of NZ businesses were targeted by deepfake scams in the past year, with 47% of targeted firms actually deceived — most often by fraudsters posing as customer-service staff, clients or suppliers — at an average cost of $2.2 million per successful scam.
Why it matters — Sharpens the earlier consumer-focused deepfake story into a B2B/vendor-fraud and business-email-compromise angle, directly relevant to commercial-banking fraud controls, payment-verification workflows for supplier changes, and corporate customer education programmes.
Thai authorities report mule-account numbers down 83.67% and related transaction volumes down more than 81% after closing over 351,000 accounts and freezing more than 3.6 billion baht, alongside roughly 29,000 arrests, as part of a coordinated crackdown on the financial infrastructure behind online scam networks.
Why it matters — A benchmark for what's achievable when a country pairs aggressive account-closure powers with cross-agency coordination — useful for NZ's own mule-account detection efforts, and a reminder that disrupting Southeast Asian scam networks reduces upstream risk feeding into NZ-directed scams.
The Sixth Circuit Court of Appeals affirmed dismissal of a lawsuit alleging PNC Bank facilitated an investment adviser's multimillion-dollar fraud, ruling the bank owed no duty of care to non-customers and that the fraud claims lacked the required specificity.
Why it matters — Sits in tension with a separate ongoing US elder-fraud case against another bank where a court let the claim proceed — together they show US courts drawing inconsistent lines on when a bank's transaction-monitoring failures create legal exposure, a live question for NZ courts and regulators as local scam-liability expectations firm up.
A Kenyan court upheld an award of roughly Sh350,000 to a customer whose account was emptied by unauthorised mobile withdrawals, rejecting the bank's appeal and holding that correct PIN entry does not absolve a bank of liability once it has been alerted to a suspected scam.
Why it matters — A distinct case from an earlier Kenyan SIM-swap liability ruling — reinforces a broader judicial trend of rejecting 'correct credentials' as a complete bank defence once fraud has been flagged, relevant to how NZ banks frame their own scam-response and post-notification obligations.
Singapore's Anti-Scam Centre and five banks use automation to block $38m in scam losses over two months
Real-time scam intervention · Operation ran 1 May-30 Jun 2026, announced 7 Jul 2026
Singapore Police's Anti-Scam Centre, working with DBS, UOB, OCBC, Standard Chartered and GXS, used robotic process automation to disrupt over 600 scam attempts and avert more than S$38 million in potential losses during a two-month joint operation.
Why it matters — A concrete operational model for public-private real-time scam disruption at the point of transaction, rather than post-loss reimbursement — a useful contrast for NZ's Anti-Scam Alliance work and banks weighing investment in automated intervention versus after-the-fact liability schemes.
Slower-burning structural risks and trends worth getting ahead of — technology, resilience and governance.
Emerging risks & trendshigh
Fed model-risk overhaul leaves generative and agentic AI outside formal bank oversight
AI governance and model risk · Guidance issued 17 Apr 2026; coverage-gap debate continuing through Jul 2026
The US Federal Reserve, OCC and FDIC's revised model-risk management guidance, which replaces a 15-year-old framework and lets banks scale governance to model materiality, explicitly excludes generative and agentic AI from its formal scope, leaving institutions to build their own parallel controls. Commentators — including the Fed's own vice chair for supervision — have flagged the resulting coverage gap around autonomous decision-making, hallucination and prompt injection.
Why it matters — A flagship regulator has effectively conceded it cannot yet write prescriptive rules for the fastest-growing category of bank AI deployment, meaning boards and risk committees — including at NZ banks tracking global best practice — must self-police agentic AI use in lending, KYC and advice pending sector-wide standards.
Ransomware attacks on financial institutions accelerate sharply into 2026, industry report finds
Cyber threats and third-party risk · Report released Jun 2026, trend data through Q1 2026
Cyber-risk analytics firm Black Kite's latest financial-services report finds ransomware incidents against the sector rose roughly 30% between 2024 and 2025, with Q1 2026 alone up about 76% on the same period last year, while the pool of vendors carrying critical unpatched vulnerabilities has grown sharply — including a case where attackers used stolen privileged credentials to move laterally across dozens of interconnected institutions via a shared vendor.
Why it matters — Confirms ransomware and vendor-supply-chain compromise are compounding rather than separate risks, reinforcing the case for NZ banks and regulators to treat third-party concentration and credential hygiene as a single resilience problem rather than two.
AT&T and Palo Alto Networks launch quantum-resilient network security fabric aimed at 'harvest now, decrypt later' threats
Post-quantum cryptography · Published 16 Jul 2026
AT&T Business and Palo Alto Networks have launched a jointly built quantum-resilient secure network service that combines hybrid post-quantum cryptography with automatic algorithm updates, explicitly targeting attackers who harvest encrypted traffic today to decrypt once quantum computers mature, and framed partly as a compliance play for sectors facing tightening resilience rules such as banking.
Why it matters — Signals post-quantum protection is moving from bespoke bank-by-bank pilots into off-the-shelf telco/security-vendor products, giving smaller institutions — including NZ banks without in-house quantum programmes — a more accessible path to crypto-agility ahead of global migration deadlines.
LSE data show climate litigation increasingly targeting banks and insurers directly, with insurers now suing governments
Climate risk in financial services · Ninth annual snapshot, covering 2025 through May 2026
New data adds to earlier warnings from European regulators: the London School of Economics' ninth annual global climate litigation snapshot counts financial institutions and state-owned enterprises as defendants in at least 42 climate-related cases filed in 2025, and identifies a new trend of insurers themselves suing governments to recover climate-related losses.
Why it matters — The emergence of insurers as claimants — not just defendants — against governments is a new twist that could reshape how financial institutions weigh climate litigation exposure in scenario planning and disclosure, relevant as NZ debates the scope of its own mandatory climate-disclosure regime.
ECB supervisor warns bank operational resilience must address AI-era third-party and geopolitical tech dependency
Operational resilience and third-party concentration · Speech delivered 3 Jun 2026
ECB Supervisory Board vice-chair Frank Elderson argued that European banks' heavy reliance on external technology, cloud and financial-infrastructure providers is now a geopolitical as well as operational vulnerability, citing a cyber-resilience stress test across 109 banks where roughly three-quarters of identified gaps have since been remediated, and pointing to a 2023 ransomware attack on a major bank's New York branch that needed a courier delivering data by USB stick as a cautionary tale.
Why it matters — Extends cloud-concentration concerns beyond a single provider outage to broader strategic dependency — a lens NZ regulators may increasingly apply given recent local findings on bank outsourcing-policy breaches and multi-day SaaS outages affecting NZ wealth managers and banks.