
Tech Suite | New Zealand’s digital banking future with Dosh co-founder Shane Marsh
09/16/24 • 17 min
In this follow-up episode, Partner Jeremy Muir from MinterEllisonRuddWatts’ Financial Services team, reconnects with Shane Marsh, co-founder of Dosh, to discuss the recently released Commerce Commission market study report on personal banking services (Report). They explore its potential impacts on the banking industry and share insights into the future of digital banking in New Zealand.
[01:22] Jeremy and Shane discuss the key finding of the report; that New Zealand's personal banking services sector lacks competition. They delve into the underlying reasons for this issue and highlight the main takeaways from the Report, particularly from a digital banking perspective.
[03:58] They discuss the need for “maverick” providers in the personal banking industry and which industry providers might be best placed to be fill that void in New Zealand.
[07:10] Shane highlights Monzo, a digital banking trailblazer from the UK, as an international example of a “maverick” and market disruptor. He explains how their tech-driven, digital-first banking model has enabled them to successfully challenge traditional banks.
[08:30] Jeremy and Shane then explore the Reserve Bank's role in promoting competition in the personal banking services sector. Shane argues that capital thresholds for new entrants should reflect the applicant’s risk profile, suggesting that smaller, digital-only banks with lower risk should have reduced capital requirements to encourage innovation and competition.
[11:15] Jeremy and Shane acknowledge the government's quick response to the Report and consider what in practice this means for the market.
[13:52] They discuss the Select Committee inquiry that is now underway and how it provides an opportunity for industry participants to support meaningful change, noting the deadline for submissions of 25 September 2024
[15:51] Shane closes out the interview sharing his insights into the future of personal banking in New Zealand, noting the dawn of a new digital banking era is now underway.
Information in this episode is accurate as at the date of recording, 11 September 2024.
Please contact Jeremy Muir or our Financial Services team if you need legal advice and guidance on any of the topics discussed in the episode.
Please get in touch if you have any feedback. Don’t forget to rate, review or follow MinterEllisonRuddWatts wherever you get your podcasts. You can also sign up to receive technology updates via your inbox here.
Additional resources
New Zealand’s digital bank revolution with Dosh co-founder Shane Marsh
Commerce Commission: Personal banking services market study – Final report 20 August 2024
Select committee: Inquiry into banking competition – Submissions due 25 September 2024
For show notes and additional resources visit minterellison.co.nz/podcasts
In this follow-up episode, Partner Jeremy Muir from MinterEllisonRuddWatts’ Financial Services team, reconnects with Shane Marsh, co-founder of Dosh, to discuss the recently released Commerce Commission market study report on personal banking services (Report). They explore its potential impacts on the banking industry and share insights into the future of digital banking in New Zealand.
[01:22] Jeremy and Shane discuss the key finding of the report; that New Zealand's personal banking services sector lacks competition. They delve into the underlying reasons for this issue and highlight the main takeaways from the Report, particularly from a digital banking perspective.
[03:58] They discuss the need for “maverick” providers in the personal banking industry and which industry providers might be best placed to be fill that void in New Zealand.
[07:10] Shane highlights Monzo, a digital banking trailblazer from the UK, as an international example of a “maverick” and market disruptor. He explains how their tech-driven, digital-first banking model has enabled them to successfully challenge traditional banks.
[08:30] Jeremy and Shane then explore the Reserve Bank's role in promoting competition in the personal banking services sector. Shane argues that capital thresholds for new entrants should reflect the applicant’s risk profile, suggesting that smaller, digital-only banks with lower risk should have reduced capital requirements to encourage innovation and competition.
[11:15] Jeremy and Shane acknowledge the government's quick response to the Report and consider what in practice this means for the market.
[13:52] They discuss the Select Committee inquiry that is now underway and how it provides an opportunity for industry participants to support meaningful change, noting the deadline for submissions of 25 September 2024
[15:51] Shane closes out the interview sharing his insights into the future of personal banking in New Zealand, noting the dawn of a new digital banking era is now underway.
Information in this episode is accurate as at the date of recording, 11 September 2024.
Please contact Jeremy Muir or our Financial Services team if you need legal advice and guidance on any of the topics discussed in the episode.
Please get in touch if you have any feedback. Don’t forget to rate, review or follow MinterEllisonRuddWatts wherever you get your podcasts. You can also sign up to receive technology updates via your inbox here.
Additional resources
New Zealand’s digital bank revolution with Dosh co-founder Shane Marsh
Commerce Commission: Personal banking services market study – Final report 20 August 2024
Select committee: Inquiry into banking competition – Submissions due 25 September 2024
For show notes and additional resources visit minterellison.co.nz/podcasts
Previous Episode

Tech Suite | Consumer data rights: A focus on open banking in New Zealand
In this follow-up episode Special Counsel, Sonya Forbes and Senior Associate, Suzy McMillan both from MinterEllisonRuddWatts’ Corporate and Commercial team, continue their discussion on the status of consumer data rights in New Zealand.
In their last episode, Sonya and Suzy provided an insightful overview of the recently released Customer and Product Data Bill. In this episode they focus on the evolving open banking ecosystem in New Zealand, examining how it is being shaped by both regulatory and industry-led initiatives.
[01:14] Suzy begins by recapping that New Zealand is in the process of developing its own statutory framework for consumer data rights, through the Customer and Product Data Bill (Bill). She notes that the Bill is currently progressing through parliament, but its finalisation and implementation as law could take some time.
[01:45] Sonya discusses what is occurring in the marketplace in the meantime, noting that implementation of a consumer data right has begun in the banking sector, on a voluntary, industry-led, basis with “open banking”. She explains the concept of open banking and how it works in practice.
[03:45] Sonya talks through the main open banking industry-led initiative; the development of Application Programming Interfaces (API) and API standards to facilitate data and payment sharing.
[04:25] Sonya then discusses the role of Payments NZ’s involvement in developing API standards and the Minimum Open Banking Implementation Plan, which New Zealand’s five largest banks (ANZ, BNZ, ASB, Westpac and Kiwibank) are expected to comply with by certain specified dates.
[05:52] Suzy and Sonya consider the challenges fintech’s face when trying to integrate with banks using APIs, in the absence of regulation. They explain that due diligence and time-consuming bilateral agreements are needed to support data sharing, but that the process will be simplified through standards and regulations under the Bill once it is passed into law.
[11:20] Sonya considers how the Commerce Commission has been involved in supporting open banking, noting the importance of three key decisions it has released this year. She discusses with Suzy the interplay between the Commerce Commission and Ministry of Business, Industry and Employment (MBIE) in the development of a consumer data right and the lessons they’ve drawn from overseas experiences.
[17:16] Sonya and Suzy lastly discuss MBIE’s consultation process on designations for both the banking and electricity sectors, noting the submission closing date of 10 October 2024.
Information in this episode is accurate as at the date of recording, 9 September 2024.
Please contact Sonya Forbes or our Corporate and Commercial team if you need legal advice and guidance on any of the topics discussed in the episode.
Please get in touch if you have any feedback. Don’t forget to rate, review or follow MinterEllisonRuddWatts wherever you get your podcasts. You can also sign up to receive technology updates via your inbox here.
For show notes and additional resources visit minterellison.co.nz/podcasts
Next Episode

Tech Suite | Overseas suppliers: When do New Zealand businesses need to understand GDPR?
In this episode, Partner Tom Maasland and Senior Associate Libby Conole from our Technology team discuss the impacts of EU General Data Protection Regulation (GDPR) on New Zealand businesses working with overseas suppliers. They explain why GDPR really matters in the New Zealand context, and how best to navigate related contractual terms.
[01:30] Tom and Libby begin the episode by considering what GDPR is, and why it matters to New Zealand businesses, particularly when dealing with overseas suppliers.
[03:14] Libby talks through the GDPR's impact for New Zealand businesses, noting the GDPR’s distinction between data controllers and processors and how this differs from New Zealand’s privacy law concepts.
[04:30] Tom and Libby discuss GDPR Article 28, how it requires contracts to be put in place where data processing occurs and specifies certain obligations that must be contained in those contracts for data protection purposes.
[06:50] Libby then explains the relevance of these obligations for New Zealand businesses when dealing with an overseas company and their standard terms of trade, offering valuable practical advice on how to deal with such clauses.
[10:11] Libby and Tom lastly discuss GDPR standard contractual clauses and their role in ensuring data protection across borders. They consider how New Zealand businesses are affected by such clauses and how they should navigate them in practice.
Information in this episode is accurate as at the date of recording, 18 September 2024.
Please contact Tom Maasland, Libby Conole or our Technology team if you need legal advice and guidance on any of the topics discussed in the episode.
Please get in touch if you have any feedback. Don’t forget to rate, review or follow MinterEllisonRuddWatts wherever you get your podcasts. You can also sign up to receive technology updates via your inbox here.
For show notes and additional resources visit minterellison.co.nz/podcasts
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