Financial Markets Conduct (Climate-related Disclosures – Citibank N.A.) Exemption Notice 2024

The Financial Markets Conduct (Climate-related Disclosures - Citibank N.A.) Exemption Notice 2024 (Notice) exempts Citibank N.A (Citibank)  from the requirement, to keep climate related disclosure records and produce climate statements pursuant to Part 7A of the Financial Markets Conduct Act (Act).

The exemption will cease to apply if any of the following events take place (Termination Events):

1. Citibank becomes a climate reporting entity for any other reason than being a registered bank under paragraph 461O(1)(b) of the Act; or
2. Citibank commences offering investment or deposit products to persons in New Zealand which are materially different to its current business offerings, such that the new business would be likely to accrue New Zealand domiciled primary users; or
3. Citibank’s New Zealand branch commences a retail business in New Zealand.

The exemption is subject to the following conditions:

1. Citibank will procure that its parent company Citigroup Inc. will publish annual climate statements in relation to its group companies (which includes the Bank’s New Zealand branch);
2. Citibank must include in its disclosure statement the relevant information (detailed below);
3. Citibank must lodge with the Registrar a notice containing the relevant information within 4 months after the end of an accounting period in respect of which Citibank relies on this exemption;
4. The Bank will report to the Financial Markets Authority(FMA):
   1. details of when and where the parent company’s group climate statements have been published
   2. Any change of the bank’s status that might trigger a Termination Event;
   3. Within 10 working days of any Termination 

The Relevant information is:

1. a statement to the effect that it is relying on the exemption in respect of the accounting period; and
2. a brief summary of the effect of relying on this exemption; and
3. the address of (or a link to) the website where a copy of the group climate statements can be accessed.

The key reasons for granting the exemption (as set out in full in the Statement of Reason in the Notice) are—

• The number of existing primary users of Citibank’s New Zealand branch is small and of those users, very few are domiciled in New Zealand.
• Citigroup Inc voluntarily prepares climate-related disclosure statements (global statements) in respect of its global business (which includes Citibank’s New Zealand Branch), demonstrating responsibility and foresight in its consideration of climate issues, which is a key goal of the New Zealand climate-related disclosures regime (CRD Regime).
• The costs of compliance with the CRD Regime in New Zealand are disproportionate when considering the small number of existing New Zealand domiciled primary users and the potential benefit those few users may obtain from any New Zealand only climate statements.
• Although not directly comparable to other climate reporting entities in New Zealand, Citibank’s primary users will be able to obtain certain information from Citibank’s parent company’s global statements in respect of the management of climate risks and governance at a group level.
• The notice has been granted for a limited term to allow the FMA to monitor developments in mandatory global climate reporting requirements and including the development in reporting globally on scope 3 emissions  

Download Financial Markets Conduct Climate related Disclosures Citibank N.A. Exemption Notice 2024 [PDF 280KB]