In a regime based on disclosure, unexpected, unpredictable and arbitrary outcomes would not be seen as a ‘fair game'. Further, the more we looked at the issues the more we, the regulator, became fixed with knowledge as to the inadequacies of branch-based disclosure. Secondly, disclosure regimes differ markedly between countries.
In some cases, the level of public disclosure by banks branching into New Zealand would be inadequate to found a presumption that depositors could be informed as to the condition of the bank. Indeed branch accounts built on the notion of branch capital can be inherently misleading.