Responsive – Part 1

Richard Philp, Raelene Stewart

Inland Revenue

Ian Caplin: Kia ora and welcome to the programme. You’re watching G-Reg, the Government Regulatory Practice Initiative. My name is Ian Caplin, and if you’re new to these webinars, this is episode three in a series of 10 webinars, that, taken together form the G-Reg conference for 2020.

This as I say is webinar episode three and if you haven’t watched episodes one and two, you will have an opportunity to catch up with those, and more on that in just a little bit.

The Government Regulatory Practice Initiative is the world’s first and only cross government user network, professional user network, for those who exercise the powers of the state, whether they’re coercive, facilitative or anything-ive.

This year is in fact G-Reg’s sixth conference year, but the first that we’ve devoted entirely to webinars over October and November.

Today is episode three and we’re looking at Responsiveness. The overall theme, the umbrella story arc of the 10 in the series, is the modern regulator.

In this episode, and in the next one, we concentrate on what it means to be a responsive regulator and, in this context, we’re very much focusing on being responsive, in the sense of being agile.

We pick up on themes that we developed in the first two episodes. In episode one we looked at what it meant to be a regulatory entrepreneur, and in episode two, we followed further to look at a collaborative regulator. What does it mean to be a collaborative regulator working across and beyond government?

And in this episode we develop that further, but you don’t actually need to have seen those first two episodes to appreciate this one, it’s rather like Star Wars. You can watch episode three – Return of the Jedi – without actually having to watch The Empire Strikes Back, and a New Hope first. And for those of you who have seen the previous episode, you’ll be relieved to know perhaps that that’s the last time in this series that I’m going to use a Star Wars allusion and therefore in episode four, when we come to it next week, it will in fact be perhaps something of a ‘new hope’!

Well, amid any of the groans for those of the Star Wars aficionados in the audience, I’m going to switch to a slightly different metaphor, that of the Olympics and the decathlon, because we are, as I’ve said, a G-Reg series of 10, and the third event in the decathlon is the shotput, and our next guests are very much in that league, because it’s not a stretch of metaphor to say that what they’ve done is really picked up quite a heavy object, got it airborne, put it forward and actually taken it somewhere. That’s because they were looking at the Small Business Cashflow Loan, working at Inland Revenue New Zealand.

Our next guests are Richard Philp and Raelene Stewart and I’ll introduce you to them more fully in the moment. They work at Inland Revenue and they were working on the Small Business Cashflow Loan in the context of being compelled to do so by the Covid situation and the legislation that produced it. Inland Revenue administers that scheme. And so it’s not just a tax administrator. It is also a lender.

I would just add also that G-Reg is based here in New Zealand. But, I’m very aware that there are a number of registrants who are international in their position and therefore, though, we’re looking at 11 O’clock New Zealand Daylight Time over a cup of tea, perhaps and a slice of cake, it may well be that you’re looking at this from a different time zone or in fact on the recorded version of this webinar, wherever, or whenever you are I make no apology each episode to say, every time, you’re very welcome here.

And I do also say that all of these webinars in a series of 10 can be accessed at any order that you prefer. They’re self-contained, but they also interlink as part of the story arc.

So how did Inland Revenue demonstrate the agility, the sort of entrepreneurialism that we’ve touched on in episode one, the sort of cross government on collaboration that we looked at in episode two.

How are they dealing at the moment? And how have they dealt with the responsiveness of being a regulator?

That we deal with in this episode three in the context of a small business cash flow scheme.

I hand over to Richard and Raelene in just a moment, but before I do so,
members of the audience, it will be open to you to ask them questions once they finish their presentation using the Q & A function at the bottom of the screen.

But please don’t be shy in filing your questions, or indeed your comments in advance of their finishing the presentation and I hand over Richard and Raelene to you now, a very warm welcome to you both, and over to you.

Richard Philp: Thank you Ian for that introduction, much appreciated. As people might see I’m based in Auckland, the city of sails boldly displayed behind me. My role in Inland Revenue is that of a customer segment lead.

I’m responsible for the micro business and not for profit segments and Inland Revenue has five customer segments that we operate from a structural point of view. The micro business and not for profit has about 1.5 million customers and represents business operators mostly who are small operators. So they have six or less employees or they have essentially a million dollars or less annual turnover and GST. As you’ll see, as Raelene and I step through this very short presentation, pretty much the applicant base or the profile of applicants for the Small Business Cashflow Loan Scheme, were in fact represented by micro businesses, and that’s the nature of the engagement that we had. So I’ll just share my screen now and bring up essentially a presentation for you.

So with the Small Business Cashflow Loan Scheme, pretty much, it was a government initiative as you would appreciate with the challenges that New Zealand was experiencing, particularly during the course of levels three and four, which pretty much closed a lot of businesses overnight by virtue of the lockdown process. So, the requirement for Inland Revenue was to pretty much shift, it’s, it’s core functional focus from collecting or being the primary revenue collection point for the government and moving towards being a formal lender of money, so it was definitely a stretch from the point of view of the organizational culture and also for many of the people who were involved in the mobilising of the Small Business Cash Loan Scheme. People at an operational level were typically used to collecting debt, or in fact auditing filed returns. And so that was definitely a challenge in relation to some of the psyche for those involved in it.

A key thing also is around the fact that we mobilised very, very quickly, a group of people across both policy experts, systems designers and operational delivery experts.

And pretty much that early intervention and engagement process across a set of knowledge and those involved did result in a much more cohesive fit between all of the design elements.

A number of the participating organisations, as mentioned in the slide, Treasury, MBIE, our Ministry of Social Development, all acknowledged the benefit of getting the right group of experts together at the onset and the value of that made for a very deliverable scheme in the end.

The other thing worth mentioning is that the conditions in which the construction of the scheme occurred was pretty much unprecedented from
any of our past experiences for Inland Revenue at that time. We were in the midst of a major release. We were converting a number of tax types or products from an old system into a new system.

Many of the participants, if not all of them, were working from home at the time and we were also preparing for our second year of our auto calculation process, which is where all salary and wage earners have an assessment issued by the Commissioner directly, and with all of those things occurring at the one time it was certainly a stretch for the organisation to pick up a fundamentally new product and basically mobilise its delivery in a very, very short space of time.

We were certainly tested in terms of the flexibility and robustness of our new system and actually tested it in ways we had not done before and it did prove to be effective and we certainly on reflection, know that we could not have done what we did with our previous legacy system.

It was a very, very great success in terms of the speed in which we brought things together.

Richard Philp: Just looking at the second slide.

Slide three. Some of the interesting things there were around the fact that, as you can see, the scheme was designed, and targeted small employers and self-employed, particularly for

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self-employed people, the scheme was useful from the perspective of, it gave them a loan of $11,800 as a maximum.

We reshaped our approach to our online services, our My IR account portal to act as both an application tool, as well as a tool for the loan recipient to manage their loan, once received, and this was particularly important for when borrowers started to wish to pay back or repay the loans. We also knew basically the critical thing was the speed of getting the loans out into the hands of impacted businesses and that was a real pillar for success. We knew businesses overnight had stopped receiving
their expected incomes, but they still had many fixed costs and the accessing of the loan for those that particularly don’t necessarily have a very deep level of cash reserves meant the difference between them paying fundamental bills and not being able to pay them, so it really impacted successfully on those that were pretty potentially viable, but pretty vulnerable at that point in time.

One of the things that we wanted to do with the design of the loan scheme, as I mentioned, was to get money out as quickly as we possibly could into the hands of impacted businesses.

But we’re also very conscious of not having too many hurdles for applicants to overcome and the notion of a high trust model was very uppermost in our minds, and by the same token, we also wanted to make sure that we maintained at a broad level, the integrity of the scheme. We didn’t want the scheme to be abused and then lack credibility, both in terms of the communities’ eyes and also as our primary stakeholder, the government. So being able to process most applications through an online process was pretty much the success or failure for us as we could not have supported a very, very manual process and it would have impeded the speed at which loan applicants received their money, and pretty much a lot of them received – successfully applied and received – the pay out of their loan within 24 hours. So it was a remarkable outcome in terms of the responsiveness, which is the theme of the sessions that you’ve joined. The eligibility criteria was quite important for us.

And in that sense, we just wanted to make sure that the application process did in fact have some filtering from an integrity perspective. What we did see in the end, was that through having an online process, we successfully, as at the end of Friday of last week, we had dealt with 104,465 applications online.

And at that point, we’d only had to deal with 258 manual applications. So as I mentioned earlier, that was the kind of pillar of success or failure for us, we certainly could not have dealt with the level of applications had it been a very manual process.

I’ll just hand over now to you, Raelene, in terms of the remaining slides.

Raelene Stewart: Thank you Richard. Kia Ora Koutou everybody, my name’s Raelene Stewart, and I’m a group lead and the micro and not for profit customer segment which Richard is from, and I’m currently the business lead for the Small Business Cashflow Loan Scheme, lucky enough to get that job, working for Richard.

So, I guess, monitoring and reporting, what actually happened. And you can see there on that first bullet point from the get go, we opened on 12th of May and, in actual fact, we were working right up to the night before to make sure that the system was all set to go, testing and everything, so right up until midnight, on the 11th of May, we were making sure that things would tick over as required, and as luck would have it, the system went live, and, I think, if you think about the economy at that time, the state for small businesses and people waiting desperately, because they knew that the small business cashflow loan was coming, you can see there that 600 applications were made within the first hour and 20 minutes of the scheme going live, and in actual fact 14,000 applications there on the very first day we opened. As Richard already mentioned, you know, 99% of all applications were processed online. There’s no way that we could resource individual applications of that scale in the timeframe that we had. And, you know, fortunately for us, our system was built to streamline that process based on the high trust model that Richard alluded to, and as a result we obviously had those applications pouring into our system and most of them paid out within 24 hours, and certainly customers were amazed at that fact.

So, the system is geared to, as long as the customers met the eligibility criteria that was programmed into that and the application was able to be processed quite smoothly and straight out, into bank accounts overnight. So in terms of the customer base, over 50% of borrowers are sole traders and other employers with less than five employees, so 68% of borrowers are in actual fact companies and with our reporting tools, which I’m going to show you on the on the next slide, we can actually drill down into specific industry areas and into quite a level of detail if we needed to, in terms of identifying that customer base. So you can see there, the majority of borrowers, so 41%,were from the greater Auckland region, and that was closely followed by Christchurch and then Wellington equally with high level applicants that there was also right around the country – applicants, you know, in various levels in a broad range of industries. So the construction industry stands out, I guess, because, you know, we can see there that 17% of total loans are paid out to them, followed by the accommodation and food services, and we know that from historically, looking back at the impacts of Covid on those types of industries, then, you know, it sort of aligns with where the country was and in terms of the customer base that were highly impacted. So most of our borrowers have been in business for more than five years at the time that they made the application for the loan and we did of course, have businesses that had actually been in shorter periods of time or companies, etc. People operating outside the system, who actually came into the system as a result of the finance available from government to help them, you know, get through the Covid times. So Richard, do you want to move on to the next slide for me, please.

Richard Philp: There we go.

Raelene Stewart: So that’s a snapshot of our reporting and so all of this information is pulled from our data and analytics and you can see there at 9am on the 16th of October that we hit 104,723 applications for loans totalling $1.7 billion applied for and 97,148 applicants had actually had their loans approved and that equated to around the $1.5 billion.

As Richard’s already mentioned, you can see from the top left box there, that the total loan applications received in the cumulative view, that top line there, are showing the number of applicants that actually came via e-services.

The customers actually had to have registered in My IR and be the owner of that account in order to apply for a loan, and that was one of the validation criteria that we had in place to help ease customers through, so they didn’t actually have to make phone contact with us unless they needed to. We did have a manual application process. And you can see on the bottom line, there, 258 applications that came through throughout the, the period of the loan through to last Friday and you can see, disproportionately there, the majority of those applications had come through online.

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I guess the data, this is really interesting, because all of this information comes from our core reporting system, and as we’ve obviously updated through the different stages and Richard alluded to that in the beginning, around business transformation.

All this information is actually data that we hold within the system. And there are another two or three layers below this, we’re only showing you the front version on this slide, but we can actually drill down to the customer demographics, the number of loan applications in particular industries where they have been declined, or what the volume of applications in particular industries or demographics are, that are trending currently [inaudible] our system is actually live and in real time. You can also see those circles at the bottom of that slide around the wage subsidy indicator. So one of the things that we had to do was ingest information from MSD because the small business loan and the wages subsidy are actually inextricably linked. So if you’re eligible for the wage subsidy up to 50 FTE equivalent you’re in business, then you’re actually, you are eligible for the small business loan. And so it was helpful for us and for customers, especially when applying online that we already had that information from MSD if they had applied for a wage subsidy and we’ve approved that, and what that amount was, that we could
pre populate our system through that data with the number of FTE’s that they had, and that sort of helped to streamline that process, but it also helped us to identify those customers who were outside those parameters and so they would get stopped, obviously.

And [inaudible] the bottom right hand corner, the registration and error review, so with the number of applicants that came through and through our validation criteria that we had built in behind the small business loans scheme, we were able to identify those customers that we might have wanted to get further information from to test their eligibility, and we can also see in that coloured circle total applications received by segment, because we operate, you know, in a customer segment environment, as Richard alluded to earlier, we can see there, where the majority of customers the loan applications are actually received from, and so of course in our segment, micro, we’ve got 56%, and the small and medium enterprises, we’ve got 27%, and we’ve even got some customers and families segment there, and you can’t see the other ones, but they are like individuals and that type of thing. So you can see, also the FTE band indicator.

Just the number of employees of the loan applicants and you know sole traders here, far, far outweigh all the others. And then obviously the – you know, less than five employees the next biggest, so can see actually as you get up in those higher areas, the high FTE numbers, that not a lot of those enterprises, small to medium enterprises, etc. were applying for the loan. This information also tells us, you know, who, who is actually repaying their loans, and we’ve got a little graph there to the right, so, which was just shy of $30 million, have been repaid and loans currently of those who’ve actually borrowed from the cash flow loan scheme. So I think we as an organisation, IR, this information is really rich and valuable for actually other agencies that are involved or linked in with the Small Business Cashflow Loan Scheme, for example, Treasury, we share these reports with the Ministers; the Minister of Revenue, the Minister of Finance.

It helps them to understand what the demographics are around the country and help them to make decisions. So it’s not just IR information we use that broader and broader context right across, you know, the different agencies involved in the Covid activity.

So I think that’s about it from me and I’ll hand back to you Ian.

Ian Caplin: Thank you very much, Richard. And thank you very much Raelene. Excellent presentation. Members of the audience, now is the time as I can tell, telepathically almost, that you’ve been thinking about this, to fire your questions and to file your comments and now’s the time that I make a special declaration of interest, which is this, I actually work at Inland Revenue in my substantive role, and I worked very closely with Richard and Raelene on this particular project, so I’ve got a truckload of questions, so please file yours so you can nudge me out of the way, because this is a really good story. And I think from very kind of G-Reg purposes, in terms of working better together across and beyond government, there is so much in here.

We probably wouldn’t necessarily see it automatically this way. But this is smacking full of examples of regulatory entrepreneurialism which Professor Jeroen van der Heijden alluded to, and spoke of fully of course
in episode one of this series, and I should just say, members of the audience, that in due course we will have, as I think I mentioned briefly earlier, recorded versions of the entire series on our G-Reg website. But there is a little bit of a lag in that, not least because we want you actually to be here live and participate. Now in terms of the entrepreneurialism, there’s the pre existing relationships that Inland Revenue has across government both within itself, in terms of connection between the operational and the policy units (and I know that you in the audience will have those similar relationships as well) and also the cross agency, in particular with Treasury.

Richard and Raelene, I wonder if I could just go to you first, perhaps, Richard, just to speak of how you leveraged off those pre existing relationships, in this very different, what was, emergency circumstance.

Richard Philp: Our policy people obviously had a very close connection with Treasury representatives to start with.

And I think probably the more compelling thing from us was the fact that people like myself and Raelene who kind of have an operational expertise and those that designed how our account would work within START. That’s what we colloquially call our system, and the interface between that and the My IR portal, that kind of lined up quite nicely.

And then the other overlay was that we needed to realise that the loan was a legally binding contract between Inland Revenue and the lender, so that was a slightly different context for us to have to deal with and thinking about how we would actively manage that. So, that collaboration was a real cornerstone of how it was built quickly and successfully.

Ian Caplin: And thank you for that Richard, and Raelene just coming to you, in terms of relationships with our legal arm and indeed external parties that may be relevant, how quickly was that galvanized because again we were in a hurry, for obvious reasons.

Raelene Stewart: Totally, and I think there was a lot of long hours worked by our legal and policy people in getting us over the line, and in particular our legal people had to engage with an external legal team just around the loan contract because as Richard mentioned, you know, we are not a bank. We’re not a lending institution, we’re actually a tax administration, so quite, quite different for us. So yes, there was a lot of, I guess, work behind the scenes to make sure that we had the right legal documentation.

That’s declarations, because they need to make a declaration when they’re actually applying for that loan.

And then how do we actually administer that from, you know, from a tax administration, and looking at that from a loan, perspective, so we’re very fortunate that the legal team that we had reviewing it, worked quite closely and with us in the operational [inaudible] to make sure that our interpretation and application of the legal framework surrounding that was applied appropriately.

Ian Caplin: And I guess, looking at entrepreneurialism in terms of savvy and in the context of this loan, commercial savvy, I think you both alluded in your presentation, to, if you like, the inherent tension between a high trust model, not because we’re just giving everything away because that’s what Parliament effectively required us with the policy settings that underscored the loan, but also of course integrity, and the classic thing that all of us regulators face whatever walk of life we’re in, which is too much in terms of, if I can put it this crudely : the teeth or too much in terms of cuddles, it’s really that the kind of the resolution of them both. How – and either of you can answer this – or both of you, how did you keep the balance?

Raelene Stewart: I guess I can start, Richard, if you like. We did have to bring our people on the journey with us because, you know, as you’ve mentioned where, you know, we are a regulatory organisation and, you know, it’s in our inherent

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DNA of our people, so we’re not actually giving away money, we’re used to collecting it or, you know, ensuring people meet their, you know, appropriate obligations, rather than handing out money, in terms of a loan and not being too tied up with the intricacies of, you know, of how they’re actually operating, which is what we would do in a normal day in the life of the tax administrator. So that sort of bringing our people on that journey to understand that we were working in a high trust model, what the Government’s intention was, you know, what the intent of the scheme was, you know, New Zealand, the economy and, you know, businesses, struggling. So getting our people over the line from that and at the same time managing the integrity aspects that we were coming across as the loan term, you know, evolved, because we originally had quite limited validations up front and then as our people were telling us of what about – you know, x y and z – that the system is agile enough our, you know, IR system is agile enough that we’re able to quite quickly put in additional integrity measures as those were identified.

Ian Caplin: And I think if I come to Richard on this – briefly, in terms of leveraging on the relationships that were already had, leveraging on the systems that we already had, sometimes, I know the audience will take value from this and some consolation, perhaps in the things that they have to deal with, sometimes being an entrepreneur, those relationships are in fact, hiding in plain sight aren’t they.

Richard Philp: Yes, and just having a common focus helped to surface the issues reasonably openly and it was quite remarkable actually how we had daily stand ups leading up to going live and some considerable time after that, which involved all participants and so leading up to go-live, the surfacing of issues, people would take those away, resolve them, come back with a solution virtually overnight, and so it was quite a, you know, a very speedy process, but still within the context of trying to balance achieving what the government wanted to achieve of getting money in the hands of businesses that needed it, but, not to the extent that, you know, we reduce the integrity of the scheme itself. And one thing, as Raelene mentioned, just internally, we needed to work quite hard around
giving people comfort that near enough was good enough for the purposes of this exercise and sensibly as part of the legal framework, we were able to fold the business cash flow loan scheme underneath all of the
the wherewithal of the Tax Administration Act, so we knew that we would have to come back to deal with some examples of where maybe we didn’t quite get the front end right. And we’re progressively doing that,
because we have the power to deal with the conditions of the loan scheme in a way we would deal with other products that we manage under the Tax Administration Act.

Ian Caplin: Excellent, we’ll hold it there for the moment. Members of the audience, you’re way ahead of me. I was going to say, please do vote on the questions by putting a thumbs up, and you get to see me kind of convulse while I’m trying to watch a thing on the screen, which I’m looking at right now, but you’ve already done that. And by far the lead question – Government BAU often struggle to make changes quickly, but we can do it in emergency situations, the question goes – to you both; what do you see are the barriers that were taken away and removed during Covid that actually could be applied to BAU to basically make it adapt quickly in normal situations. Why can’t we have it in peacetime as well as Covid?

Richard Philp: I think we managed to find cut-through on the bureaucracy and there was a resounding compelling and common driver for all involved. And so, it was quite stimulating to see the positions of some traditional approaches put to one side and we had a common goal and we got on with it.

Ian Caplin: And I think what links to that is really our next question, which is for both of you, pointing to the shift in culture and that’s actually just jumped because somebody’s done a democratic vote and moved the question line, but I pick it up again.

Could you talk a bit more about that? And I think I’d add the word well- being, because in episode eight or nine of the series, we’re going to come to the well-being, not just of regulated parties, but regulators, like us, so the shift in culture and well-being that this threw up. How did you deal with it all?

Richard Philp: I’ll give it over to you, Raelene, we did some communication, things that you can talk through.

Raelene Stewart: You’re correct. We did have to work hard at the communication levels and getting our people to understand what the government intention was.

I think we leveraged off the fact that, you know, we had the Covid environment all around us, regular news reports on what was happening in terms of, you know, business activity or inactivity as a result of Covid, and we leveraged off our environment basically to deliver those messages, but we were quite clear on also telling our people, listen we’re not forgetting our role as a tax administrator, and as you are telling us things we are acting on those and we’re looking into that and then communicating out around what we’re actually doing to tackle the issues that our people were actually having, but I think communication was really key and leveraging off our environment.

Ian Caplin: And I was gonna say really linked to that, perhaps I can invite you to deal with this one question here, how did you identify where to get the critical capability from, as I read it, in short order, while you were also in lockdown?

Raelene Stewart: So it’s actually part of our core business. So we have, you know, IR is made up of a whole lot of different areas of business. So we have our people at front end, so contact centres, we have investigations staff, we have debt and returns staff, we have staff that are there to help customers you know with the normal obligations, and we leveraged off all of those areas and it was a natural fit in with the small business loans scheme. And when we identified key people across the organization very early in the piece, when we had the stand up meetings and making sure the appropriate people were actually there at the table when we’re having those conversations and if they weren’t, bringing them in immediately, because, you know, the broader reach in terms of the capability and I guess we also, we quickly identified areas that we needed to provide resource and material to help our people deal with various scenarios that they were dealing with.

Ian Caplin: And I think I…

Richard Philp: was just gonna say, and I think the

Ian Caplin: over to you Richard.

Richard Philp: From a leverage point of view was, we’ve been working very closely with MSD around the wage subsidy, so we’d taken virtually over half a million calls, or, sorry, 500 million calls from MSD around the wage subsidy and because of the connectivity between the two, many of the people who helped and worked on the small business cash flow loan scheme had a pretty good context to start with.

Ian Caplin: And those links, I guess just make almost more of a seamless transition between the wage subsidy. As the screen wanders away from me in terms of the Q and A, one of the questions, just arcing it back to first base, what was the genesis of the idea to provide loans or what led to IRD providing this support when it isn’t IRD’s original purpose? Was it suggested by ministers and officials?

And the answer to that, I think I’ll just also tack on, I would like you to tack on; how agile a move was it for you to perform without needing spandex?

Raelene Stewart: I mean, as I understand it, so policy were the central coordinate as sorry not policy, Treasury were the central coordination agency and so they had representatives from the different agencies there around the table, our policy folk.

And it was really about who could actually do this and do it quite quickly and who had the capability and the tools, etc. And because IR, you know, spent millions of dollars in our business transformation program, and that we actually had the capability to actually build this quite quickly and deliver it. I guess that was the impetus of it, Richard?

Richard Philp: I agree.

The driver was a government initiative, I think part of it was also the uptake with the loan process through banks as it was, was quite small and so the notion of the loan scheme was to give

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access to funding in a loan context but unsecured, and therefore deal with it in a much more widespread way than was achieved through the original plan. That was my recollection.

Raelene Stewart: And I think that because the smaller businesses don’t have the ability to get the money from the bank because they want some security, it was why one of the reasons around that under 50 FTE cap was there. It was actually deliberately for those smaller businesses who couldn’t get other financial support.

Ian Caplin: And it finds itself in a particular place. I guess just looking forward, and the question here, which I think is, is a nice place as we draw towards a close.

Are there one or two key learnings the organisation’s taking forward into future planning really as a result of this very interesting experience?

Richard Philp: I’ll start and you can add in, Raelene, I’m sure.

Ian Caplin: One each.

Richard Philp: One of the realities, is that it did prove the investment in a new system, even though it is an off the shelf product, it showed the flexibility and its ability to be designed effectively. And I think the other thing that made a difference was that most of our challenges with transitioning out of an old system to a new one has been around dragging through legacy information. This was an entirely new product. So we didn’t have anything from a conversion perspective and it was basically entirely fresh and didn’t bring with it some of the complications of history.

Raelene Stewart: And I guess from, from my perspective, the importance of that cross agency interaction of everybody dealing with a common, you know, common goal. There for a common purpose and able to work in with each other because obviously that information that we got from MSD, the data that we ingested into our system actually just sped up everything. Everything went quite quickly anyway, but it just added to all of that in terms of that efficiency and conversely back the other way, when we were helping out with the wage subsidy, going on around verification activity for MSD, I think that coordinated approach, it’s definitely, you know, we’re all working for a common goal – that does help.

Ian Caplin: Raelene, Richard, thank you both very much, an excellent presentation and thank you to the audience for a wealth of wealthy contributions and lots to think about and talk about there. Lots to rewire what it means to be a modern regulator. The notion of responsiveness which we very well discussed today in terms of agility, we continue that discussion next week in our responsiveness panel in terms of perhaps more the range of discretionary powers that we have, do please take a look at that. Do please take a look at the website and also if you are interested in taking part in any of the G-Reg qualifications, the website in turn has a wealth of detail on that. I was wrong to use a Star Wars analogy. The only decent thing that happened in terms of throwing in episode three was when Darth Vader threw the Emperor off the Death Star at the end. The better analogy as these 45 minutes have definitely shown is the shotput Olympian analogy, because I think we’ll all agree that an Olympian task has been successfully performed by our guests and their colleagues. And with that, members of the audience, I leave you. Until next week, stay well. And until next time ka kite ano, thank you very much.

ENDS