"It does appear in this case the rules were not followed," Willis said.
She said the charter was "explicit" that members should "refrain from any public communications relevant to monetary policy following receipt of MPC briefing papers".
Orr had received papers for the meeting the day before the panel discussion, although the Reserve Bank said he had not accessed or read them by the time he appeared on the panel.
"The papers were submitted to our secure portal at midday on Thursday 29 September. The Governor was at an offsite meeting all day and did not access the papers until the evening of the 30th of September – noting the engagement was at 2am on the 30th so had not read any of the material before his engagement," a spokesman for the Bank said.
The spokesperson said the remarks "did not relate to current New Zealand monetary policy".
While the Bank said Orr's comments did not relate to current New Zealand monetary policy, Orr mentioned "monetary policy" twelve times over the course of a relatively brief panel discussion.
Willis said the episode raised questions about the enforcement of the bank's charter.
"The charter exists for a reason which is to provide clear transparent rules to hold the Monetary Policy Committee accountable," Willis said.
She said that if the "minister and the bank no longer think the wording of the charter is wording they are going to enforce then they need to openly and transparently change the wording of the charter".
Orr has found himself at the centre of a political scrap between Labour and National, with National wanting a review into the Bank's Covid response.
Orr's term is up for renewal before the election. National said he should not be reappointed for another five-year term, but instead be given a 12-month extension to his term, allowing them to appoint a governor should they win the election next year.