Submissions
We contribute to regulation and public policy consultations that affects our members and their customers. You can download our completed submissions categorised by topic below.
- Credit Contracts and Consumer Finance
- Reserve Bank
- Insurance
- Climate Change and Transport
- Insolvency Act 2006 and Partnership Law Act 2019 Review
- Consumer Data Right
- Fair Trading Act
- Conduct
- Privacy
- Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT)
- Payments
- Advertising
- Non-bank deposit takers
- Education
- Financial Advice
- Tax
- Trusts
- Other Submissions
- Older
Credit Contracts and Consumer Finance
- (2022) CCCFA Regulation Changes October 2022 submission
- (2002) Updated Credit Contracts and Consumer Finance Regulations and Responsible Lending Code submission
- (2021) Commerce Commission draft guidance on due diligence under CCCFA submission
- (2020/21) Responsible Lending Code Amendments: December Code Draft and FSF's Submission
- (2020) Technical amendments to the Credit Contracts and Consumer Finance Act 2003: Submission
- (2020) Criteria for Certification under the Credit Contracts and Consumer Finance Act 2003 : Consultation Document and Submission
- (2020) Consumer credit review: Fees for certification and registration requirements for non-financial services businesses: Consultation Document and Submission
- (2020) Exposure Draft of the Credit Contracts and Consumer Finance Amendment Regulations 2020: Submission
- (2020) Draft Addendum to Responsible Lending Code: Submission
- (2019) Credit Contracts and Consumer Finance Amendment Bill Submission
- (2014) Responsible Lending Code Submission
- (2014) Commerce Commission Fees Guidance Submission
- (2014) Credit Contracts and Consumer finance Amendment Act Regulations (CCCFA) Submission
- (2014) Disclosure Regulations - CCCFA Submission
- (2014) Responsible Lending Code Discussion Document Submission
- (2014) Consultation in Relation to Potential CCCFA & FSP Act Exemptions for Securitisations Submission
- (2013) Credit Contracts and Financial Services Law Reform Bill Submission
- (2012) Credit Contracts & Consumer Finance Amendment Bill Submission
Reserve Bank
- (2022) Issues Paper: Tax Administration in a digital world submission
- (2021) Deposit Takers Bill
- (2021) RBNZ enforcement principles and criteria submission
- (2021) RBNZ policyholder security submission
- (2021) Reserve Bank's Cyber Resilience Guidance consultation submission
- (2020) Review of the Reserve Bank of New Zealand Act 1989 - Phase 2, Consultation 3: Consultation Paper and FSF's Submission
- (2019) The RBNZ's Role in Financial Policy Submission
- (2019) The Role of RBNZ and How it Should be Governed Submission
- (2018) Reserve Bank Act Review - Phase 2 Submission
- (2014) RBNZ Regulatory Stocktake Submission
- (2011) Non Bank Deposit Takers Bill Submission
Insurance
- (2022) Income Insurance Scheme submission
- (2021) Review of the Insurance (Prudential Supervision) Act submission
- (2020) Insurance Contract Law Review submission
- (2019) Insurance Contract Law Reform Submission
- (2018) Insurance Contract Law Review discussion Paper Submission
- (2018) Fair Insurance Code Review Submission
- (2017) RBNZ Review of the Insurance Prudential Supervision Act Submission
- (2021) Climate related financial disclosures
- (2021) Options to provide Clean Vehicle information to consumers
- (2021) Land Transport (Clean Vehicles) Amendment Bill
- (2021) Sustainable Biofuels Mandate 'Increasing the use of biofuels in transport'
- (2021) Climate Change Commission Report
- (2019) Climate-Related Financial Disclosures
- (2016) Review of FBT for Electric Vehicles
- (2016) Land Transport Bill
Insolvency Act 2006 and Partnership Law Act 2019 Review
- (2020) Insolvency Act 2006 and Partnership Law Act 2019 Review: Consultation document and Submission (in progress)
Consumer Data Right
- (2020) Options for establishing a consumer data right in New Zealand Discussion Document: Consultation document and Submission
Fair Trading Act
- (2020) Fair Trading Amendment Bill: Consultation Paper and Submission
Conduct
- (2022) Conduct of Financial Institutions (CoFI) License Fees
- (2021) Discussion document: Regulations to support the new regime for the conduct of financial institutions, see the submission here.
- (2021) Discussion document: Treatment of intermediaries under the new regime for the conduct of financial institutions, see the submission here
- (2020) Financial Markets (Conduct of Institutions) Amendment Bill: Consultation Document and Submission
- (2019) Protecting Businesses and Consumers from Unfair Business Practices Submission
- (2019) Conduct of Financial Institutions Submission
- (2014) Financial Markets Conduct Act Submission
- (2014) Unfair Contract Terms Submission
- (2013) Review of the Code of Professional Conduct for Authorised Financial Advisers Consultation Paper Submission
- (2012) Financial Markets Conduct Bill Submission
Privacy
- (2020) Repeal and Replacement of the Credit Reporting Privacy Code : FSF's Submission
- (2018) Privacy Bill Submission
- (2017) Credit Reporting Privacy Code Review Submission
- (2014) Privacy Commissioner Naming Policy Submission
- (2011) Credit Reporting Privacy Code Submission
Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT)
- (2021) AML/CFT Statutory Review
- (2021) AML/CFT Electronic Identity Verification Guidance Submission
- (2019) AML/CFT Regulations for High Value Dealers Submission
- (2018) AML/CFT Suspicious Activity Reporting Guidelines Submission
- (2017) AML Phase 2 Consultation January Submission
- (2017) AML Regulations Consultation October submission
- (2016) AML Phase 2 Consultation Submission
- (2012) Ministry of Justice Anti-Money Laundering and Counter-Financing of Terrorism Consultation Submission
- (2021) Buy now pay later
- (2021) Retail Payment Systems Bill submission
- (2021) Regulating to reduce Merchant Service Fees
- (2017) MBIE Issues Paper on the Retail Payments System
Advertising
- (2021) Review of the Code for Financial Advertising
- (2021) FMA's Proposed guidance on advertising offers of financial products under the Financial Markets Conduct Act 2013)
- (2022) Deposit Takers Bill (work in progress)
- (2015) Non-Bank Deposit Takers Review
- (2013) Prudential Review of Non-Bank Deposit Takers
Education
- (2021) Service Industries Workforce Development Council - order in council proposal
- (2019) Proposals for the Reform of the Vocational Education System Submission
- (2018) Ministry of Education Consultation on the role of Industry Training Organisations Submission
- (2014) National Financial Literacy Strategy Submission
Financial Advice
- (2018) Financial Services Legislation Amendment Bill Submission
- (2017) Financial Services Legislation Amendment Bill Submission
- (2017) FMA Consultation Paper on Robo-Advice Exemption Submission
- (2016) Parts 1 & 2 of MBIE's Financial Advisers Act Options Paper Submission
- (2015) Financial Advisers Act and Financial Services Providers Act Review Submission
- (2013) Review of the Code of Professional Conduct for Authorised Financial Advisers Consultation Paper Submission
Tax
- (2022) Tax Administration in a Digital World
- (2018) IFRS16 Tax Treatment Submission
- (2018) Tax Working Group Future of Tax Submission
- (2017) Taxation on Corporate Securitisations Submission
Trusts
Other Submissions
- (2021) FMA class exemption financial reporting
- (2021) Assess Financial Institutions upon change in control
- (2021) Review of the Financial Markets Authority's funding and levies
- (2021) Incorporated Societies Bill
- (2021) Review of the Approved Financial Dispute Resolution Scheme Rules
- (2021) Consultation: Review of the Wholesale Investor Exclusion $750,000 Minimum Investment Exemption
- (2021) District Court (Protection of Judgement Debtors with Disabilities)
- (2019) Farm Debt Mediation Bill
- (2016) Consumer Guarantees (Removal of Unrelated Party Lender Responsibility) Bill
- (2016) FMA Fee Proposals
- (2016) Misuse of FSPR Submission
- (2015) GST and the Cost of Sale Associated with Mortgagee Sales
- (2014) Review of Credit Rating Exemption Threshold
- (2014) Proposed Ministerial Exemption for Managing Intermediaries
- (2014) Health and Safety Bill
- (2014) Uninvited Direct Sales(2014) Financial Reporting Designation Exemptions
- (2014) Governance Consultation Paper
- (2013) Exposure Draft of Land Transfer Bill
- (2012) FMA Class Exemption Review
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Please get in touch to request earlier submissions.