Submission to CCCF Amendment Regulations 2020 Exposure Draft

General Comments:

Overall, The Salvation Army is generally supportive of the amendments outlined in the CCCFA Amendment Regulations 2020 Exposure Draft. The Salvation Army has three main social services engaged with the credit contracts area; our national network of financial mentors or budgeters located in various Salvation Army Community Ministry centres, our national network of Community Finance workers providing advice and access to low or no interest loans products, and the Good Shop vans operating in South Auckland and Porirua. In our estimates, over half of the 120,000-plus New Zealanders that use our social and Christian spiritual services have some sort of problem-debt on credit contract and consumer finance issue. Therefore, we have tried to provide insights, views and opinions on the different options presented in the Exposure Draft based on the clients using our services, and the feedback received from these three specific social services. We will provide our views below following the format used by MBIE in the Exposure Draft.