Submission to Credit Contracts and Consumer Finance Amendment Regulations 2020

Executive Summary 

1. Overall, The Salvation Army is very supportive of these regulations. We believe they strike a good balance between protecting consumers (especially those facing serious financial hardship) and supporting a robust lending sector. Because we are strongly supportive of these provisions, our comments in the body of our short submission are on sections we seek further clarification on, areas we are unclear on, or other general comments. However, we submit that these draft regulations are very positive and help reinforce the true spirit and intent of the principal CCCFA. 
2. We want to note here the challenge we have in responding in the last few months to a relatively large amount of consultations, draft legislation and requests for information from MBIE and also the Commerce Commission in relation to the CCCFA 2003 and other consumer and credit issues. The extremely tight timeframes we are often given to respond to these requests is very difficult for us, particularly in this post-Covid 19 lockdown environment. We recommend a more ordered and reasonable process in the future so that the NGO and community sector can respond effectively to these important matters. The timeframe for this Draft (7 business days to prepare a submission) is not really helpful to develop reasonable and informative responses. Still, The Salvation Army is very grateful to be involved in these ongoing discussions. 

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