Submissions

The New Zealand Government and Regulators often request feedback on planned legislation and laws. The Financial Services Council submit both written responses via submissions and oral evidence at select committees. We work with members through our committees to develop and agree responses.

Submissions by topic | Code, Conduct & Culture | Financial Advice | Investment & Funds | KiwiSaver | Life Insurance | Tax 
 

Submissions in the Pipeline

• 14 December | Proposed guidance on KiwiSaver fees and value for money
• 29 January 2021 | RBNZ Consultation: Risk management guidance on cyber resilience and views on information gathering and sharing
• 16 February 2021 | FMA: Proposed guidance on advertising offers
• 31 March 2021 | RBNZ: Changes to the Banking Supervision Handbook: Exposure Draft for Capital Review Changes

Completed Submissions by date

2020

• 20 November | Recognition of Australian adviser qualifications
• 20 November | FDR FX Hedges Rules
• 12 November | Review: Insurance Solvency Standards (Principles and Timeline)
• 23 October | Reserve Bank Act Review Phase, Third Round
• 5 October | Payment systems, open banking and consumer data
• 20 August | Review of Class Exemptions expiring in 2021 (Financial Markets Conduct (Licensed Independent Trustees of Restricted Schemes) Exemption Notice 2016) 
• 12 August | Taxation (Annual Rates for 2020-21, Feasibility Expenditure, and Remedial Matters) Bill
• 7 August | Proposed standard conditions for Financial Advice Providers
• 22 May | GST Policy Issues, An Officials' Issues Paper
• 30 April | Financial Markets (Conduct of Institutions) Amendment Bill
• 26 April | Fair Trading Amendment Bill
• 5 March | Proposed changes to the Unclaimed Money Act 1971 Consultation
• 28 February | Funding and Levies
• 5 February | Credit Contracts and Consumer Finance Amendment Regulations 2020

• 13 December | Climate related financial disclosures
• 31 October | Green bonds and other responsible investment products
• 31 October | Retirement Commissioner's three-yearly Review of Retirement Income Policies
   
• 20 September | KiwiSaver default provider arrangements
   
• 16 September | Investment income: custodial institutions
   
• 13 September | New financial advice regime exemptions

•  13 September | Disclosure requirements in the new financial advice regime

• 6 September | Taxation (KiwiSaver, Student Loans, and Remedial Matters) Bill and the supplementary order paper on KiwiSaver withdrawal in cases of life-shortening congenital conditions

• 29 August | Reserve Bank Act Review Phase 2 consultations 2A and 2B
   
• 26 July | Proposed standard conditions for financial advice provider transitional licences
   
• 6 July | Insurance Contracts Law Review options paper
   
• 7 June | Conduct of Financial Institutions options paper
   
• 8 March | FMC Amendment Regulations 2019 - Retirement savings and income projections in KiwiSaver annual statements
   
• 22 February | Response to MBIE discussion paper on protecting businesses and consumers from unfair commercial practices
   
• 22 February | Response to MBIE discussion paper on financial advice provider licensing fees and changes to the FMA levy
   
• 25 January | Submission to the Reserve Bank of New Zealand: Consultation on Reserve Bank Act Phase Two

2018

• 6 December | Global Federation of Insurance Associations (GFIA) Global insurance industry letter on IFRS 17 follow up on IASB November Board Meeting (co-signatory)
   
• 23 November | Submission to the Financial Markets Authority: Consultation on proposed open-ended term for FMCA licences.
   
• 9 November | Submission to the MBIE Code Working Group: Code of Professional Conduct for the Financial Advice Sector
   
• 1 November | Submission to the New Zealand Government's Tax Working Group: Future of Tax: Interim Report
   
• 24 October | Submission to Social Services and Community Committee: KiwiSaver (Foster Parents Opting in for Children in their Care) Amendment Bill
   
• 16 October | Global Federation of Insurance Associations (GFIA) Global insurance industry comments on IFRS 17 (co-signatory)
   
• 31 August | Submission to Financial Markets Authority: Exemptions, other legislative notices, and unnecessary compliance costs
   
• 24 August | Submission to Reserve Bank of New Zealand: Insurance Solvency Standards and NZ IFRS 16 Leases 
   
• 14 August | Submission on Taxation (Annual Rates for 2018-19, Modernising Tax Administration, and Remedial Matters) Bill
   
• 13 July | Submission to MBIE - Review of Insurance Contract Law. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC)
   
• 25 May | Submission to Justice Committee: Privacy Bill. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC)
   
• 25 May | Submission to Financial Markets Policy Building, Resources & Markets and Ministry of Business, Innovation & Employment: Disclosure requirements in the new financial advice regime. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC)
   
• 16 May | Submission to Financial Markets Authority: Consultation on including an annual declaration of compliance in regulatory returns and updating the standard regulatory returns condition. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC)
   
• 16 May | Submission to Financial Markets Authority:Proposed exemption to enable dual-language product disclosure statements.  This is a submission from the Financial Services Council of New Zealand Incorporated (FSC) 
   
• 30 April | Submission to Ministry of Business, Innovation & Employment: Code of Professional Conduct for Financial Advice Services. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 30 April | Submission to Tax Working Group: Future of Tax. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 13 April | Submission to Economic Development, Science and Innovation Committee: KiwiFund Bill. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 7 March | Submission to the Inland Revenue: GST - Unit Trust Management Fees. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 26 February | Economic Development, Science and Innovation Committee - Submission: Financial Services Legislation Amendment Bill. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 13 February | Finance and Expenditure Committee - Submission: Taxation (Neutralising Base Erosion and Profit Shifting) Bill. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC) 
  click here to view

2017

• 15 December | Financial Markets Authority - Request for feedback: Exemption to enable personalised digital advice. Feedback from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 15 December | Reserve Bank of New Zealand - Request for feedback: Audit requirements for insurer data returns  Feedback from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 20 October | Reserve Bank of New Zealand - Request for feedback: Insurance statistics.  Feedback from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 19 September | Consultation Paper to MBIE: KiwiSaver savings and income projections - designing assumptions.  This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 1 September | Consultation Paper to FMA: Proposed exemption from the market index requirement. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 19 July | Consultation Paper to FMA on the proposed exemption to facilitate personalised robo-advice: Financial Services Council response.
   
• 7 July | Office of the Chief Tax Counsel: GST - unit trust management fees. This is a submission from the Financial Services Council of New Zealand Incorporated (FSC).
   
• 6 July | FSC and WSNZ - MBIE KiwiSaver query - Withdrawals from KiwiSaver, This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 30 June | Submission to RNZ on Issues Paper – Review of the Insurance (Prudential Supervision) Act 2010 (IPSA). 
   
• 9 June | Consultation Paper to FMA: Proposed exemption from obligation to prepare scheme financial statements for bundled unit trusts. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 9 June | Submission to MBIE on Managed Investment Schemes - Making annual reports available to participants. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 5 May | Submission of the KiwiSaver Annual Statements. This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).
   
• 31 March | Submission to MBIE in relation to the consultation paper for the proposed new Financial Advice Regime (FAA Review).

2016

• 16 December | Submission on the proposed KiwiSaver advice guidance note (Guidance Note).  This is a joint submission from the Financial Services Council of New Zealand Incorporated (FSC) and Workplace Savings NZ Incorporated (WSNZ).