The strength of our work lies in the experience of bureaux from their daily client contacts and the evidence this provides. CABNZ coordinates the process for submission making by our organisation on national-level issues.
Local bureaux or groupings of bureaux may undertake social justice advocacy on the local level and this can include making formal submissions to local body authorities and other organisations.
Recent Submissions
Submission on Police Charging (Vetting Services) (March 2013)
In this submission we focused on the proposal for the introduction of charges for the Police vetting service. We argued that most charitable organisations use the police vetting for public benefit, and therefore it is not appropriate to charge them for it. We suggested that there should be a complete exemption for all registered charities, this would be a transparent and easy to administer exemption option.
Submission on Family Court Proceedings Reform Bill (February 2013)
We expressed our concerns about the proposed reforms having a detrimental impact on the most vulnerable users of the court and undermining a focus on early intervention
We also expressed concern about the removal of easily accessible free family counselling without consideration of other mechanisms to make counselling accessible to low income New Zealanders.
We expressed our significant concerns about the impact of increased costs for users of the court and the inadequacy of fee waivers.
We opposed restricting legal representation in the court, expressing concern that this would exacerbate existing power imbalances between parties at the court.
Submission on Civil Fees Review (November 2012)
This submission emphasised the importance of ensuring that justice is not limited because of the cost of accessing it. We considered that the review of Civil Fees undertaken by the Ministry of Justice did not take sufficient account of the importance of access to justice.
In particular we raised concerns about the reliance placed on the use of fee waivers. The review appeared to assume (without providing evidence) that fee waivers are sufficient to ensure that everyone is able to access the justice system. If the review is serious about wanting to ensure access to justice it must investigate the effectiveness of fee waivers. There are a number of potential problems associated with the heavy reliance on fee waivers, but none of these problems appear to have been considered to date.
We also opposed the increase in fees for the Disputes Tribunal. We argued that the low cost of the Disputes Tribunal was an essential element of its accessibility and that increasing fees would reduce the effectiveness of the Tribunal.
Submission on Local Government Act 2002 Amendment Bill (July 2012)
This submission expresses concern about the unintended consequences of the Local Government Act 2002 Amendment Bill. We express concern that this Bill could lead to withdrawal of Council funding for the CAB. This is because of the uncertainty around the changes to the purpose of the Act and the lack of clarity around what local public services are.
We conclude that the risks are too great to proceed with the change in purpose statement. We recommend that the Bill is amended to reassert the current wording of the purpose statement in the Local Government Act 2002 along with the other references to it in that Act and other Acts. Additionally, given the risks that we have already experienced, we ask that that specific reference is made to the Citizens Advice Bureau as a service that Council’s may fund.
Submission on Gambling (Gambling Harm Reduction) Amendment Bill (June 2012)
This submission reiterates the long held position of the CAB to support measures to reduce the harm caused by pokie machines. This position is based on the clear evidence that pokies are the cause of significant social and individual harm. As an organisation we see this with clients coming to us seeking help with problem gambling.
In this submission, we support the need for greater transparency in the distribution of the proceeds from pokie machines. However we ask that more in depth policy work is carried out in relation to options for this through a consultative review process led by the Department of Internal Affairs. We ask that this review process looks at options for the distribution of the proceeds from pokie machines, as well as how to ensure sustainable funding for the important work that the community and voluntary sector carries out.
Submission on consultation draft of the Credit Contracts and Consumer Finance Amendment Bill (May 2012)
In this submission we supported many of the proposed amendments to the CCCFA, although in some cases we do not consider that they provide the same level of protection for consumers that consumers receive in equivalent overseas jurisdictions, such as Australia. We supported the introduction of Responsible Lending guidelines, improved disclosure and greater clarity around fees. We proposed changes to make hardship provisions more useful and raised concerns about the sale of credit related insurance. We also pointed to the urgent need for reform of the Repossession Act.
Submission on Consumer Law Reform (March 2012)
In this submission we supported the modernisation and consolidation of consumer law. We argued for stronger safeguards around unfair contract conditions. We also argued that there need to be stronger rules around door-to-door sales and extended warranties.
Submission on Repossession Act (September 2011)
In this submission we argued that the Act needs an urgent overhaul and that there are two things this overhaul should focus on:
- Improving oversight and enforcement of the Act
- Rebalancing the Act to provide a fairer balance between lenders and debtors.
Compared to other similar jurisdictions we have relatively weak consumer safeguards relating to repossession. This is particularly apparent in relation to what can be repossessed and oversight of the repossession process
Submission on Credit Reporting Code Amendment 5 (June 2011)
This code would introduce much more intensive credit reporting information. We argued that there is insufficient evidence to demonstrate that it would be more beneficial than not to introduce such a system and that changes in how credit reporting works should not take place in isolation of wider reform of the credit system.
We expressed concern about the possibility of increased inaccuracies in the way credit records would be kept under the proposals.
Older Submissions
You can view previous submissions on our archived submissions page.