Who we are:
The Financial Services Federation (FSF) exists to lead Aotearoa New Zealand's responsible non-bank lending and fleet leasing sector, by promoting the highest standards of compliance and ethics.
Through advocacy and education, FSF supports a healthy financial system that fosters competition, protects consumers, and gives both people and businesses the ability to apply for a responsibly provided loan when life calls for it. FSF members touch the lives of more than 1.7 million New Zealand consumers and businesses, and 48% of personal lending in Aotearoa New Zealand is financed by the nonbank sector represented by FSF members.
Based in Wellington, the FSF was established as the NZ Finance Houses Association in 1965. Today, the FSF is recognised as the industry body representing responsible and ethical non-bank finance and leasing providers of New Zealand. We have over 92 members and affiliates providing financing, leasing, credit-related insurance services, and more to over 1.5 million New Zealanders.
Our affiliate members include internationally-recognised legal and consulting partners, credit reporting and debt collection agencies and FinTech providers. A current list of our members can be seen here.
The benefits of FSF membership:
The FSF can represent members more effectively than if they were to do so themselves. We make sure the membership's voice is heard by:
Government, Policy Makers and Regulators:
- FSF ensures members' interests are consistently represented by maintaining strong relationships with politicians, Ministry policy advisers, regulators and other officials.
- FSF advocates for members to ensure that they are recognised by stakeholders as being the responsible and ethical participants in the finance, leasing and credit-related insurance sectors.
- FSF works with regulators and officials to ensure that regulatory reforms achieve the best possible balance between the need to provide protection to New Zealand consumers and the ability for members to conduct their business while minimising compliance costs.
- FSF provides information to its members to give them an understanding of how such changes will impact their business including obtaining legal or accounting opinions from its professional advisers where necessary.
- FSF draws on the advice of its professional legal and accounting advisers as well as members' practical experience when making submissions to Government.
- FSF is proactively consulted on proposals at all stages of policy development and exerts influence before and during the legislative development stage - as an example FSF members are represented on the Advisory Group set up by the Ministry of Business, Innovation and Employment (MBIE) which informed the development of the Responsible Lending Code and recommends changes to the Code as required.
- FSF proactively influences policy at Government and policy maker level to drive positive change to legislation and regulation where appropriate and where it benefits both members and New Zealand consumers.
- FSF is able to represent the responsible and ethical finance company sector as a whole to Government, policy makers and regulators, to avoid the perception of self-interest that might arise if individual companies were to do so themselves.
The private sector and the public:
- FSF encourages members to use its logo to promote their membership on their digital platforms and in their advertising and marketing material. This demonstrates to the New Zealand public a member's commitment to responsible and ethical behaviour and distinguishes them from players in the industry who do not hold such high ethical standards.
- FSF has strong relationships with other like-minded industry bodies, particularly the New Zealand Bankers Association, the Insurance Council, the Motor Trade Association, Financial Advice New Zealand, Trustee Corporations Association, and the Financial Services Council, so that where possible we can speak as one on common issues.
- FSF has links with and/or is an associate of counterpart industry bodies in Australia, Canada, the UK and the USA and uses these relationships to share ideas of best practice and experiences with regulation.
- FSF has a strong media and social media profile to proactively provide the voice of the responsible participants in the finance company, leasing and credit-related insurance sectors and is actively sought after for comment by media sources.
The FSF is effective in its work to reduce compliance costs for members:
- FSF has over the years been able to achieve beneficial modification to the application of numerous statutes.
- FSF has fought erosion of the rights of secured parties.
- FSF was able to achieve exemption from the financial advisers' regime under the Financial
- Advisers Act for Point of Sale financiers.
- The FSF achieved similar exemptions for Point of Sale financiers from the Anti-Money Laundering and Countering the Financing of Terrorism Act.
- FSF successfully pushed for a substantial change to the Credit Contracts and Consumer Finance Amendment Act 2014 ("CCCFA") to allow finance providers to be paid commission on credit-related insurances when they finance the premium as part of the loan.
- FSF achieved outcomes to the disclosure regulations in support of the CCCFA relating to the way in which the borrower's right to cancel and the minimum repayment warning on monthly credit card statements is disclosed that saved members hundreds of thousands of dollars in systems costs.
- FSF advocated for high value goods dealers to have limited suspicious transaction reporting obligations under Phase 2 of the AML/CFT Act rather than the full obligations of an AML/CFT reporting entity.
- FSF strongly advocated for the exemption of consumer credit contract and credit-related insurance providers from the requirements of the revised financial advisers' regulatory regime during the process of the review of the Financial Advisers Act. This has been achieved in the Financial Services Legislation Amendment Act passed by Parliament in 2019.
- FSF also advocated that Non-Deposit-Taking Lending Institutions should not be included within the Reserve Bank of New Zealand's regulatory perimeter as suggested in the first round of consultation on the review of the Reserve Bank Act. Following this submission, the in-principle decision has been made by the Minister of Finance not to include such entities within the Reserve Bank's supervisory regime.
- Through the sharing of best practice at Working Group and other FSF meetings as well as FSF's targeted information to members, the cost of seeking professional advice to understand compliance obligations is significantly reduced for members.
This list is by no means exhaustive. FSF has been instrumental in achieving many concessions from regulators which have directly resulted in either reduced compliance costs or in members retaining the ability to carry on business as usual without undue regulatory interference and the FSF will always look for ways in which they can continue to do so.
FSF resources help members in their day-to-day business:
- Regular newsletters and communications to members on a timely and as-required basis and the resources held in the Members' Hub of the FSF website keep members fully up to date on legislative, regulatory and any other issues relevant to them.
- The FSF has developed Codes of responsible behaviour for various sectors of their membership to publicly demonstrate members' commitments to providing the highest standards of responsible lending behaviour to New Zealand consumers. These Codes outline to consumers, regulators and other providers how they should expect responsible providers to behave. To date these Codes include the Responsible Lending Guidelines (which were used to develop the Lender Responsibility Principles now required of all lenders as part of the Credit Contracts and Consumer Finance Act); the Responsible Borrowing Code (which demonstrates to consumers their obligations to lenders under a credit contract); and the Responsible Credit-Related Insurance Code (which describes the value to consumers of having protection when taking on debt and the way in which responsible providers will treat them).
- FSF runs a variety of special interest groups designed to target particular sectors of the membership and to provide a forum for people working in various parts of members' businesses. These Working Groups are Tax and Finance, Legal and Compliance, Wheels (for members providing motor vehicle financing to consumers), Insurance (for credit-related insurance providers), Fraud, Leasing, and People and HR. These Groups meet regularly to discuss common issues, gain insight from guest speakers, and to provide a forum for best practice sharing and networking amongst peers.
- FSF organises other regular meetings for members at which they can share their views and network with one another. These meetings also include presentations from high profile and relevant guest speakers who will engage with members to get an understanding of what is happening in the financial services sector.
- FSF provides concise and focused material about trends in specific markets through publications, reports, statistical information and market analysis.
The FSF promotes business integrity and responsible and ethical behaviour on the part of its members that other financial services sector participants can strive to emulate:
- Through member commitment to FSF Rules and the Code of Conduct for Members.
- Through development of Codes of responsible behaviour to which all members are committed. These include the Responsible Lending Guidelines, the Code of Responsible Borrowing and the Responsible Credit-Related Insurance Code.
- FSF members work together with the FinCap financial mentor network to proactively refer customers to assist them in hardship situations or where they have had finance declined.
- Criteria for membership of the FSF is clearly defined in the Federation's Rules and the Executive Committee ensures these are met and other due diligence carried out as required (including inquiries with the Commerce Commission, disputes resolution schemes and financial mentor networks) which is taken into account when the Executive Committee considers applications for membership which must reach full consensus.
- The FSF has a Disciplinary Committee and a process in the case that a member potentially brings the Federation and the sector into disrepute. Disciplinary action can include termination of membership as well as a complaint to the regulator in appropriate circumstances.
- The FSF acts as a whistle-blower to regulators whenever instances of non-compliance with legislation or regulation are identified from outside of the membership. This provides regulators with an independent source of complaint which is more likely to be acted upon than if laid by an industry competitor. This also ensures that a level playing field in respect of compliance is maintained and competitive advantage cannot be gained by not being fully compliant.
- Audited accounts for FSF are produced each year and filed with the Registrar of Incorporated Societies.
The FSF celebrates and recognises excellence in the non-bank finance sector:
The FSF annual conference has become a highlight in the sector calendar. As well as an opportunity for the sector to connect and network, attendees hear from Ministers, economic and political experts, regulators, policy makers, representatives from international financial services organisations, and other relevant and entertaining and motivational speakers.
The post-conference FSF Awards gala evening recognises excellence in the non-bank finance sector in categories of leadership, rising stars, support persons, innovation, and corporate social responsibility.
Accountability to members:
- Because joining and remaining a member of FSF is voluntary, it is essential for FSF to remain relevant and responsive to member concerns and information needs in order to continually add value for membership and to operate in a cost-effective manner.
- The Executive Committee of the FSF is made up of representatives from member organisations and the Committee determines how the FSF is run to ensure it achieves its strategic goals, remains relevant, and continues to add value to members. Wherever possible the Committee is made up of representation from each sector of the membership - e.g, motor vehicle finance providers, consumer and business finance providers, leasing and insurance providers.
- Regular surveys of members ensure that membership of FSF remains relevant and of value to members.
- Member needs vary considerably so a range of services are provided from which members can take what they need to give their membership value. These services are constantly reviewed following member feedback to ensure they remain of value.
- FSF is frequently able to provide members with a professional opinion as to the impact of regulatory change and how that will affect their compliance programme meaning that members do not need to incur the cost (or can significantly reduce the cost) of engaging their own professional advisers.