HHA High Cost Loans and CCCFA Compliance

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We hope this finds you and your family safe and well in this challenging time.  At HHA, it is business as “new normal.” 

Does the CCCFA amendments, specifically High-Cost Consumer Credit Contracts changes, affect you?

We are attempting to establish if you are aware of, and compliant with the upcoming changes in CCCFA, specifically High-Cost Consumer Credit Contracts. 
Take our short survey to check your understanding of this. 
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Amendments to CCCFA  
Can you afford a fine of $500,000? I know I can’t!  
If you don’t review the changes to this legislation, that could be the outcome! 
The Credit Contracts Legislation Amendments Act was passed in 2019 – there are several important changes for lending and borrowing in New Zealand. 
Key changes to be introduced include:  
  • Interest Rate and Cost of Credit Cap:
  • Lenders assessment of affordability and suitability of loans - *Delayed 
  • Responsible lending laws for mobile traders – to be treated as creditors under consumer credit contracts. 
  • Responsible advertising standards–to provide contracts in languages used in advertising, for example. *Delayed  
  • Greater transparency and access to redress during debt collection. - *Delayed 
Tougher penalties will be imposed for irresponsible lending, including financial penalties up to $600,000 for an organisation and $200,000 for an individual (Directors and Senior Managers). 
Directors and senior managers of consumer credit lenders will be required to meet a “fit and proper person” test before being registered on the Financial Service Providers register.  *Delayed 

The legislation can be found on the Government Legislative website.

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Further information on the delays can be found on the Government Legislative website

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We are here to help and will be in contact
HCCCL Power BI-240-750
We have a neat tool which can highlight if you may have any clients and accounts that may be close to HCCL criteria. 

For further assistance to interpret how these changes will affect your business we recommend seeking legal advice.  
We are available to advise you from a software and systems perspective.  Please complete our short survey to give us a starting point to assist you and your team. 
If you took our survey and answered yes (or unsure) to any questions it is possible that you are offering loans that have a combined Interest rate greater than 50%, and may be subject to the High Cost Consumer Credit Loan regime that comes into effect on 1 June 2020. 
Please give us a call for us to discuss the next steps, or if you would like us to check your database regardless to put your mind at ease, we can do this with our cost effective check tool developed in-house by HHA.  

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All views expressed in the document are that of HHA Associates Limited and should not be construed or taken as legal advice whatsoever. We encourage all readers of this document to seek their own legal clarification and interpretation to understand how anything in this document may affect them or their business interests.
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