Submissions

Age Concern New Zealand welcomed the opportunity to submit feedback on the Financial Markets Authority’s draft Fair Outcomes for Consumers and Markets: A guide to outcomes-focused regulation

Overall, Age Concern New Zealand supports the proposed outcomes and approach. We believe the outcomes identified are reasonable and would meet the expectations of consumers. Access to, and engagement with, financial services is an important part of older people’s wellbeing and ageing well in their communities.

We emphasise the importance of accessible information and communication with consumers. The issue we see is more with how effective implementation of the Code will be measured or assessed. Training and a monitoring framework of some form will be needed to ensure the Code lives up to its aim and intent.

We believe the success of the framework will be shaped by the approach of the Financial Markets Authority in their work with providers to meet the outcomes. The intent of establishing fair outcomes for consumers and markets is commendable, but implementation comes down to multiple providers interacting with a wide range of people, who may be under pressure at the time.

We would like to see a process developed for consumer and consumer advocate groups to share their experiences with the Financial Markets Authority after the regulations have been implemented and providers have started taking steps to meet the outcomes.

Age Concern New Zealand supports the development of a Code of Insured Persons’ Rights to outline the standard of service insured people can expect from Toka Tū Ake EQC. The management and settlement of claims after a natural hazard event, such as an earthquake or landslide, is important to any insured homeowner. There is also potential for an insured person to face the distressing impact of multiple natural hazard events. This is challenging for anyone, especially for many older New Zealanders and people with disabilities. 

Older New Zealanders are a diverse, resilient and valued part of every community. Some of the older adults in our communities will need greater support and help when making an insurance claim after a natural hazard event. Older people are not all the same, any more than any other population group. However, older people that are frail, have a disability or live alone may require extra support throughout the process. Older adults may not use digital technology as regularly as others, or at all, which is a disadvantage at a time where much information and many forms that need completing are online. We urge those developing the Code and Insurers working with older homeowners ensure ageism does not impact on their interactions with older people.The issue we see is more with how effective implementation of the Code will be measured or assessed. The intent is laudable and pleasing to see, but implementation comes down to multiple home insurance providers interacting with a wide range of people, who will likely be under considerable stress at the time. Training and a monitoring framework of some form will be needed to ensure the Code lives up to its aim and intent.

Age Concern New Zealand and our Member Organisations welcomed the opportunity to submit comments on the Review of the Retirement Villages Act 2003: options for change.

Age Concern New Zealand supports updating the legislation to protect the interests of current and future residents and to enable retirement villages to operate under a legal framework readily understandable to residents and operators.

We acknowledge the importance of retirement villages as a housing option for older New Zealanders, with just over 50,000 now living in retirement villages.

Our key recommendations:

Age Concern New Zealand and Member Organisations strongly recommend that the Ministry for Housing and Urban Development prioritises the following areas in any final decisions: 

1. Plain language and accessible formatting should be used in all documentation, including disclosure statements, occupation right agreements, and code of resident’s rights.
2. Ensure all key retirement village documents are available in multiple languages
3. Clarify the differences between a retirement village and aged residential care, including the financial and other implications of transferring from an independent unit into residential care.
4. Ensure culturally responsive services and models of care are provided.
5. Require all retirement villages to stop weekly and other fixed fees when a unit is vacated.
6. Require the timely repayment of the capital sum within three to six months when a unit is vacated. 
7. Ensure that changes in the Act are applied to all existing occupation rights agreements within a specified timeframe.
8. Enable a percentage of affordable rental units to be available for older adults who are unable to pay a capital sum.
9. Ensure that retirement villages are required to meet the Healthy Homes standards.
10. Establish a new simplified independent disputes scheme.

Age Concern New Zealand welcomed the opportunity to submit on the Emergency Management Bill

Age Concern New Zealand supports updating legislation to guide our preparation, response, and recovery from emergency events. Aotearoa has been experiencing severe weather events which are extremely challenging for people living in affected communities, as well as for the organisations responsible for responding to those events.

Older New Zealanders are a diverse, resilient, and valued part of every community. Some of the older adults in our communities will need greater support and help in an emergency, others will be amongst the helpers. Older people who are frail, have a disability or live alone may require extra help in an emergency. Some may not have whānau or friends living nearby, or they may need help to evacuate their home or get to higher ground. If injured, they are likely to take longer to recover. Older adults may not use digital technology as regularly as others, or at all. Displacement and disruption resulting from emergency events make it difficult for older adults to access healthcare, obtain medication, receive home support or have access to equipment they require.

Our recommendations

• Create supportive environments that foster collaboration and working together, encourage people to look out for one another, and provide mutual support.
• Use multiple methods to alert communities of an emergency event.
• Protect and provide for older people but also recognise their strengths, the benefit of their past experiences coping with emergencies and their ability to contribute to helping others.
• Recognise that some older New Zealanders may be disproportionately affected by emergency events.
• Appoint a lead person for older people’s welfare in each area who can co-ordinate activity, share information and set up an ongoing network of organisations that work with older people in their local community.
• Retain and extend a successful Community Connector model.
• Advise communities about who to contact for emergency home repairs and link them with offers of help to clean up after an emergency.
• Provide additional funding to superannuitants to carry out repairs to their property if they are dependent solely on their superannuation with little, if any, additional income
• Prioritise preparedness and talking about the ‘what ifs’ for emergency events, particularly for those living alone.
• Clear communication must take place before, during, and after an emergency event and must be clear, use simple language, and be in multiple formats and languages.
• Ensure that timeframes and processes for processing insurance claims are fair and reasonable.
• Provide extra funding to marae, iwi, non-government and community organisations such as Age Concerns, during the emergency event and for a time during recovery.
• Provide free emergency management training for Māori and Pacific providers, community organisations and the not-for-profit sector who will all play a key role in any emergency response.
• Provide free counselling for the staff of Māori and Pacific providers, community organisations and the not-for-profit sector who may experience trauma during their emergency response activities.