This page is directed to the Financial Markets Authority, asking that ACF is exempt from fees and that ongoing compliance costs are not ultimately laid on the poor.
“In the sustainable society, people are not subject to conditions that systematically undermine their capacity to meet their needs.
The Natural Step
The cost of living crisis is primarily driven by the affordable housing crisis where government and private sector parasitic policies are artificially creating this despair.
It creates a sense of hopelessness that withers the spirit, fosters crime, drug addiction alcohol abuse and domestic violence.
The first step to combatting this is stakeholding – to work toward owning one’s own home, starting with the most basic of homes: 8×3 home on wheels.
A Matter of Public Interest
The struggling class spawns a predator class
New Zealand is polarising into a comfortable class and a struggling class. As seen in places like Brazil and South Africa, the struggling class spawns a predator class; the comfortable class becomes their prey. This is not changed by taxing the rich and funding more welfare payments to the poor. It is changed by uplifting the poor so they have the capacity to meet their needs.
This begins with affordable housing, and while it would be desirable that all housing is affordable, the system that created this crisis is far too entrenched to change overnight. In the interim, mobile homes can provide warm, dry, safe, durable and adequate homes to begin the journey from poverty to self-sustainability.
The FMA and all the people associated with it are of the comfortable class. Few, if any of them will have experienced hidden homelessness. They live in a world of comfortable salaries and an expectation of a flat white on the way to the office. For the struggling class buying a $5 flat white means going without a week of canned beans to feed ones children.
It becomes imperative the decision-makers at the FMA understand that s4(c) of the Financial Markets Conduct Act purposes: to avoid unnecessary compliance costs is understood in the context of poverty. Any cost, initial or ongoing, ultimately adds to the cost of housing. For those at the bottom, any compliance cost is too much.
Cui Bono – WHo Benefits?
Cui Bono (who benefits?) What should be paid by tax dollars? A basic test in law asks who benefits? Does the proposed service benefit the promoters, or is it in the public interest, to benefit the people?
When the People Tax Themselves: If an outcome is in the public interest, it should be paid for by the public… that the people value an outcome so they vote, through their elected representatives, to tax themselves to pay for it. User pays has become overused by government bureaucracies when the taxpayer does not feel their taxes are being well used. The upshot is polarisation, where the comfortable class pays to get what they want, while society sees the growth of a struggling class
Relief of Poverty: Developing funding sources for poor people, so they may raise themselves out of poverty is in the public interest. While it would be desirable if the government provided direct funding (without another parasitic bureaucracy that makes poor persons’ engagement with it it miserable), the private and NGO sector is prepared to offer a solution now. However, to do so, the FMA must be part of the solution, not part of the problem.
No Parasitic Compliance Costs: Yes, a fund must protect the investors, so they will provide the money, but it must do so in a way that does not add a parasitic level of compliance costs that make the program unaffordable. Because no matter how it is applied, parasitic costs end up being paid by the customer – the poor seeking to better themselves.
Primary target: The primary customers for the ACF scheme are rural Māori on Māori-title land and the urban poor who have support systems – family or friends who are OK about parking a mobile home on their section to relieve overcrowded conditions. This includes racial groups (predominantly Pasifika and urban Māori) as well as old people, young school-leavers, solo mums and other struggling class.
It’s a simple scheme: Create a fund that pays for mobile homes for poor people. These are people whose alternative is living in cars, tents, sheds, garages and overcrowded conditions.
The need for a Specialist FSO: Because they are poor people, they add layers of challenges that requires specialised lenders who ensure the poor repay their obligations, and when they do not, that the investment is protected.
ACF is proposed to do that, but the biggest obstacle are the FMA compliance costs.
As a matter of national interest, to benefit the public, it becomes paramount that the FMA:
- Waive all fees
- Add no ongoing compliance costs
If FMA requires independent trustees, they must either be volunteer (generally semi-retired, or from large accounting firms out of their pro bono budget) or paid by the taxpayer.
Cui Bono? The primary beneficiaries of the ACF scheme are not the investors, and curiously, not the poor beneficiaries, although they benefit by raising themselves out of poverty.
The primary beneficiary it is the nation as a whole. NZ should not have poverty. Poverty breeds despair, a sense of hopelessness that withers the spirit. But it also spawns crime, drug addiction and alcohol abuse, domestic violence as the struggling class gives rise to a predator class. The first step to combatting this is stakeholding – to work toward owning one’s own home, even if it is 8×3 on wheels.