The Salvation Army welcomes this opportunity to offer a brief submission to the Reserve Bank’s Capital Review.
The Army’s interest in this review stems mainly from our interest in public policy generally and in the economic and social interests of the most vulnerable New Zealanders more particularly.
These broad and specific interests cover concerns we have for the systemic risk associated with our rising levels of indebtedness alongside the role of banks in creating this debt.
As well we are concerned about the impact changes in banking regulation may have on economically marginal consumers and communities. A further concern which is discussed also in this submission is the treatment of lending to alternative housing providers such as NGOs like The Salvation Army and to housing co-operatives or community housing providers (CHPs).