NZPIF Submissions and Reports
The NZPIF works hard to be the voice for rental property owners in New Zealand. Below is a list of submissions we have made over the years with a link through to the submission.
Response submitted to Regulation of Methanphetamine Contamination in Rental Housing
Submitted 2023-03-08
Submission to the Reserve Bank of New Zealand - "DTI Framework Consultation 2022"
December 22
The NZPIF remains of the opinion that Debt-to-Income Restrictions are fundamentally flawed and should not be introduced. However, if a DTI is to be introduced then it should not applied to investor loans.
Submission to the Finance and Expenditure Committee on interest limitation
26 October 22
A submission was forwarded to the Finance and Expenditure Committee on the Taxation (Annual Rates for 2022-23, Platform Economy and Remedial Matters) Bill (No2). The submission only addresses the parts of the Bill which impact on the rental property industry.
Submission to the Reserve Bank of New Zealand "Debt Serviceability Restrictions"
February 2022
NZPIF Executive Office has written and forwarded this submission to the Reserve Bank to explain why DTIs should not be introduced.
Submission on Housing and Urban Development –Government Policy Statement on Housing
NZPIF Executive Officer Sharon Cullwick has responded to the Government Policy Statement on Housing and Urban Developement Survey
July 2021
Submission Interest Limitation and Bright Line test
July 2021
This New Zealand Property Investors' Federation Inc (NZPIF) welcomes the opportunity to provide feedback on the Design of the interest limitation rule and additional bright-line rules. See the full submission here
RTA AMENDMENT BILL - SUBMISSION TO THE SELECT COMMITTEE
25 March 2020
The RTA was first established in 1986 and has undergone two large reviews since it was first introduced. It is good to examine Acts of parliament to see if they require amending in order to continue being relevant for changing circumstances. This Bill assumes that there is an imbalance between tenants and landlords and seeks to balance their rights and obligations. It does so by increasing the rights of tenants and increasing the obligations of landlords. In doing so, the Bill actually creates inequality between the two parties that will lead to a reduction in rental property supply and an increase in rental prices. This will occur at a time when we already have a shortage of rental properties and rental prices increasing faster than
general inflation. While the NZPIF believes that tenancy rules can always be improved to meet changing societal circumstances, these changes need to be carefully thought through. As much as possible, changes need to ensure they are correcting a problem that actually exists, that the change will actually correct the problem, that the right people are being helped and that there are no unintended consequences.
Read the full submission here
Ring fencing rental property losses - Submission to Select Committee
28 February 2019.
Submission to the Finance and Expenditure Select Committee who are looking into ring fencing rental property losses. This is part of the Taxation (Annual rates for 2019/20, GST Offshore Supplier Registraton, and Remedial Matters) Bill.
Read the full text of the submission here
Healthy Homes Guarantee Bill Standards Consultation
22 Oct 2018.
Submission to the Ministry of Business Innovation and Employment who are developing the standards to be included in the Healthy Homes Guarantee Bill. Standards cover insulation, room temperatures, heating, ventilation, drainage and draught proofing.
Read the full text of the submission here
Residential Tenancies Act Review
21 Oct 2018.
Submission to the Ministry of Business Innovation and Employment into a wide ranging review of the RTA with the objective of improving conditions for tenants. The review covers security of tenure, allowing tenants to modify their property, allowing tenants to keep pets, restricting rent increases and increasing enforcement powers of MBIE to investigate nd take action against landlords.
Read the full text of the submission here
Residential Tenancies (Prohibiting Letting Fees) Ammendment Bill
23 May 2018.
Submission to the Social Services and Community Select Committee. The Bill seeks to prohibit tenants from being charged a letting fee by property Managers.
Read the full text of the submission here
Ringfencing rental property losses
11 May 2018.
Submission on Ring-fencing Rental Losses, which would stop rental property losses from being used to offset other income of the rental property owner.
Prepared in response to the select committee invitation to provide feedback on the Residential Tenancies Amendment Bill.
Read the full text of the submission here
2018 Tax Working Group
30 April 2018.
Submission to the 2018 Tax Working Group, which was established by the 2017 Labour Government to examine the tax system in NZ and report back on how it could be made fairer.
Read the full text of the submission here
Read the Morgan Wallace report into shortfalls with the TWG study into marginal effective tax rates here
Unlawul Dwellings
01 November 2017.
An Aide Memoir to Minister of Housing, Phil Twyford, on problems with proposed legislative changes to address unlawful dwelling problem. Memoir prepared by lawyers Chen Palmer .
Read the full text of the Memoir here
Residential Tenancies Ammendment Bill No2
22 August 2017.
Submission to the Local Government and Environment Select Committee. The Bill covered the topics of Tenants liability for damage, Unlawful dwellings and Methamphetimine.
Read the full text of the submission here
Debt to Income Restrictions
18 August 2017.
Submission to the Reserve Bank of New Zealand. The Reserve Bank requested submissions on a proposal for the Bank to be allowed to use Debt to Income Ratio's as a further tool to control mortgage borrowing in NZ.
Read the full text of the submission here
Affordable housing report
March 2017.
This was a report on research undertaken by the NZPIF into housing affordability in New Zealand over the last four decades. The study looked at what it was like to be a first home buyer in each decade from the 80's. The study found that it has always been difficult to buy your first home. In the 80's the main problem was high mortgage interest rates, while in subsequent decades it was saving a deposit.
Read the full report here
Osaki report: Tenant Liability for Damage
August 2016.
A NZPIF report into the High Court case which has found tenants are no longer responsible for the damage they they or their guests cause in a rental property.
Read the full report here
Adjustments to restrictions on high LVR lending
18 August 2017.
Submission to the Reserve Bank of New Zealand. The Reserve Bank considered that New Zealand's financial system was at risk because of high house price growth. The NZPIF submission states that the needs of home buyers should not be put in front of tenants needs for reasonable rental prices.
Read the full text of the submission here
Taxation (Bright Line Test for Residential Land) Bill
10 September 2015.
Submission to the Finance and Expenditure Select Committee on introducing a Bright Line Test for residential property.
Read the full text of the submission here
Asset Class Treatment of Residential Property Investment Loans
March 2015.
Submission to the Reserve Bank of New Zealand. The Reserve Bank considered that "lending for property investment has a different risk profile than lending to owner-occupiers, and banks therefore need to have a larger amount of capital for their investment property loans than they do for loans to owner occupiers". The NZPIF submission disagrees with the studies the Bank used to form its opinion and argues that residential rental property loans are not a higher risk to home owner loans that they need to be classed differently and have higher deposit requirements.
Read the full text of the submission here
Proposal to reduce tax on Kiwisaver and bank deposits
November 2014.
A NZPIF report into a proposal by the Financial Services Council to reduce the tax obligations for Kiwisaver savings and some term deposits. The NZPIF disagrees with the proposal.
Read the full report here
Building (Earthquake-Prone Building) Amendment Bill
17 April 2014.
Submission to the Local Governemnt and Environment Select Committee on proposals to improve the system for managing earthquake-prone buildings in New Zealand.
Read the full text of the submission here
Proposal to introduce a Rental Property WOF
February 2014.
A NZPIF report into a proposal by the Childrens Commissioner to introduce a WOF scheme on rental properties.
Read the full report here
Civil Fees review
2 November 2012.
Submission to the Ministry of Justice on their proposal to increase the fee for enforcing a possesion order obtained from the Tenancy Tribunal.
Read the full text of the submission here
Expert Advisory Group call for Rental Property WOF
October 2012.
Submission to issues and options paper released by the Expert Advisory Group on Child Poverty, who have called for a WOF on rental property in NZ.
Read the full text of the submission here
NZPIF Survey into Tenancy Tribunal
3 April 2012.
A NZPIF report on a survey they conducted among members into their use and views of the Tenancy Tribunal.
Read the full report here
Housing Affordability
11 February 2012.
Submission to the NZ Productivity Commission on their report into housing affordability.
Read the full text of the submission here
Courts and Criminal Matters Bill
July 2010.
Submission to the Law and Order Select Committee on proposals to enhance the Courts powers and processes for the collection of fines and other monetary penalties, and civil debts. The NZPIF is supportive..
Read the full text of the submission here
Social Assistance (Future Focus) Bill
May 2010.
Submission to the Social Services Select Committee on how beneficiaries should be paid. Of particular interest to the rental property industry is direct rent payments to landlords.
Read the full text of the submission here
Residential Tenancies Amendment Bill
July 2009.
Submission to the Social Services Select Committee on changes to the Residential Tenancies Act.
Read the full text of the submission here
Review of Property Managers
16 March 2009.
Submission to the Ministry of Justice on their review of Property Managers.
Read the full text of the submission here
Security of Tenure
March 2008.
Position statement of the NZPIF on security of tenure for tenants. The NZPIF is generally in support.
Read the full text of the submission here
IRD Associated Persons Proposal
26 April 2007.
A NZPIF report to PIA's on an IRD proposal to reform the definitions of associated persons. The aim is to extend associations between Property Developers, Builders and Traders that will extend who is associated with these people and therefore have the same tax conditions applied to them.
Read the full report here
Accommodation Suppement Review
August 2006.
A NZPIF report on the Ministry of Social Development review of the accommodation supplement. The NZPIF supports the AS as a way to help tenants afford good rental accommodation. The NZPIF believe that the AS should be paid directly to landlords.
Read the full report here
Residential Tenancies (Damage Insurance) Bill
July 2006.
Submission to the Social Services Select Committee regarding making landlords respopnsible for insuring their tenants against damaging their rental property.
Read the full text of the submission here
HISTORICAL DOCUMENT
Residential Tenancies Bill
25 October 1985.
This is the NZPIF submission to the Social Services Select Committee on the establishment of the Residential Tenancies Act which was eventually made into law in 1986. This is the principle governing Act of the rental proeprty industry in New Zealand.
Read the full text of the submission here
You can also see the submission from the Auckland Landlords Protection Association here which was written by the Association President, Peter Chilwell.
The Canterbury Property Investors Association submission here