Submission on the review of class exemption notices

Advocacy submission
Written By Saya Wahrlich

Cooperative Business NZ provided feedback to the Financial Markets Authority as part of its review of 16 class exemption notices due to expire in 2021. The submission focused primarily on exemptions relied upon by cooperatives, including the Small Cooperatives Exemption Notice.

The feedback outlined how these exemptions support the establishment and operation of cooperatives by reducing compliance costs while maintaining appropriate investor protections.

Submission at a glance 

  • Submitted by: Cooperative Business NZ 
  • Date: September 2020 
  • Submitted to: Financial Markets Authority 
  • Policy area: Financial markets regulation and exemptions 
  • Format: Feedback submission (PDF)

CBNZ position

The submission supported renewal of the Small Cooperatives Exemption Notice and recommended deferring substantive changes to allow for fuller consultation. It emphasised that exemptions play a critical role in enabling cooperative formation while preserving investor protections appropriate to member-owned enterprises.

Key issues addressed

  • Reliance of cooperatives on class exemption notices

  • The role of exemptions in enabling cooperative start-ups

  • Compliance costs associated with full disclosure requirements

  • Treatment of cooperative shares as membership instruments

  • Alignment between different exemption regimes

Read the submission [pdf]

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Saya Wahrlich https://www.stocknotstock.com/
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