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NZSAE Association Insights

Practical perspectives for New Zealand association leaders. Straight-up thinking on governance, membership, events, and operations — grounded in real experience and ideas you can actually use.

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  • 18 March 2026 10:17 PM | Brett Jeffery, CAE (Administrator)

    Has your organisation reregistered? Now is the time to check

    As we move closer to 5 April 2026, it is important that every incorporated society in New Zealand confirms whether it has successfully reregistered under the Incorporated Societies Act 2022. The Companies Office is clear that societies wanting to continue operating as incorporated societies must reregister by that date. If they do not, they will be removed from the register on 6 April 2026 and will no longer legally exist.

    This is not something to leave to chance.

    For associations and other membership organisations, legal status matters. If a society is removed from the register for failing to reregister, the consequences can be significant. According to the Incorporated Societies Register guidance, this may include losing access to bank accounts, needing to re-apply for an IRD number, losing separate legal identity, being unable to sign new contracts in the society’s name, and exposing members to potential personal liability for debts or obligations.

    If your organisation believes this has already been sorted, that is good. But now is the time to check and make sure. The official guidance also makes clear that reregistration is not simply a filing exercise. It requires a compliant constitution, a review of operational processes, a general meeting to approve the constitution and the decision to reregister, and then completion of the online application process.

    We recommend every association take a moment to confirm its status on the official Incorporated Societies Register. If you are not yet reregistered, or if you are unsure, urgent action is needed.

    Click here to check your organisation on the Incorporated Societies Register.

    If you check the register and find your organisation has not yet been reregistered — even if you believed this had already been done — do not leave it sitting. With the deadline so close, NZSAE has a team standing by to assist associations that need help working through the process, so please reach out.

    At this point, the message is straightforward: do not assume — check.


  • 16 March 2026 7:13 AM | Brett Jeffery, CAE (Administrator)

    Board Members Paying Membership Fees: Do They Need to Be Disclosed?

    Financial reporting under the Incorporated Societies Act 2022 is bringing many associations closer to the XRB reporting standards, and with that has come increased discussion around related party disclosures.

    One question that is emerging across the sector is simple but surprisingly nuanced:

    If a board member is also a member of the association and pays a membership subscription, does that need to be disclosed in the financial statements?

    Under PBE IPSAS 20, board members are considered related parties because they hold governance responsibility and influence over the organisation. This means transactions between the organisation and board members must be considered when preparing financial statements.

    For most associations, the most common related party transaction is simply the membership subscription paid by board members.

    In many cases these subscriptions are paid on the same terms as every other member and the amounts involved are relatively small. In these situations, many organisations disclose the transactions in aggregate, rather than listing each individual board member separately.

    A typical disclosure may look something like this.

    Example: Related Party Disclosure

    Note X: Related Party Disclosures

    Governing Body and Key Management Personnel

    The members of the Board during the year were:

    • [Name], Chair
    • [Name], Deputy Chair
    • [Name], Board Member
    • [Name], Board Member

    The Board members are considered related parties in accordance with PBE IPSAS 20.

    The Chief Executive is also considered key management personnel.

    Membership Subscriptions

    During the year, Board members paid membership subscriptions on the same terms and conditions as other members. These subscriptions were charged at standard rates and on normal commercial terms.

    Total membership subscription income received from Board members during the year was $X (2025: $X).

    No amounts were outstanding at balance date.

    This approach provides transparency while remaining proportionate. The disclosure acknowledges that related party transactions exist without itemising every individual board member.

    Reimbursements and Other Transactions

    If board members receive reimbursements for travel or other governance expenses, these are often disclosed in aggregate as well.

    For example:

    During the year, Board members were reimbursed $X (2025: $X) for out-of-pocket expenses incurred in the performance of their governance duties. No honoraria were paid.

    Where there are no significant transactions beyond ordinary membership subscriptions, some financial statements simply note:

    Board members transact with the Society in the ordinary course of membership. All transactions are conducted on normal terms and conditions. No material related party transactions occurred during the year.

    When Greater Disclosure Is Required

    More detailed disclosure is expected where the relationship goes beyond normal membership activity. For example:

    • a board member’s company supplies services to the organisation
    • consultancy or professional services are provided by a board member
    • loans or financial arrangements exist
    • special pricing or non-arm’s-length arrangements occur

    In these situations, the XRB standards expect clear and transparent disclosure.

    A Practical Reality: Interpretation

    One important point to recognise is that there is still a degree of professional judgement involved.

    While many accountants and auditors are comfortable with aggregate disclosure for routine transactions such as membership subscriptions, some auditors take a stricter view and may expect individual board member transactions to be listed separately.

    In practice, this means the approach adopted can depend on the interpretation of your accountant or auditor. The underlying principle remains transparency, but how the disclosure is presented can vary between organisations.

    The Bottom Line

    For most associations:

    • Board members paying standard membership subscriptions is entirely normal.
    • The amounts are typically small relative to overall revenue.
    • Disclosure is usually made in aggregate form.

    However, societies should discuss the approach with their accountant and auditor to ensure it aligns with their interpretation of the XRB standards.

    As always, organisations should confirm the approach with their accountant or auditor to ensure it aligns with their interpretation of the XRB reporting standards.

    What matters most is that organisations acknowledge the relationship and ensure the financial statements provide clear and transparent information to members.

  • 01 March 2026 2:22 PM | Brett Jeffery, CAE (Administrator)

    Key NZ Employment Law Changes That Will Matter to Associations and Their Staff Arrangements

    (As at 26 February 2026)

    1. Employment Relations Amendment Act 2026 (In Force)

    1.1 Personal Grievance Changes

    High-Income Threshold

    • Employees earning $200,000+ total remuneration cannot bring a personal grievance for unjustified dismissal or disadvantage unless both parties agree otherwise.
    • Existing employees have a 12-month window to opt in to retain protections.

    Remedies Reduced Where Employee Contributed

    • Compensation may be reduced or eliminated entirely where employee conduct contributed.
    • Reinstatement is no longer available where employee behaviour contributed.

    Justification Test Adjusted

    • Procedural defects alone will not automatically make a dismissal unjustified unless they result in substantive unfairness.

    Impact for Associations
    Stronger footing in dismissal situations involving misconduct. Reduced exposure at the top remuneration level. Process still matters.

    1.2 Contractor vs Employee – Statutory “Gateway Test”

    To qualify as a specified contractor, all criteria must be met:

    • Written agreement specifying contractor status.
    • Freedom to work for others.
    • No minimum required availability period.
    • Ability to subcontract.
    • No termination for refusing additional tasks.

    Impact for Associations
    More certainty — but only if documentation and practice align precisely.

    1.3 Removal of the 30-Day Rule

    • New employees no longer need to start on collective agreement terms for the first 30 days.

    Impact for Associations
    Simplifies onboarding. Templates must be updated.

    1.4 Trial Period Protections Expanded

    • Employees dismissed under a valid trial period cannot raise a grievance for unjustified dismissal or disadvantage relating to that dismissal.

    Impact for Associations
    Trial periods are now a stronger risk-management tool — provided agreements are correctly drafted.

    2. Crimes (Theft by Employer) Amendment Act 2025

    • Withholding wages can constitute theft under the Crimes Act 1961.
    • Elevates non-payment from a contractual issue to potential criminal liability.

    Impact for Associations
    Payroll accuracy is now a governance risk. Controls must be robust.

    3. Pay Transparency and Pay Equity Changes

    3.1 Pay Transparency (August 2025)

    • Employees cannot be disciplined for disclosing their pay details.

    3.2 Equal Pay Amendment Act 2025

    • Revised framework and thresholds for pay equity claims.

    Impact for Associations
    Remuneration systems must be defensible and transparent. Confidentiality clauses restricting pay discussion are unenforceable.

    4. Other Relevant Updates

    Minimum Wage & Training Rates

    • Updated in 2025. Ensure payroll compliance.

    Leave Reform (Proposed)

    • Employment Leave Act intended to replace the Holidays Act (not yet in force).

    Fair Pay Agreements

    • Repealed. No current compliance obligation.

    Accredited Employer Work Visa (AEWV)

    • Adjustments affect migrant employee conditions.

    What This Means for Associations – Practical Checklist

    Immediate Actions for Boards and Executives

    • Review employment agreements (especially senior roles near $200k).
    • Audit contractor arrangements against gateway criteria.
    • Update dismissal and performance policies.
    • Strengthen payroll oversight and sign-off controls.
    • Refresh onboarding documentation.
    • Review remuneration transparency settings.

    References

    Employment Relations Act changes take effect today | Employment New Zealand

    Employment Relations Amendment Act

    Major reform to employment law: the Employment Relations Amendment Act 2026 - Lane Neave

    Employment Law changes with the Employment Relations Amendment Act 2026 - Christchurch Lawyers and Legal Advice » Harmans Lawyers

  • 18 February 2026 8:45 AM | Brett Jeffery, CAE (Administrator)

    Work Isn’t a Place Anymore — It’s a Discipline

    This morning I’m sitting at the Aotea Centre in Auckland.

    Laptop open.
    Phone hot-spotted.
    Coffee close by.
    NZSAE Professional Development Committee dialled in and around the table.

    And in my hand, a “space pen” gifted by Darren from the Steel Construction Association — apparently it writes in space. I haven’t tested that claim, but it writes perfectly well in a civic centre foyer.

    Twenty years ago, this would have been unusual.
    Ten years ago, it would have been labelled “flexible.”
    Today, it’s simply how we work.

    Work Has Shifted — Permanently

    For associations in New Zealand, the idea that work must happen in an office from 9 to 5 no longer holds.

    We travel.
    We meet members where they are.
    We run committees from airports.
    We hotspot our phones when Wi-Fi fails.
    We draft board papers in hotel lobbies.
    We host webinars from home offices.
    We hold governance discussions across cities.

    The tools are straightforward:

    • A reliable laptop

    • A strong phone connection

    • Cloud-based systems

    • A bit of discipline

    That’s it.

    The shift hasn’t just been technological — it’s cultural.

    The Association Sector Is Built for Mobility

    Associations, by nature, are distributed.

    Our members are nationwide.
    Our boards are often in different regions.
    Our events move city to city.
    Our stakeholders are not confined to one postcode.

    So why should we be?

    The modern association executive can operate:

    • From a conference venue between sessions

    • From a regional café before a member visit

    • From a major city civic space like the Aotea Centre

    • From home

    • From anywhere with signal and intent

    The office is no longer the centre of gravity. The mission is.

    But Let’s Be Clear — This Isn’t About Slowing Down

    Remote work doesn’t mean casual work.

    In fact, it requires more discipline, not less.

    You need:

    • Structure in your diary

    • Clear outcomes for meetings

    • Reliable systems

    • Strong governance processes

    • Trust within your team

    Working anywhere only works if you know exactly what you’re there to achieve.

    The danger isn’t flexibility — it’s drift.

    Big Centres, Small Corners

    One of the advantages of operating in our larger centres — Auckland, Wellington, Christchurch — is that there are professional spaces everywhere.

    Conference venues.
    Hotels.
    Shared civic buildings.
    Libraries.
    Quiet foyers.
    Airport lounges.

    You can conduct serious business in any of them.

    This morning’s committee discussion was no less robust because we weren’t in a formal boardroom. The work still mattered. The outcomes still count.

    The environment changes. The responsibility does not.

    What This Means for Associations

    If we’re honest, many associations still design their internal structures around older models of work.

    Policies assume presence.
    Systems assume office servers.
    Processes assume paper.

    But our members are modern.
    Our partners are mobile.
    Our workforce is hybrid.

    If we want associations to remain relevant beyond 2030, we must reflect the way professionals actually operate.

    Mobility is no longer a perk.
    It’s infrastructure.

    A Final Thought

    The ability to work anywhere is a privilege.

    But it’s also a reminder.

    Our role is to strengthen membership organisations across New Zealand. That responsibility doesn’t switch off because we’re in a different building.

    Today it’s the Aotea Centre.
    Tomorrow it might be Wellington.
    Next week Rotorua.

    The location changes.
    The purpose doesn’t.

    And for the record — the space pen works just fine in Auckland.


  • 09 February 2026 7:32 AM | Brett Jeffery, CAE (Administrator)

    Conference Standards Work – Update for Members

    Thank you to everyone who contributed to the Conference at a Crossroads discussions. The feedback was clear, practical, and consistent.

    A Conference Standards Group of experienced association executives has now met to help shape how this work is progressed in practice.

    Members highlighted:

    • increasing cost pressure and pricing uncertainty

    • inconsistent quoting and late add-ons

    • challenges understanding AV and technical costs

    • the need for practical tools that support teams with varying levels of experience

    The message was not about prescribing how conferences should be run, but about improving clarity, confidence, and consistency.

    What we are focusing on first

    Based on the group’s input, NZSAE will focus initially on:

    • Standardised RFP and quotation templates

    • Clearer guidance on pricing transparency and add-ons

    • Practical frameworks and checklists for association teams

    • Foundational standards for supplier, sponsor and exhibitor engagement

    What happens next

    NZSAE will begin drafting practical tools and guidance, alongside a national member survey to build an evidence base. Draft materials will be tested with the Conference Standards Group before being shared more widely.

    This work is about reducing uncertainty and supporting better outcomes for associations — not setting prices or limiting choice.

    Should you wish to be involved please email Brett


  • 02 February 2026 8:37 AM | Brett Jeffery, CAE (Administrator)

    When “Yes” Becomes the Default

    By February, most New Year’s resolutions have already slipped away. The year has found its rhythm again, the inbox is full, and work feels familiar.

    For me, this is usually the point where I stop and take stock — not of big goals, but of how I’m actually showing up day to day.

    In associations, “yes” is our default setting. And I include myself squarely in that.

    Yes to helping.
    Yes to another call.
    Yes to one more request that wasn’t in the plan.

    It comes with the territory. Supporting members, answering questions, making ourselves available — that’s what association people do, and we’re generally pretty good at it.

    But lately, I’ve been realising that always saying yes doesn’t automatically mean I’m being as effective as I could be.


    Noticing the pattern

    Most requests are reasonable. Most conversations are worthwhile. And that’s what makes it tricky.

    What I’ve noticed, though, is how easily days can become reactive. One request leads to another, and before long, time that should be going into longer-term work gets pushed out — not because it isn’t important, but because it’s less urgent.

    None of this is about being unwilling to help. It’s more about recognising that capacity isn’t unlimited.

    Rethinking what “no” really means

    I’m trying to get more comfortable with the idea that saying no — or at least not yes straight away — isn’t the same as saying no to members.

    Sometimes it’s a:

    • not right now

    • not in that way

    • let’s come back to this

    • or here’s a better place for this to land

    That shift feels small, but it’s harder than it sounds.

    A small adjustment, not a big resolution

    This isn’t a grand resolution or a dramatic change. It’s just an intention to pause a little more before responding, and to be clearer with myself about what actually needs my time and attention.

    Associations are long-term organisations. If we want to keep doing this work well, there’s probably value in being a bit more deliberate — even when our instinct is to say yes.

    I don’t have this sorted. But it feels like a useful thing to notice as the year settles in.

    And if it resonates with others in the sector, that’s probably a good sign we’re not alone.

    Brett 


  • 22 January 2026 4:19 PM | Brett Jeffery, CAE (Administrator)

    Outsourcing is often talked about as if it’s now standard practice in associations. The data tells a more measured story.

    Based on recent NZSAE survey results, only around 35% of New Zealand associations currently outsource any part of their operations. The majority still operate fully in-house, typically with small teams managing a wide range of responsibilities.

    That context matters.

    Outsourcing is not the norm. It is a considered option used by a minority of associations — but one that offers useful insight into how organisations are managing workload, capability, and sustainability.

    What is being outsourced

    Among the associations that do outsource, the approach is targeted rather than extensive.

    The most commonly outsourced areas relate to back-office and specialist support, particularly:

    • Accounting, financial, and bookkeeping support

    • Administrative and account management support

    • Event and conference delivery

    • Graphic design and communications assistance

    Importantly, accounting and administrative functions are often delivered as a combined back-office service, rather than as distinct roles. In practice, many associations engage a single provider to manage invoicing, reconciliations, payroll processing, and basic reporting alongside general administrative support.

    This reflects how smaller associations actually operate — outsourcing capability, not job titles.

    Outsourcing is measured in hours, not headcount

    Rather than outsourcing whole functions, most associations engage contractors for defined, limited time commitments:

    • Short weekly engagements (2–10 hours)

    • Part-time ongoing support (10–20 hours per week)

    This suggests outsourcing is being used to supplement lean teams, providing specialist support where needed without adding permanent roles.

    Why associations choose to outsource

    For those associations that outsource, the drivers are pragmatic:

    • Cost certainty

    • Access to specialist expertise

    • Flexibility to scale support up or down

    Annual outsourcing costs vary, but generally remain well below the full cost of employing equivalent in-house roles once salary, leave, KiwiSaver, and overheads are considered. For boards managing financial risk, that flexibility is significant.

    What remains in-house

    It is equally telling what associations continue to keep in-house.

    Leadership, member relationships, and strategic direction overwhelmingly remain internal functions. These are seen as central to the organisation’s identity, credibility, and long-term success — and are not readily outsourced.

    The real insight for boards

    The takeaway is not that associations should outsource.

    It is that:

    • Most associations still don’t

    • Those that do are deliberate and targeted

    • Outsourcing works best when it supports focus, not when it replaces core capability

    For boards and CEOs, the more useful question isn’t “Why aren’t we outsourcing?”
    It’s “Is our current structure still fit for purpose given the size, complexity, and expectations placed on the organisation?”

    That’s where the real conversation begins.


  • 19 January 2026 9:14 AM | Brett Jeffery, CAE (Administrator)

    NZSAE has been advised of an upcoming call for nominations to Industry Skills Boards, overseen by the Tertiary Education Commission (TEC). This is a significant opportunity for association executives and senior leaders with an interest in workforce development, vocational education, and training.

    There are eight Industry Skills Boards, each playing a critical role in shaping training and workforce priorities across New Zealand:

    • Transport
    • Construction & Specialist Trades
    • Food & Fibre
    • Energy & Infrastructure
    • Manufacturing & Engineering
    • Services
    • Education, Health & Community
    • Electrotechnology & IT

    Each Board currently has five members, with a further three appointments per Board to be made by 31 March 2026.

    Why this matters

    Industry Skills Boards:

    • Set training and skills standards
    • Endorse and moderate vocational training programmes
    • Advise government on funding priorities
    • Undertake workforce and skills analysis
    • Act as the sector voice on education and training

    For association leaders, this is a genuine opportunity to influence the future skills pipeline for your sector and represent industry needs at a national level.

    Appointment details

    • Board fees: approximately $30,000 per annum
    • Term: 2–4 years
    • Experience: strong governance, sector knowledge, and workforce or training insight are key

    Key dates

    • Nominations open: 21 January 2026
    • Nominations close: 18 February 2026 (5.00pm)
    • Appointments confirmed: by 31 March 2026

    A wider opportunity for associations

    In addition to Board appointments, the regulations require each Industry Skills Board to formally engage with industry associations and peak bodies.

    This presents a potential opportunity for NZSAE — and for member associations — to:

    • Act as a recognised conduit for sector consultation
    • Support member input into skills and training discussions
    • Strengthen the role of associations in workforce planning

    NZSAE will continue to explore where this aligns best with our coverage and member capability.

    Further information

    Links to the nomination process will be shared once they go live on the TEC website.

    If you’re considering applying and would like to talk it through, feel free to get in touch.

    Here for associations
    Brett

  • 15 January 2026 4:22 PM | Brett Jeffery, CAE (Administrator)

    Is Your Association Website Up to Standard for 2026?

    Most association websites look fine on the surface. But many are still hard to use, hard to manage, and disconnected from how the association actually operates.

    For 2026, the question isn’t “Do we need a redesign?”
    It’s “Is our website actually helping our members, staff, and volunteers do their jobs?”

    Below are five simple, testable checks you can use to answer that — no theory, no technology debate, just practical reality.

    1. Can a New Member Find What They Need in Under Two Minutes?

    If someone joined your association today, could they quickly:

    • log in
    • see upcoming events
    • access member-only resources
    • update their personal or organisational details

    If the answer is no, that’s friction.

    And friction loses members — not because they’re unhappy, but because things feel harder than they should be, especially in those first few weeks after joining.

    Early member experience matters. If people struggle to find their way around straight away, confidence drops and engagement stalls.

    A member portal doesn’t need to be clever or clever-looking. It needs to be clear, obvious, and reliable — so members can get on with why they joined in the first place.

    2. Is Your Website Doing Work Your Staff Shouldn’t Be Doing?

    Take an honest look at where staff time goes.

    If your team is regularly:

    • emailing PDFs
    • manually updating member records
    • resending event details or links

    then your website isn’t pulling its weight. A well-set-up association website should reduce admin, not create more of it. If staff are acting as the bridge between members and information, something isn’t working.

    3. Does Your Site Reflect How Your Association Actually Works?

    Most associations evolve over time. Boards change. Committees form and dissolve. SIGs come and go. Events grow. Resources build up.

    The problem? Websites often don’t keep up.

    Ask yourself:

    • Is the structure of your site clear and logical?
    • Do boards, committees, interest groups, events, and resources make sense to someone new?

    If only “the person who built it” understands how things fit together, that’s a risk — especially when staff or suppliers change. Your website should mirror how the association operates today, not how it operated years ago.

    4. Is Your Content Written for Members — Not About the Organisation?

    This is a common one.

    Many association websites talk about the organisation:

    • history
    • structure
    • internal language

    But members are asking a different question: “How does this help me do my role better?”

    When reviewing a page, ask:

    • Does this help a member take action?
    • Does it answer a real question they have?
    • Is it written in plain language they’d actually use?

    If not, it’s probably serving the organisation — not the membership.

    5. Can You Improve One Thing Without Rebuilding Everything?

    This is the most important check.

    If every improvement requires a full rebuild, the issue isn’t design — it’s setup.

    Strong association websites are modular:

    • you can fix navigation without redesigning the homepage
    • improve member access without changing branding
    • tidy structure without touching content

    If change feels risky, expensive, or impossible, that’s a signal worth paying attention to.

    The Bottom Line

    For 2026, associations don’t need prettier websites. They need websites that:

    • reduce workload
    • support members properly
    • reflect how the organisation actually functions
    • get used — not worked around

    Start small. Fix what’s slowing you down. Build from there.

    If you’d like help thinking through where to start, that’s exactly the conversation NZSAE is here for.

  • 21 November 2025 2:58 PM | Brett Jeffery, CAE (Administrator)

    The AML/CFT settings have been under review for some time, and many organisations across New Zealand have been calling for more workable, real-world requirements. Last week, the Statutes Amendment Bill passed its final reading, bringing several practical updates into force immediately.

    For associations and membership bodies that interact with AML-regulated environments — whether through financial services, professional services, or sector partnerships — these changes will matter.

    Address Verification No Longer Required for Standard CDD

    The headline change is simple but significant:

    Address verification is no longer required as part of standard customer due diligence (CDD).

    This step now only applies when there’s a higher-risk situation under enhanced due diligence.

    For years, organisations have highlighted the difficulty of collecting physical address documents when the risk profile didn’t justify it. This amendment brings the law more in line with how organisations operate, supported by sector submissions including work from Lyn McMorran and the Financial Services Federation.

    It’s a shift toward a more risk-based, proportionate approach — something long requested by many associations.

    More Time for Reporting Obligations

    Two further changes aim to improve reporting quality and practicality:

    • Prescribed Transaction Reports (PTRs) now have a longer timeframe for submission.
    • Suspicious Activity Reports (SARs) also have extended submission times.

    For organisations working alongside AML-regulated providers — or operating within regulated settings themselves — this should ease reporting pressure and support more accurate, complete information.

    Clarification on “Occasional Transactions”

    Another helpful change clarifies the definition of “occasional transaction.”
    Cheque deposits made at a registered bank or non-bank deposit taker are now excluded from this definition.

    This removes ambiguity and helps prevent organisations being captured by rules not intended for low-risk, routine actions.

    Why These Changes Matter for Associations

    Many associations may not be directly captured by the AML/CFT Act, but often work alongside sectors that are. Others have members affected by changing compliance expectations.

    These amendments demonstrate a move toward:

    • More practical compliance requirements
    • A better fit with how organisations actually operate
    • Clearer proportionality and risk focus

    They also show that sector feedback is being taken seriously — especially where compliance obligations have become unnecessarily burdensome.

    What Happens Next

    The Ministry of Justice will update formal guidance shortly. Until then, the amendments apply immediately.

    If you or your members need further detail, the AML/CFT Programme Team can be contacted at aml@justice.govt.nz.

    View the ministerial press release.

    The amendments included in the Statutes Amendment Bill:

    • clarify that address verification is not required for standard customer due diligence and only required under enhanced due diligence
    • extend submission timeframes for Prescribed Transaction Reports
    • extend submission timeframes for Suspicious Activity Reports
    • clarify that cheque deposits at registered banks or non-bank deposit takers are excluded from the definition of “occasional transaction”


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