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1. What is your name?
Name
(Required)
Phil McKinnel
Section 3: Governance of advice
1. As an NZ ETS user, have you received poor, misleading or inaccurate advice on NZU prices or ETS trading? If so, how did this affect you, and what was the financial impact?
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2. As an NZ ETS user, have you received advice with financial implications from an NZU adviser with a real, or perceived, conflict of interest? If so, how did this affect you, and what was the financial impact?
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3. To what extent would an education campaign and information pack improve decision-making for users?
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4. What information could help users and traders make informed decisions about engaging with the NZ ETS or selecting an adviser?
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5. To what extent would voluntary guidelines for advisers improve the quality of their advice?
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6. What should be included in the guidelines to improve the quality of advice?
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7. To what extent would a code of conduct, registration and licensing framework for advisers improve the quality of their advice?
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8. What content would you expect in a code of conduct for advisers?
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9. Which licensing requirements and standards would you expect for an adviser?
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10. What other changes, if any, could improve the quality of advice in the NZ ETS?
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Section 4: Governance of trading
11. To what extent would more visibility on the price or volume of other NZU trades improve transparency in the NZ ETS, and better inform your decisions about buying and selling?
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Information on whether trades are being conducted by market speculators or NZETS participants would be useful in determining if supply and demand indicators where relevant to sale and purchase decisions or if there was attempts at market manipulation or capitalising on investment gains being made.
12. What other types of information would make trades more transparent?
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Whether or not the trades were being made by genuine NZETS participants or investors.
13. To what extent has credit and counter-party risk affected your ability to buy or sell NZUs? What was the financial impact on you?
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Due to constraints imposed on solid fuel producers by lenders, the requirement to lodge collateral prior to auctions has impacted on our ability to participate in the auction process.
Smaller energy consumers are restricted in the same manner.
The financial impact can be considered significant.
Smaller energy consumers are restricted in the same manner.
The financial impact can be considered significant.
14. As a NZ ETS user, what impact would voluntary transaction reporting have on your business or trading activity?
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Increased staff time and costs.
15. As a NZ ETS user, what impact would position reporting have on your business or trading activity?
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Commercially sensitive information may be required to be disclosed. This is not considered to be a positive.
16. As a NZ ETS user, what impact would exchange-based trading have on your business or trading activity?
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17. What other options could increase transparency of trades, or reduce market risks associated with trading NZUs?
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Participation in the NZETS should be restricted to NZU producers, NZU users and NZETS participants.
Restrictions placed on participation of investors and speculators.
Restrictions placed on participation of investors and speculators.
Section 5: Governance of market conduct
18. To what extent would position and purchase limits protect all users against price manipulation, money laundering, and financing of terrorism?
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Limiting the participation in the NZETS to genuine producers and users would likely see a reduction in market volatility and price shocks that have occurred during 2019 - 2021.
19. As a NZ ETS user, what impact would full transaction reporting have on your business or trading activity?
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Negative consquences for protection of commercially sensitive information.
20. What information should be disclosed as part of full transaction reporting?
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Volume and price of transactions. Identification of parties to the transactions should not be disclosed as a matter of course.
21. What other options could reduce the risk of insider trading, price manipulation, money laundering, or financing of terrorism?
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Restriction of participation to producers and users.
Section 6: Appointing a regulator
22. To what extent would appointing a regulator improve trust, efficiency and confidence in the ETS?
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