Mr H Bennett: Consultant led the presentation which highlighted the following key issues: . This submission was mainly concerned with Section 2 and 3 of the HELA Bill and the consequences of the proposed amendments for education generally and for private higher education service providers specifically. . The submission was also concerned with the term "offered" which needs to be defined since the Act did not provide significant definition to the term and this might add additional uncertainty. . It further alluded that the amendments to the Act may have the effect of isolating the country's higher education from the rest of the world and this might discourage the presence of some high quality providers that could assist in meeting the national agenda. . The Bill cannot be promoted in its current form if there is any likelihood that its effect would be either to deprive or discourage students from access to a range of education opportunities and relationships just on the grounds of their being international. . The proposed section 65 (d) to the Higher Education Act introduced by Section 3 of the Bill repeats the provision of section 51(2) but extends the prohibition on offering unregistered qualifications to all persons. The reality is that part of qualifications cannot currently be registered on the NQF so even if reasonable, this is not enforceable. . The further statement that no certificate or diploma (or degree) can be offered by a private higher education institution unless it is registered on the HE sub framework of the NQF could be read to mean that ALL certificates or diplomas are higher education qualifications and this is currently not the law.