Position paper
In its response to the Central Bank of Ireland consultation on the Consumer Protection Code, Finance Watch stresses that technology should not allow to exploit customer vulnerabilities, advocates for a clear, fair Alternative Repayment Arrangements and pleads for convergence and transparency in considering clients’ sustainability preferences.
On 7 June 2024, Finance Watch responded to a consultation from the Central Bank of Ireland for the review of its Consumer Protection Code. The consultation covers a wide range of topics including the protection of consumers in a digital context, the protection of vulnerable consumers in the context of mortgage credits and the consideration of consumers’ sustainability preferences.
Finance Watch welcomes the initiative of the Central Bank of Ireland and shared targeted recommendations including:
- Finance Watch suggests that the Code of Conduct on Mortgage Arrears also introduces a requirement that ensures that creditworthiness assessments conducted prior to providing a borrower an ARA is used as a means to ensure that an ARA is offered that is suitable and sustainable rather than being a barrier to accessing an ARA.
- Finance Watch strongly agrees that there is a need to introduce a requirement for all firms to train staff on vulnerability issues and proposes to extend it to trainings about basic products that are tailored/suitable to vulnerable consumers.
- Finance Watch also highlights that the current rules on the consideration of sustainability preferences, including the ESMA guidelines and EIOPA guidance on the implementation of the consideration of the sustainability preferences, are too flexible and that priority loopholes should be solved.
