3.1 Article 2(5) of CCD2

Deferred debit cards are credit cards available on the market where the total amount of transactions is debited from the cardholder account at a pre-agreed specific date, usually once a month, without interest to be paid.

In transposing this directive, Member States may exempt certain credit agreements in the form of deferred debit cards where a credit institution or a payment institution provides the service and where -

a. the credit needs to be repaid within 40 days, and

b. is free of interest and without any other charges, and

c. there are only limited charges linked to the provision of the payment service. 

This exemption should be without prejudice to the application of relevant provisions on overdraft facilities or overrunning, which should apply in case the repayment exceeds the positive balance in the current account.

Question 1 - Should debit cards, which comply with the above conditions, be exempted from the transposition of CCD2 in Ireland, and if so why?