No, an outright ban on commissions paid by a credit providers to a credit intermediary should not be necessary given the proposed requirements to protect consumers as set out in Regulation 20 of the...
3.19 Article 32(4) of CCD2
Closed19 Sep, 2024, 12:00 - 18 Oct, 2024, 17:00
CCD2 requires creditors and credit intermediaries to act with integrity, transparency and impartiality in the design, promotion and conduct of credit services. Such responsible behaviour should avoid practices that have a negative impact on consumers, and appropriate management of conflicts of interest including those arising from remuneration, as well as to give advice in the best interests of the consumer. Member States shall impose safeguards on creditors and credit intermediaries to ensure that the range of products considered and remuneration arrangements are commensurate with best interests of consumers. This might include a prohibition on commissions paid by the creditor to the credit intermediary.
Question 19 – Should Ireland impose a ban on commissions paid by a creditor to a credit intermediary?
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Materials
Observations
Observations
CUMA does not believe there is a valid reason to impose a ban on such commissions. Section 26 of the Credit Union Amendment Act 2023 introduces a new provision allowing credit unions to refer members...
No, given the potential for unintended consequences for consumers and lenders. Credit intermediaries are an important distribution channel delivering a convenient point-of-sale option for consumers,...
No. We do not favour a ban on commission as parts of the Credit Union (Amendment) Act 2023 as commenced by SI 475 of 2024 relating to referral of members may involve a fee or commission. Adding...
We do not see the merit in a ban on such commission. The Consumer Protection Code sets out onerous requirements with respect to remuneration and transparency, including in the Addendum to the...