3.20 Article 32(5) of CCD2

Closed19 Sep, 2024, 12:00 - 18 Oct, 2024, 17:00

Under CCD2 Member States remain free to maintain or introduce additional obligations incumbent on creditors and credit intermediaries, including the conditions under which a creditor or credit intermediary may receive payments from a consumer prior to the conclusion of a credit agreement.

Question 20 – Should Ireland prohibit or impose restrictions on the payments from a consumer to a creditor or a credit intermediary prior to the conclusion of a credit agreement?

CUMA does not find it reasonable to impose a prohibition or restrictions of this kind. It seems fair and beneficial for consumers that service providers receive remuneration, regardless of whether...
No. Imposing restrictions on the payments from a consumer to a creditor or a credit intermediary prior to the conclusion of a credit agreement may result in unintentional consequences. We...
No. We are not fully sure what payments are referred to in this article.  
We do not see the merit in a prohibition or imposing restrictions of this nature. We believe it is  fair, and in the interest of the consumer, that the service provider is remunerated...
Intermediaries must be remunerated for the work they undertake in relation to credit agreements. If an intermediary is undertaking to advise a consumer on the most suitable option for them, they...