No. To ensure sufficient consumer protection and to avoid consumers becoming over-indebted, qualifying enterprises should be required to meet the regulatory requirements i.e., registration and...
3.22 Article 37(3) of CCD2
Closed19 Sep, 2024, 12:00 - 18 Oct, 2024, 17:00
CCD2 provides that Member States should ensure that creditors and credit intermediaries, including non-credit institutions, are subject to an adequate admission process including an authorisation process or entering the non-credit institution in a register, and supervision arrangements by a competent authority.
Member States may exempt those suppliers of goods or providers of services from the admission and registration requirements who qualify as micro, small and medium-sized enterprises as defined in Commission Recommendation 2003/361/EC. Such suppliers and providers must act as credit intermediaries in an ancillary capacity or grant credit in the form of deferred payment for the purchase of goods and services offered by them. The credit must be provided free of interest and charges,
Question 22 – Should Ireland exempt qualifying enterprises from registration and supervision arrangements?
Contents
Materials
Observations
Observations
No. The provision of credit and other services is subject to domestic legislation, codes, regulations as well as a suite of EU Directives and regulations in order to protect the consumer and to...
The regulations must be proportionate and balanced while protecting the consumer. While these firms could possibly be exempt from certain aspects of the directive they should still be required to...
We do not believe it is proportionate for retailers offering interest free, short term loans to be required to hold a credit broker licence or similar authorisation, given the lower risk nature of...