3.9 Article 16(4) of CCD2

Providing advisory services is an activity that may be combined with other aspects of granting or intermediating credit. Given the importance which consumers attach to the use of the terms 'advice' and 'advisors', Member States may prohibit the use of those terms, or of similar terms, where such advisory services are being provided to consumers by creditors or credit intermediaries. It is appropriate to ensure that Member States impose safeguards where advice is described as independent to ensure that the range of products considered and remuneration arrangements are commensurate with consumers' expectations of such advice.

Question 9 – Should the use of the terms “independent advice” and “independent advisor” or other similar terms be prohibited where these services are provided by the credit provider or credit intermediary?