3.9 Article 16(4) of CCD2

Unique Reference Number: 
DFIN-C8-1
Status: 
Submitted
Submission: 
Brokers Ireland Submission on Consumer Credit Directive - CCD2
Author: 
Brokers Ireland
Consultation: 
Consumer Credit Directive - CCD2
Date Submitted: 
15.10.2024 - 15:13

3.9 Article 16(4) of CCD2

Chapter: 
3. Consultation Questions » 3.9 Article 16(4) of CCD2
Question: 
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?

No, there should be no restrictions on using the terms “independent advice” and “independent advisor” for credit intermediaries who are not tied to one credit institution whilst acknowledging that individual member states may have restrictions on the use of the term “independent”.  Credit providers should be restricted from using the terms “independent advice” and “independent advisor”.