3.5 Article 8(8) of CCD2

Unique Reference Number: 
DFIN-C8-3
Status: 
Submitted
Author: 
BPFI

3.5 Article 8(8) of CCD2

No. Reference to the “ease and speed” of accessing credit would seem to imply that the product poses a higher risk or that access is based on an unsound credit decision. It is important to note that this is not the case, as credit assessment criteria is always robust and in line with regulatory requirements. This leads us to believe that Ireland should not prohibit advertising that accentuates the ease and speed of the application or credit process, as to do so may result in unintended impacts on consumers.

In the case of discounts and payment breaks, which would result in a cost to the consumer or which may mask an underlying inability to pay, differentiating such features may warrant consideration.