3.4 Article 2(8) of CCD2
Yes. Credit agreements for amounts under €200 should be exempt from advertising, pre-contractual information on credit agreements and information to be included in credit agreements. Whilst consumers should have the same level of information and disclosure, it is with consumers in mind that we take this view. Meeting regulatory requirements for credit of low amounts can come at a cost to the credit providers that exceed at return derived from the product - making such loans untenable by consumers or reduce choice of credit providers in the market. A proportionate regulatory approach benefits the consumer. Credit unions offer consumers choice when it comes to low value loans – a trusted, highly regulated credit provider, also offering wider financial services including the ability to save. Credit unions offer loans to members on low value incomes and social welfare payments (including but not exclusively through a collaborative scheme known as “It Makes Sense” loan scheme). Whilst, assessing capacity to repay is not compromised, less onerous regulatory requirements support the provisions of such products. In support of members, some credit unions will provide loans as low as €100. Often such loans are required to repay a more costly credit product, when something unexpected occurs, or/and a loan is required urgently.