We have no strong view on the prohibition of such terminology. A credit union can offer a range of services. This can include a review of a member’s current financial arrangements and advice on a range of products to meet that members financial needs. The credit union acts as intermediary between the consumer and a product provider. Such services are regulated under Section 48 and Schedule 2, S.I. No. 1 of 2016 (or under Sections 48 – 49, Credit Union Act 1997). Credit unions do not use the term “independent advice or “independent advisor” to describe their services or advice in relation to credit agreements. That said, once the credit institution stipulates in relation to such services that there is no preferred provider commission and meets the requirements of Provision 4.58A Addendum to the Consumer Protection Code (Central Bank of Ireland, September 2019) could act as a counter-balance. Perhaps the matter should form part of the discussion/revisions to the existing Consumer Protection Code (CP158 and draft Central Bank (Supervision And Enforcement) Act 2013 (Section 48) (Conduct Of Business) Regulations 20[ ]).