We appreciate why consumer rights in respect of overdraft facilities and overrunning are captured as part of CCD2, however we believe that Article 24(1)-(4) provides a sufficient level of protection for consumers accessing overdraft facilities. Additional requirements with respect to overdraft facilities are required by credit unions as part of the current additional services application process (under Sections 48-52, Credit Union Act 1997) for services known as a Member Personal Current Account Service (MPCAS). As a result, further stringent consumer protection provisions under Article 24 should not apply to credit unions.