No, not for credit unions. As set out in the explanatory memo credit unions are subject to an interest rate cap of 2% per month as part of Credit Union (Amendment) Act 2023. The Act also made changes to Section 38(b) of the CUA to remove the requirement that the interest on a loan included all the charges made by the credit union in making the loan. Bringing in further limitations at this stage via this Directive would run counter to consistent and predictable legislative outcomes.
We would argue that the maximum interest rate for High-Cost Credit Providers as provided for in the Consumer Credit (Amendment) Act 2022 and SI 576 of 2022, should be reduced from 48% per annum to 36% per annum. The Central Bank is mandated in the Consumer Credit (Amendment) Act 2022 to prepare a report within three years of the commencement of the Act. This is critically important that this work is completed urgently.