Yes. Credit Unions have members who must join before accessing credit or using the credit union. This is set out in Section 17 of the CUA. It could be read in such a way that for the abundance of caution, maintaining this exemption allows credit unions to operate in line with the CUA.
The Credit Union and Co-operation with Overseas Regulators Act 2012 introduced the concept of “attached savings” in Section 32 of the CUA. This is effectively a form of security where the credit union can specify that members’ shares are “attached” to the loan.
This highlights the need to take account of the interaction between domestic legislation namely the Consumer Credit Act 1995 as amended, the Consumer Protection Code, the CAU and this Directive when transposing this Directive.