Unique Reference Number: 
DFIN-C8-6
Status: 
Submitted
Author: 
CUMA - Credit Union Managers Association

3.5 Article 8(8) of CCD2

No. Consumers should have the freedom to prioritise what matters most to them in making credit decisions. While interest rates are an important consideration, they are not always the only factor driving the decision. For many, the convenience and speed of an online loan application process may be a deciding factor.

With clear and transparent advertising, consumers should be able to compare various products and select the one that best suits their needs. Therefore, CUMA would not agree that offering discounts based on accepting credit needs to be prohibited. As with any loan, a borrower’s ability and willingness to repay should remain the primary factor in determining whether the loan is granted. Finally, credit assessment criteria should always be robust and in line with regulatory requirements.