Yes, the use of such terms should be prohibited for Credit intermediaries. Credit intermediaries continue to fall outside the Central Bank’s Consumer Protection Code and are currently subject to a very limited statutory authorisation regime. The CCPC continues to advocate that credit intermediaries should be under the supervisory frameworks of the Central Bank of Ireland.
Even if the intention of a credit intermediary is to provide independent impartial advice, this would be very difficult should there be commission or other incentives available from providing a particular credit product to a consumer.
Appropriate periods of time should be set out to allow consumers avail of independent advice, from a provider of their choosing, before they sign a credit agreement.