Yes, there should be more stringent consumer protection provisions than those set out in Article 24. Article 24 paragraph (3) of the CCD2 requires a credit provider to notify the consumer at least 30 days prior to it reducing or cancelling an overdraft facility. This should be extended to at least 90 days to give the consumer adequate time to consider their overdraft position, arrange alternative banking and credit solutions if required, and seek any necessary independent advice.
Paragraph (4) of Article 24 allows for 12 equal monthly instalments repayment of the overdraft facility at no additional cost, but at the borrowing rate applicable to the overdraft facility. 12 months may not be enough for some consumers to repay their overdraft. Consideration should be given to allowing consumers, on foot of an assessment of their financial circumstances, longer than 12 months to pay back their overdraft.