Caibidil: 3. Consultation Questions » 3.11 Article 18(11) of CCD2Question: Should Ireland continue to require creditors to consult with appropriate databases as part of the creditworthiness assessment? Yes it is important that for loans such as mortgages that the CCR is referenced. Also for personal loans that are large. There is an argument that small loans under €200 should be exempted from this requirement.