Central Bank of Ireland Consumer Code: have your say – Financial services


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Financial services providers in Ireland have until the end of March 2023 to respond to questions raised in a discussion paper published by the Central Bank of Ireland on its plans to revise the consumer protection code.

The global pandemic, Brexit and technological advancements are just some of the catalysts for change in the financial services landscape in Ireland. The purpose of the discussion paper, published in October 2022, is to break down some of these factors and engage with stakeholders to identify the specific revisions that are needed to the Consumer Protection Code (CPC) Therefore.

Submissions to questions raised in the discussion paper are open until March 31, 2023 with comments to be provided in Q3 2023.

CPC was born over 30 years ago and although there have been many updates, there has not been a significant code overhaul since 2012.

Gabriel Makhlouf, Governor and Chairman of the Central Bank Commission, explained that the Central Bank: “must ensure that we continue to evolve our consumer protection framework and that it responds to the challenges facing consumers of financial services, today and in the future”.

The working document is divided into two main themes:

Availability and choice

The objective is to have an efficiently functioning market with appropriate levels of competition, fair and transparent pricing, providing consumers with what they need.

Act in the interests of consumers

While providing a profitable and sustainable business model, a financial services provider has a fundamental responsibility to place the best interests of consumers at the center of the design and delivery of its products and services.

Within these themes, some of the key topics on which the Central Bank is seeking input are:

  • Innovation and disruption – what can be done to support innovation while protecting consumers?

  • Digitization – what are the challenges and risks?

  • Non-regulated activities – should there be additional obligations for regulated companies undertaking non-regulated activities?

  • Pricing matters – how can price transparency be improved for consumers?

  • Information efficiency – can regulation/technology be used to improve it?

  • Climate change – how will the availability, choice and pricing of financial services and products be affected?

And then ?

As part of phase 2, a public consultation document is to be published in the fourth quarter of 2023. This will define the draft regulations and the proposed changes to the CPC.

Phase 3 will see the updated code and related regulations released.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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