Consumer Protection 2016 Priorities And Risks


The Central Bank published its annual Consumer Protection - Outlook Report on 2 February 2016, setting out its consumer protection objectives for the year ahead, and key ongoing risks.


European agenda: it will continue its work on implementing both the Mortgage Credit Directive and Payment Accounts Directive (due for implementation by 31 March 2016 and 18 September 2016 respectively), and promoting a "coherent cross sectoral consumer protection framework" at EU level. New SME Regulations: it will publish a guide to the new SME Regulations (which will replace the current Code of Conduct on Business Lending to Small and Medium Enterprises) in advance of 1 July 2016.   Mortgages and arrears: Variable Rate Mortgages: once its Consultation on Increased Protections for Variable Rate Mortgage Holders concludes in mid-February, it will consider whether resulting changes are required to the Consumer Protection Code. Tracker Mortgages: it will focus on making continuing progress in its examination of tracker mortgage issues. Mortgage Arrears: it will be following up with lenders on the results of its 2015 CCMA themed inspection. Issues identified during that inspection related to delays in MARP assessments, the quality of communications with borrowers (in particular in relation to decisions of Arrears Support Units), adherence to time-frames, telephoning borrowers and the ability to provide supporting documentation. Authorisation and supervision: Credit Servicing: following the introduction, in 2015, of a new authorisation regime for credit servicing firms (see our previous client briefings here and here), those firms will need to be able to demonstrate compliance with the Central Bank's new Authorisation Requirements and Standards for Credit Servicing Firms. New authorisation models: it has already introduced new authorisation process models for payment institutions and electronic money institutions; these will be rolled out to other institutions (such as bureaux de change, retail intermediaries, debt management firms, retail credit firms and moneylenders) during 2016. Supervision: it will focus on on-site supervision, checking regulated firms' progress in putting "fit-for-purpose consumer risk frameworks" in place. Culture: it will work with the boards and senior management of regulated firms to assess what outcomes are being delivered to consumers. Monitoring internal frameworks: it will assess the risk frameworks...

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