Looking Ahead: Irish Developments
CAPITAL REQUIREMENTS DIRECTIVE
The Department of Finance’s consultation on the limited Member State discretions under the CRD VI Directive closes for feedback on 14 February 2025.
The questions posed by the consultation relate to cooling-off periods for staff members of competent authorities; whether third country branches should be subject to the third country branch-specific requirements of CRD VI or to the broader CRD requirements for credit institutions; administrative sanctions; review timetables for risk management reviews; and suitability assessments of members of the management body.
CONSUMER PROTECTION CODE
The final draft ‘Conduct of Business’ Regulations which will replace the Consumer Protection Code and incorporate, among other codes, the Code of Conduct on Mortgage Arrears are expected to be published shortly (having originally been signposted for publication towards the end of December 2024).
These will be accompanied by a Feedback Statement and final draft ‘Standards for Business’ Regulations (part of the Individual Accountability Framework). Both sets of regulations will be signed into law shortly afterwards, with a 12-month transition period.
For more information, read our insights: Consumer Protection Code Reform: Central Bank launches 3-month consultation and Individual Accountability Framework: Central Bank consults on Business Standards as part of CPC review.
CREDIT UNIONS
The Central Bank’s public consultation on proposed changes to the regulatory framework for credit union lending closes for feedback on 11 February 2025. The focus of the proposed changes is on concentration limits for house and business lending, and certain conditions attached to underwriting. The consultation was announced in conjunction with the publication by the Central Bank of the results of a review of the regulatory framework for credit union lending.
GUARANTEES – CREDIT REPORTING
Where a reportable credit agreement is entered on or after 1 February 2025, and a guarantee is entered into in respect of that credit agreement on or after 1 February 2025, the relevant credit information provider is now required to report data in relation to both the guarantee and the guarantor to the Central Credit Register operated by the Central Bank.
This requirement applies whether the guarantee is an ‘all sums due’ guarantee, or a more limited form of guarantee.
For more information, read our insights here: Credit Reporting Update: Guarantees reportable from 1 February 2025 and Credit Reporting Reminder: Guarantees reportable from 1 February 2025.
PAYMENTS
We expect the Finance (Provision of Access to Cash Infrastructure) Bill to be reintroduced to Dáil Éireann in Q1 2025 now that a new Government is in place.
For more information on the Bill, and the related National Payments Strategy, read our insights here: National Payments Strategy: Notable Actions / Recommendations and Access to Cash Bill published.