Reminder: CPC Consultation

Tue May 14 2024

Thank you to members for attending the Central Banks webinar in relation to the CPC consultation.  As previously advised, some key areas that the consultation paper focuses on:

  • The introduction of a Securing Customers’ Interests obligation.
  • Vulnerability – introduces a new definition of what is a consumer in vulnerable circumstances, new obligations for staff to receive training on vulnerability issues with a requirement for firms to facilitate a new trusted contact person.
  • It introduces new requirements in respect of unregulated activities in respect of transparency of branding.
  • It proposes to introduce within the regulations the IDD requirement of capturing sustainability preferences as part of the knowing the consumer requirement and asks whether sustainability preferences should be given the same level of consideration as risk profiling etc.
  • SME threshold – the Central Bank is proposing to update the threshold in the definition of consumer under the revised Code to apply the General Requirements to small businesses, to include incorporated bodies with an annual turnover of less than €5m per annum (current threshold is €3m).
  • Insurance switching – a further enhancement is also proposed to the general renewal requirements for insurance products. In addition to the ‘renewal notice’ currently issued to holders of non-life insurance policies 20 days in advance of their renewal date, an additional ‘pre-renewal’ notification will now be required for consumers a further 20 days prior to the issuance of the ‘renewal notice’.
  • Investments and Pensions – the Central Bank are proposing to strengthen current requirements in the revised Code, so that firms inform their customers of the importance of considering the ongoing suitability of investment and pensions products for their needs at the point of sale, and in annual statements. Where the firm does not provide ongoing suitability assessments, firms will be required to explain to the customer the reasons for this.

Thanks to members who have provided feedback, if members have any additional feedback on the consultation, please send to before Friday the 24th of May.

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