Central Bank of Ireland: Consumer Protection Outlook Report 2023
March 2023The Central Bank of Ireland (‘CBI’) have published the Consumer Protection Outlook Report 2023. The report outlines the five key drivers of consumer risk in Ireland, in this changing and challenging economic environment.
These risk drivers reflect the feedback and engagement that the CBI has undertaken with various stakeholders over the last year which has been incorporated into their annual risk assessment. The five Key Drivers of Consumer Risks and associated CBI expectations of firms are:
1) The changing operational landscape- Actively identify and address risks to consumers that may emerge from change in the landscape within which the firm and/or its consumers are operating
- Engage with financial innovation to address the needs and interests of consumers
- Have sufficient operational resilience to manage change
- Clearly distinguish between regulated and unregulated services for the consumer, particularly when they are being offered in the same digital space.
2) Poor business practices and weak business processes - Place the best interests of consumers at the heard of commercial decisions
- Implement robust governance and oversight arrangements for the design, sale and delivery of the product
- Comply with suitability requirements
- Monitor products to ensure it is performing as intended and remains suitable for the target market
- Ensure proper resources are deployed to deliver a high quality service
3) Ineffective disclosures to consumers- Provide clear information promptly, to consumers, disclosing key information upfront
- Support consumers by ensuing information is provided in a way that can be easily understood
- Ensure that statements of suitability and other disclosures are fully compliant with legislative requirements
- Ensure disclosure is as clear on digital media as with more traditional methods
- Avoid Greenwashing by producing disclosure documents that are clear and full compliant with legislative requirements
- Disclose exclusions to financial products effectively at the outset, to support consumers in making good decisions
4) Technology-driven risks to consumer protection;- Have well defined and comprehensive IT and cybersecurity risk management frameworks, supported by sufficient resources
- Make sure that the interests of the consumer are the firm's top priorities when designing and distributing financial products digitally, and that the product will only be made available to suitable consumers
- Have effective measures to mitigate the risk of fraud and scams and be proactive in identifying and dealing with cases
- Demonstratable oversight of delegated or outsourced arrangements and evidence that associated risks are appropriately considered and managed
5) The impact of shifting business models- Consider the impact of decisions on vulnerable customers and implement effective processes and communication plans
- Proactively assess and mitigate the risks and consumer impact of commercial decisions whilst ensuring that customers understand that changes mean for them
- Have sufficient customer service capacity and structures
- Only design and bring to market products that meet the needs of identified target market
The CBI have anchored on these risks for their work in 2023 and beyond, which means that regulated firms can focus on making long-term sustainable improvements. The report also includes a description of key bodies of work to be delivered by the CBI with respect to the Key Drivers of Consumer Risk.
The full Report can be found at:
Central Bank of Ireland Consumer Protection Outlook Report 2023