Ireland:
Hire-Purchase (And PCP), Consumer Hire And Buy-Now-Pay-Later Products: New Central Bank Authorisation Requirements
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The new Consumer Protection (Regulation of Retail Credit
and Credit Servicing Firms) Act 2022 (which requires a
commencement order before it becomes operational) extends the
Central Bank of Ireland's retail credit and credit servicing
regimes by requiring that:
- any person carrying on a business of offering hire purchase
products (including personal contract plans
(PCPs)) or consumer-hire products to consumers,
and any other person providing credit directly or indirectly to
consumers, be authorised by the Central Bank as a retail credit
firm (if not already subject to Central Bank authorisation);
and
- any person who services such products be authorised by the
Central Bank as a credit servicing firm.
As the new Act will regulate indirect forms of credit, providers
of buy-now-pay-later products and other similar products which
allow a person to pay in instalments will now need Central Bank
authorisation (unless they can avail of a recently-narrowed
exemption under the Consumer Credit Act 1995).
This article contains a general summary of developments and
is not a complete or definitive statement of the law. Specific
legal advice should be obtained where appropriate.
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