The Alternative Credit Council (ACC) has submitted a letter to the Irish Ministry of Finance and Public Expenditure and Reform on proposals being considered by the Oireachtas that would require credit agreement owners to be authorised by the Central Bank of Ireland.

This letter highlights how the proposals may have unintended consequences beyond their stated objective to strengthen borrower protection in instances where their loan is owned by a non-bank entity. Specifically, how this may reduce demand amongst asset managers for credit agreements originally issued by an Irish bank, the unintended consequences of the proposals for Irish Securitisation vehicles and potential incompatibility of the proposals with existing financial services legislation.  The ACC also called on all parties to consider an alternative approach that would meet the objectives of the legislation in a more proportionate manner.

If you have any questions regarding this letter please contact Nick Smith.