Our submission to the Central Bank on CCMA 2013

As a firm we believe compliance is important, relevant and while not always efficient it helps to smooth out some of the issues in firm/client relationships. This is why we encourage every firm working with indebted people to respond to the Central Banks call for submissions on the new proposals for the CCMA 2013.

Our submission paper is here.

Amongst the suggestions are that banks stop using auto-diallers and instead are allowed more points of contact but it must be by a human, also that the hours used at present from the CCA 1995 are revised and made less invasive, the trade off being that this doesn’t apply if people don’t engage or if they expressly permit it.

There are many points to consider, from revocation of tracker mortgages, to disclosures, paperwork required etc. but the main point we want to make is that people should submit their suggestions and don’t wait until afterwards to scratch your head and say ‘why does it work this way? Why didn’t somebody think of X’.

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