FLAC thoughts on new CCMA, are they well thought out?

I can’t help but feel disappointment when I hear that FLAC are calling for banks to be highly limited in their ability to make unsolicited contact to resolve issues with debtors. This was widely reported (audio clip here), but doesn’t go on to state why it’s good, bad, or why it may need to be changed, the suggesting isn’t coming out of thin air.

Our thoughts are that pragmatism must win out, a level of limiting power along with a corresponding engagement and non- harassment policy is possible. Our submission to the Central Bank (below) attempts crudely to consider this.

The TD Stephen Donnelly reported in the Sunday Independent that he had constituents who were being harassed by the banks and that the use of auto-diallers was a part of that. This didn’t count as unsolicited contact because under the precise rules of the Code of Conduct on Mortgage Arrears calling a person then not leaving a message doesn’t count as ‘contact’.

At the same time it …

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