central credit register personal lines guide august 2019 ccr pl guid… · payslip, p60, p45, p21...

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Close Brothers PremiumFinance Ireland

Central Credit RegisterPersonal lines guide

August 2019

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What Why How FAQsContents

What is the Central Credit Register (CCR)? 3

Why is the CCR needed? 4

How will the CCR affect how we do business with you? 5

How will the digital journey look? 6

How will the E-sig journey look for the customer? 7

How will the non-digital journey look? 8

How will the changes look on i-prompt? 9

How will the changes look on i-prompt for finance under €500? 12

What ID&V documents will be accepted? 13

How will the changes look on i-prompt for finance of €500 or more? 14

What are the additional occasions when CBPFI will require ID&V? 15

Updates to improve i-prompt 17

How can you see that ID&V is needed before sending the additional lending? 18

Auto Authorisation Exceptions 19

Frequently asked questions 20

Frequently asked questions – Additional Lending and Enquiry 23

Frequently asked questions – Auto Authorisation Exceptions 24

Our commitment to you 25

Contents

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What Why How FAQsWhat is the Central Credit Register (CCR)?

What will the CCR do?

• The information collected will help lenders, borrowers and the Central Bank in its role of safeguarding stability and protecting consumers.

• Lenders will be able to use the information to get a more detailed picture of a borrower’s credit history, which will help them to make decisions about finance applications.

• Borrowers will have the opportunity to see what credit information lenders hold about them.

Who will Close Brothers Premium Finance Ireland (CBPFI) need to verify the identity of?

We will need to verify the identity of customers who are individuals.

For information on the verification documents required, please turn to pages 12-14.

Central Credit Register (CCR)The CCR is a centralised system thatcollects and stores personal and credit information from lenders aboutfinance and credit facilities theyprovide, in line with the Credit Reporting Act 2013.

What is the Central Credit Register (CCR)?

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What Why How FAQs

Why is the CCR needed?

The Government in Ireland gave a commitment as part of the EU/ IMF Programme of Financial Support, to develop a legal framework that would facilitate the collection and centralisation of credit information on borrowers.

The CCR will contribute to consumer protection and financial stability by providing:

• Borrowers with an individual report detailing their credit agreements.

• Lenders, such as CBPFI, with credit reports that will support credit assessments.

• The Central Bank of Ireland (CBI) with better insights into financial markets and supporting functions of the CBI.

Why is the CCR needed?

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What Why How FAQs

How will the CCR affect how we do business with you?

How will the CCR affect how we do business with you?

Over the last few months, we have been liaising with the CBI to help us work with you in order to meet the regulations.

As part of the regulations we are required to capture Identification and Verification documents (ID&V) for all new consumer credit agreements from 31 December 2017.

We are taking this opportunity to transform our business by introducing electronic signature (E-sig) and an online portal for customers (private individuals) to use to upload their identification documents.

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What Why How FAQs

How does the digital journey work?

OverviewPlease note, you will not be required to upload a Running Account Credit Agreement (RACA) if your customer uses the digital journey; instead, we will request that your customer signs their RACA online.

The customer decides to pay for their insurance policy by monthly Direct Debit instalments.

Broker reads/sends script to customer (then submits finance (via i-prompt or software house). Finance details include bank details and email address.

The customer E-signs the credit agreement.

CBPFI sends email to customer with a link to provide ID&V information and E-sig.

The customer uploads their ID&V documents on portal.

The ID&V documents and RACA are sent to CBPFI for verification and authorisation.

The customer received a welcome pack confirming the RACA has been received.

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What Why How FAQs

How will the E-sig journey work for the customer?

Customer receives email invitation from CBPFI.

Customer must verify their account by using their bank account or

mobile to log in.

The verification documents and signed RACA will be sent to CBPFI for authorisation.

Digital journey (customer)

The customer will be directed to the greeting screen

(Payment terms, digital consent and paperless

Direct Debit Mandate)

Q&ASECCI and preview of RACA

Signing of the RACA

(ID&V uploads)

The customer will then be able to view their payment terms, digital consent and paperless SEPA Direct Debit Mandate. Upload their ID&V, view the Q&A document, SECCI, RACA and give digital consent.

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What Why How FAQs

How will the non-digital journey look?Overview of the non-digital journeyWe have updated i-prompt to allow you to upload customer ID&V documents directly onto our system.

Broker uploads customer’s signed RACA and ID&V onto i-prompt.

Customer receives welcome pack confirming RACA and

finance has been authorised.

Customer decides to pay for their insurance premium by monthly

Direct Debit instalments.

Customer signs RACA and

returns to broker with ID&V

documents.

Broker reads/sends script to customer (including affordability

assessment) then submits finance request (via i-prompt or

software house).

ID&V and RACA sent to CBPFI for verification and

authorisation.

Broker prints SECCI, Q&A documents, and RACA and sends to customer.

SUBMIT PRINT

• If you do not speak to the customer at the point of sale, you can send a written finance application form to the customer along with the SECCI, Q&A document and RACA.

• Please instruct the customer to read and sign the application form prior to signing their RACA. The customer will then need to send you their signed RACA and script.

• CBPFI will only verify the customer’s ID&V documents once all documents have been received. Please upload all the required ID&V documents and the RACA at the same time, do not upload them individually over a period of days/weeks.

• If documentation is missing or incorrect CBPFI will contact you (the broker) and the unauthorised report on i-prompt will reflect this.

If your customer would like to use the digital journey please refer to page six of this guide.

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What Why How FAQs

How will the changes look on i-prompt?

We have made small changes to how you enter in the customer’s finance details – please see below:

Trader type is now at the top of the screen. The information that is required for the customer will vary dependent on the trader type.

The customer’s title, forename and surname is now split into separate fields. Please note, the customer’s legal name must be confirmed here.

It is important to capture the customer’s email address and bank details to enable E-sig.

Please note: for private individuals we cannot accept a co-borrower.

The credit agreement must be set up under one individual’s name.

It is also very important that you enter the correct date of birth.

Step 1

Private individuals

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What Why How FAQsHow will the changes look on i-prompt?

Private individuals:

Once you have entered all of the required finance details for your customer, you will proceed to the i-prompt screen below, where you can choose whether to offer them the digital journey. (You need to untick the box if you do not want customers to use the digital journey).

The customer’s title, forename and surname is now split into separate fields. Please note, the customer’s legal name must be confirmed here

Please note, you will not be required to upload a RACA if your customer uses the digital journey; instead, we will request that your customer signs their RACA online.

This figure tells you the amount of finance required by the customer.



The email to your customer will only be initiated if you click “confirm loan now”.

Private individuals

Step 2

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What Why How FAQsHow will the changes look on i-prompt?

Once you have successfully confirmed the finance, you will now need to upload the customer’s ID&V documents along with their signed RACA.

This can be uploaded by clicking on the ‘Documents’ link from the main menu bar in the customer's loan then click on ‘Add Paperwork’.

Please ensure that you upload all the required ID&V documents and the RACA at the same time, do not load them individually over a period of days/weeks – We may only process the application when all the required documents have been uploaded.

Send client an E-sig e-mail

If you want to re-send the E-sig request to your customer this can be done by clicking the link above.



(If you chose not to offer the digital journey to your customer)Step 3

Private individuals

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What Why How FAQs

Document upload for finance under €500 Below is a list of verification documents that CBPFI can accept from the customer. Remember it is either a valid passport or diving licence or two separate pieces of identification:

Verification method:a) Valid passport, or (b) valid driving licence.

Verification method:Signed RACA from the customer.

Verification method:Any two of the following documents: A utility/landline telephone bill, financial statement, official letter/document including insurance schedule which shows the customer’s name and address dated within the last six months.

The customer must scan both ID’s into one document for you to upload. Please note, these two forms of ID are not required if a passport or driving licence has been uploaded.

Verification method:Payslip, P60, P45, P21 (ROI), Drugs Payment Scheme Card, Medical Card, GP Visit Card, European Health Insurance Card, tax assessment, notice of tax credits.

The customer must provide their ID&V document(s) within 30 days of applying for finance for their insurance premium.

These documents can be scanned copies or photographs of the original document.

Please note - PPSN is not required for finance under €500

How will the changes look on i-prompt for finance under €500?

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What Why How FAQs

What ID&V documents will be accepted?

ID&V documents for finance under €500

The customer can choose to provide either one document from the following list:

The customer’s identity:• A valid passport. • A valid driving licence.

OR

Two documents from the following list:

The customer’s full name and residential address:Any two of the following documents, which must be current and shows the customer’s name and address and must be dated in the last six months:• Utility bill or landline telephone bill. • Financial statement such as credit/debit card statement. • Official letter/document such as letter from Department of Social Protection/Revenue, other

official correspondence from an Irish state agency, correspondence from an insurance company regarding an active policy.

The finance amount payable by the customer is the insurance premium, excluding deposit, plus any charges and fees.

The customer must provide their ID&V document(s) within 30 days of applying for finance for their insurance premium.

These documents can be scanned copies or photographs of the original document. The customer must scan both ID’s into one document for you to upload. Please note, these

two forms of ID are not required if a passport or driving licence has been uploaded.

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What Why How FAQs

How will the changes look on i-prompt for finance of €500 or more?

Document upload for finance of €500 or more

The list of acceptable documents for finance of €500 or more is as follows:

Verification method:a) Valid passport, or (b) valid driving licenceIf neither a or b available then:c) National identity card, or (d) residence/working Visa.

Verification method:Signed RACA from the customer.

Verification method:Payslip, P60, P45, P21 (ROI), Drugs Payment Scheme Card, Medical Card, GP Visit Card, European Health Insurance Card, tax assessment, notice of tax credits.

Verification method:A utility/landline telephone bill, financial statement, official letter/document including insurance schedule which shows the customer’s name and address dated within the last six months.

The customer must provide three separate ID&V documents and the RACA within 30 days of the credit agreement being confirmed. Failing to provide these will mean the finance will not be authorised.

These documents can be scanned copies or photographs of the original document. If any of the documents have already been received, the browse facility will be greyed out on i-

prompt to reflect this.

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If a new personal lines customer, onboarded on or after 1 January 2018 makes an application for additional lending taking their total finance to €500 or more, then:

1. We are required to pass their finance details to the Central Credit Register (CCR), as they are requesting finance of €500 or more.

2. We will ask you to provide additional customer ID&V to us via i-prompt

3. This must be provided within 30 calendar days of their application.

4. Failure to provide the required ID&V will result in the additional lending to the customer being cancelled and a pro-rata cancellation will be processed to your bordereau, taking into account any instalments collected.

Additional lending is any additional credit application under an existing credit agreement, for example, MTAs, renewals and aggregate finance applications.

For example, if a new customer borrowed €450 in February 2018, full ID&V as required by Credit Reporting Act 2013, such as PPS number, would not have been captured as the credit agreement was ineligible for reporting to CCR as it is under €500. But if they apply for €100 additional credit before the original credit has been cleared, this becomes eligible for reporting to CCR as a credit agreement with a credit limit of €550 regardless of the actual value of outstanding credit. As the credit agreement must now be reported, we will require additional customer ID&V.

What Why How FAQs

What are the additional occasions when CBPFI will require ID&V?

CBPFI will contact you as agreed with your sales manager, if additional ID&V is required. Please use your normal means of uploading documents to CBPFI shown on pages 11-14 of this guide.

The new additional lending procedures came into force October 2018.

Private individuals

Additional lending

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If a personal lines customer has not previously provided full ID&V as per the requirements set out under the Credit Reporting Act 2013 (“CRA”) and makes an application for additional lending taking their total finance amount to €2,000 or more, then:

1. We are required to submit an Enquiry to the CCR before approving the finance.

2. We may ask you to provide additional full customer ID&V to us via i-prompt

3. This must be provided within 30 calendar days of their application, if successful we will then complete an Enquiry.

4. Failure to provide the required ID&V will result in the additional lending to the customer being cancelled and a pro-rata cancellation will be processed to your bordereau, taking into account any instalments collected.

Where we have received ID&V for the customer we will submit an Enquiry to the CCR.

For example, If a customer was onboarded before 1 January 2018 they would not have been required to provide complete ID&V in accordance with the CRA. However, their credit agreement may have been reported to the CCR if the total finance was over €500. At renewal if their total finance exceeds €2,000, additional full ID&V will be required prior to completion of Enquiry.

An Enquiry is a lender consulting the Central Credit Register (CCR) when a customer makes an application for credit over €2,000 or more. This monetary threshold is a regulatory requirement and is specified in the Credit Reporting Act 2013.

What Why How FAQs

What are the additional occasions when CBPFI will require ID&V?

CBPFI will undertake an Enquiry following successful completion of our ID&V checks and prior to authorising any request for credit.

This process will be mandatory for personal lines credit applications processed on or after 30 September 2018. The result of an Enquiry may affect our application approval process for some customers, in all cases you will be advised.

Private individuals

Enquiry requirements

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What Why How FAQs

Under ‘Update Client’s Details’ the name and address fields will now be greyed out. You can still amend their telephone numbers and email address.

Updates to improve i-prompt

As part of the CCR changes that we have had to implement on i-prompt, you will no longer have the access to amend a customer’s name or address once the finance has been confirmed.

The customer can call CBPFI at any point to change their name/address on the system. For change in name, the customer will need to provide proof of name change.

You can request this change as a broker, but you will need to confirm to us that you have identified the customer in accordance with your usual customer identity checks.

Further changes on i-prompt

Private individuals

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Under ‘Last Actions’ then ‘Unauthorised Loan’, you will find a report that highlights all credit agreements that have an unauthorised status on i-prompt.

This report shows two things: the total amount tobe paid to the broker and the credit charge to be paid to CBPF. The total amount of finance being provided is the sum of these two fields

If you are unsure, please contact customer services on 1890928281

This field will confirm whether it is an MTA or new finance application (parent loan)

What Why How FAQs

How can you see that ID&V is needed before sending the additional lending?

The final column shows the reason why the agreement is unauthorised. If the reason states ‘Awaiting customer information’ this indicates that there are outstanding documents (which could be either ID&V or the signed RACA, or both).

Click into the agreement and select ‘Documents’ from the bottom menu bar to view what's outstanding in order to authorise the agreement.

Unauthorised finance on i-prompt

Private individuals

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Auto Authorisation Exceptions

Close Brothers Premium Finance Ireland (CBPFI) are making changes to its system as a result of mandatory customer ID&V requirements introduced by the Credit Reporting Act 2013. These changes will take effect from 21 March 2019.

What Why How FAQs

What system enhancements are CBPFI are making?

Personal Lines:

This means we will no longer automatically authorise finance applications (including renewals), if we do not have the correct customer documents. This is shown in the flow diagram below.

Where additional lending* takes the total finance amount from under to over €500, CBPFI will request additional customer ID&V documentation prior to progressing the application.

Where additional lending takes the total finance amount of the application, from under to over €2,000 or more, CBPFI must submit an Enquiry to the Central Credit Register (CCR) prior to approving the request for additional lending

The requirements for ID&V and Enquiry have been communicated to you previously and further information is on pages 12-16 of this guide.

If we do not receive the correct customer ID&V documents within 30 days of receipt of the finance application/additional lending request it will not be progressed.

In advance of submitting finance applications, you have the option of checking the i-Prompt unauthorised report and/or the current finance application to clarify which ID&V documentation is required. This is shown on page 18 of this guide.

In addition, all finance applications will be reviewed and CBPFI will notify you if we require additional ID&V documentation.

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What Why How FAQs

Frequently asked questions

1. What is the Central Credit Register (CCR)? The CCR is a database of personal and credit information to be created by means of a national mandatory credit reporting system being established by the Central Bank of Ireland (CBI).

2. Why is the CCR needed?The Government in Ireland gave a commitment, as part of the EU/IMF Programme of Financial Support, to develop a legal framework that would facilitate the collection and centralisation of credit information on borrowers.

The CCR will contribute to consumer protection and financial stability by:

• Providing borrowers with an individual report detailing their credit agreements.• Providing, lenders such as Close Brothers Premium Finance Ireland (CBPFI) with comprehensive

information to support credit assessments.• Providing the CBI with better insights into financial markets and supporting functions of the CBI.

3. When will this change come into effect? From 31 December 2017, banks and finance providers, such as CBPFI will require ID&V documents to be provided as part of all new credit applications for individuals. This will also take effect for sole traders and businesses from September 2018.

4. Do these regulations impact all finance providers in Ireland?Yes – all banks, credit providers and money lenders will need to adhere to the new regulations. The timeframe in which to implement changes may vary depending on the type of firm.

5. Does this also apply to sole traders and businesses?The changes apply to individuals only from 31 December 2017 but will take effect for sole traders and businesses from September 2018. We’ll be in touch with you prior to then to ensure that you are prepared.

6. Where can I find out more information about the CCR?Information on the CCR can be found at the following sites:

• https://www.centralbank.ie/consumer-hub/explainers/what-is-central-credit-register• https://www.centralcreditregister.ie• https://www.centralcreditregister.ie/media/1083/a-consumer-guide-to-the-central-credit-register.pdf

7. Do the ID&V documents have to be dated within a certain timeframe?Passports and driving licenses must be valid (not expired), all other documents need to be dated within the last six months.

8. What if the customer doesn’t provide ID&V documents? The new regulations require ID&V documents to be provided for all credit agreements. Without acceptable ID&V documents, we will be unable to authorise finance for the customer.

9. Can we accept an insurance policy schedule as proof of address?Yes, we can accept the insurance renewal document for the policy being funded provided that the information matches the credit agreement.

https://www.centralbank.ie/consumer-hub/explainers/what-is-central-credit-register

https://www.centralcreditregister.ie/

https://www.centralcreditregister.ie/media/1083/a-consumer-guide-to-the-central-credit-register.pdf

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What Why How FAQsFrequently asked questions

10. What is the criteria around document quality?ID&V documents that are uploaded must be clear and legible so that the information can be viewed and checked against the credit agreement.

11.Can the ID&V document image be a photo of the document?Yes, a photo of the original document will be accepted as long as the image is clear and legible so that the information can be viewed and checked against the credit agreement.

12. Does the ID&V document image need to be in colour?We do not have a specific requirement for colour images. Black and white images will be accepted as long as the image is clear and legible so that the information can be viewed and checked against the credit agreement.

13. Can originals be sent in?We cannot accept original documents, therefore, we have taken the position of accepting clear and legible copies/images of the documents.

14. How will CBPFI collect missing or incomplete documentation?If the customer does not upload the required documents within 30 days from the date finance is created, CBPFI will reject the agreement. If documentation supplied by the customer is invalid CBPFI will delete the uploaded document, contact the customer directly and send an i-mail to update the broker.

15 How do I upload the documents to i-prompt?Please refer to pages 11 – 13 in this guide for more details.

16. What do I do if my customer’s total aggregated borrowing with CBPFI is €500 or more, i.e. they have used premium finance for two or more insurance policies under the one finance agreement in a year and their combined total finance amount is €500 or more?If your customer’s total aggregated borrowing is €500 or more, we will need additional ID&V, as this will trigger the ID&V threshold requirement of €500 or more for a single customer agreement.

For example, if your customer takes out additional finance or makes an adjustment to their existing finance under their existing finance agreement. Please note, fees and charges incurred by customers during the life of their finance agreement will not in themselves invoke the need for additional ID&V.

17. Why do I need to capture the customer’s PPSN for credit agreements of €500 or more?As a Credit Information Provider, CBPFI is legally required by the Credit Reporting Act 2013 to provide certain personal information and credit information to the Central Bank of Ireland (CBI) including a PPSN (section 6(f) of the Credit Reporting Act, 2013). The PPSN is a strong identifier of an individual borrower and is therefore an important component in producing a single borrower view for the CCR. Failure to provide the PPSN number could result in an enforcement action against CBPFI by the CBI.

18. What is needed for change of name - New finance agreements?For anyone who has recently got married we will ask for their marriage certificate or proof from a solicitor, in addition to the requested forms of ID (passport/driving license) to show their change of name, and the account will be created in the customer’s new name.


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What Why How FAQsFrequently asked questions

19. Are brokers allowed to capture a customer’s PPSN for credit agreements of €500 or more?For finance agreements over €500, whilst there is a general prohibition on the use of PPSN under Section 262 of the Social Welfare Consolidation Act 2005, the Credit Reporting Act 2013 (CRA) contains a provision that is designed to resolve any conflict that may arise between the obligation of the Credit Information Providers (or any person acting on their behalf) to collect and report PPSN to the CCR and the general prohibition on the use of PPSN under the Social Welfare Consolidation Act 2005. In particular, Section 6(6) of the CRA provides that any person who uses or seeks to have disclosed a PPSN for any purpose connected with the CRA does not commit an offence under Section 262(9) of the Social Welfare (Consolidation) Act 2005.

A key point of Section 6(6) of the CRA is it does not refer to Credit Information Providers, but to ‘any person’. In this context, ‘any person’ means an individual, body corporate or unincorporated body of persons. Therefore the exemption provided under section 6(6) is not limited in scope to a Credit Information Provider. As such, the law permits a Credit Information Provider or anyone acting on its behalf, such as a broker, to use and collect (including temporarily storing on its electronic systems where necessary) the PPSN from customers and forward this to a Credit Information Provider the purposes of reporting to the CBI in accordance with the CRA.

Extract from Section 6(6) Credit Reporting Act 2013

“A person who uses, or seeks to have disclosed, a personal public service number for any purpose connected with this Act does not commit an offence undersection 262 (9) of the Social Welfare Consolidation Act 2005.”

A broker may only use and collect (and temporarily store on its electronic systems where necessary) a PPSN for the purposes of enabling CBPFI to report the PPSN to the CBI and the use of it for any other matter may be an offence. We would advise that brokers should destroy any records of PPSN including where it has been temporarily stored on any of its electronic systems once it has been forwarded to CBPFI following collection. If in doubt, brokers should seek guidance from their own data protection advisers.

20. How do I amend a customer’s address on i-prompt?As part of the CCR changes that we have had to implement on i-prompt, you will no longer have the access to amend a customer’s address once the finance has been confirmed. However, there are two options available:1. The customer can contact CBPFI at any point to change their name/address on the system.

Customers will need to provide appropriate evidence for change of name, e.g. marriage certificate. 2. You can request this change as a broker, but you will need to confirm to us that you have identified

the customer in accordance with your usual customer identity checks.

21. What is needed for change of name - Post credit agreement authorisation (or renewal) for existing customers?If a customer has previously supplied us with proof of name, address and PPSN, only the document used to verify a customer name will need to be updated (e.g. valid Driving licence or valid passport). As per new finance we will ask for marriage certificate or deed poll as acceptable form of ID but also accept valid driving licence/passport.


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What Why How FAQs

1. Do the ID documents have to be dated within a certain timeframe?Passports, driving licences and tax clearance certificates must be valid (not expired). All other documents need to be dated within the last six months.

2. How will I know if ID&V is required?CBPFI will contact you by your preferred route, e.g. i-mail, email to a specific address or telephone call to a specific number.

3. Where can I see that ID&V is required in advance of sending the additional lending?You will need to check the individual customers finance via i-prompt using “documents” tab to see which documentation has already been received. If you are unsure, please contact customer services on 1890928281.

4. If we collect ID after day 30 can we reset the finance up?If you are in receipt of ID documents after 30 days you need to re-submit the finance application for CBPFI to process. To avoid resubmission the early collection of ID is essential.

5. What is a CCR Enquiry? Lenders must consult the Central Credit Register (CCR) when a customer makes an application for credit for €2,000 or more, prior to authorising such an application for credit.

6.When will this change take effect?This process will be mandatory for personal lines credit applications processed on or after 30 September 2018.

7. Who determined the €2,000 threshold for ROI CCR Enquiry?This monetary threshold is a regulatory requirement and is specified in the Credit Act 2013.

8. At what point in the credit application process will CBPFI undertake a CCR Enquiry?CBPFI will undertake an Enquiry following successful completion of our ID&V checks and prior to authorising any request for credit.

9. Will the Enquiry process delay credit applications being authorised? We will accommodate it within the existing time taken to authorise finance applications.

10. Will a footprint be left on the customer’s credit history for Enquiry?Yes, each finance application Enquiry is recorded on the customer’s credit report. This will remain on the customer’s credit report for a period of 24 months from the date of Enquiry.

11. If a customer has an active credit agreement, will an Enquiry be carried out for any subsequent credit applications received?Yes, if the subsequent credit application results in aggregate lending of €2,000 or more.

12. Will you decline credit applications based on the results of Enquiry?The result of an Enquiry may affect our application approval process for some customers, in all cases you will be advised.

Frequently asked questions – additional lending and Enquiry

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What Why How FAQs

Frequently asked questions – Auto Authorisation Exceptions

1. What changes are being made by CBPFI?CBPFI are making system changes which will mean that all finance applications, including renewals will no longer be automatically authorised if we do not have the required ID&V documents for the customer.

2. Why are CBPFI making changes to their system?CBPFI are making changes to its system as a result of mandatory customer ID&V requirements introduced by the Credit Reporting Act 2013.

3. Which customers will this affect?These changes will affect all CBPFI Personal Lines customers.

4. Will this delay finance applications being authorised?The system changes will not delay finance applications being authorised if the correct ID&V documents for the customer have been received.

5. Will this delay receipt of payment?There are no changes to payment and payment will be made under the normal terms if the correct ID&V documents have been received by CBPFI.

6. Will Brexit have an effect on the current process?Regulatory changes as a consequence of the UK’s departure from the European Union (“Brexit”) may have impact on these system changes. Once the terms of Brexit are agreed we will update you on the implications as soon as practicable.

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What Why How FAQs

At CBPFI, we’re here to support you and we remain committed to working closely with you over the comingmonths. If you have any queries regarding the CCR, please do contact your Sales Manager who will be happyto help or email your query to [email protected].

You can also refer to the official CCR and Central Bank of Ireland websites (addresses shown below)

A consumer guide to The Central Credit Register Central

Bank of Ireland explaining CCR

Our commitment to you

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Close Brothers Premium Finance Ireland Alexandra HouseThe Sweepstakes Ballsbridge Dublin 4T: 1890 928 281