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ARTICLE · 28 MARCH 2025

A First Look - Changes And Clarifications To The Proposals In CP 158 On The CPC

The Central Bank of Ireland has published the much anticipated Feedback Statement to its Consultation Paper on the Consumer Protection Code ("CP158"), along with the finalised regulations and guidance documents.

IrelandFinance and Banking

1. Changes and Clarifications to Securing Customers Interests

  • Acting on behalf of a customer
    Clarified that 'acting in the best interests' and 'securing customers' interests' in the context of the CPC does not mean that a financial services firm is 'acting on behalf of' a customer, or in any way taking responsibility for making decisions that could and should be made by the customer themselves. In placing obligations on firms, the securing customers' interests obligations do not remove responsibility from their customers.
  • Assisted Decision Making Act
    Clarified that the proposals do not conflict with the Assisted Decision Making Act ("ADMA"). The guidance outlines for firms how the requirements apply in order to support firms in understanding their obligations under the CPC and the ADMA.

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