CCPC welcomes the publication of the Department of Finance’s Retail Banking Review

November 29, 2022

The Competition and Consumer Protection (CCPC) has welcomed the publication of the Department of Finance’s Retail Banking Review earlier today. During the course of the review, the CCPC engaged extensively with the Department of Finance, the Central Bank and other relevant stakeholders in the development of key recommendations.

In particular, the CCPC welcomes the commitment that Ireland meets the requirements of the OECD’s recommendation on financial literacy by developing a national financial literacy strategy. This strategy will be achieved with stakeholders working together to support the development and implementation of a range of financial education initiatives.

However as expressed in their submission in July 2022, the CCPC continues to view the competition issues within the banking sector as significant and is concerned that this will lead to consumer harm in terms of price, levels of service and innovation.

The CCPC considers that the decision not to include the CCPC’s recommendation that the mandate of the Central Bank of Ireland (CBI) be amended to include competition is a missed opportunity to ensure that the entity closest to conditions in the retail banking services market in Ireland is empowered to factor the importance of competition into its decision making. The CCPC notes the recommendations that the Central Bank more closely consider competition, market entry and innovation in its regulatory approach. The CCPC looks forward to considering the impact of this new strengthened focus on competition by the Central Bank and resultant outcomes for consumers.

The CCPC remains committed to ensuring that competition in the retail banking market functions well and will engage with the CBI to improve information sharing and the ability to collaborate more closely in the interests of consumer protection and competitive markets.  The recommendation to review and strengthen the ability to share relevant information between the CCPC and the Central Bank is very welcome in this regard.

The CCPC also welcomes the Report’s acknowledgement of the ongoing importance of branch services, including access to cash, and the need to ensure that any collaboration between banks to address this is in compliance with competition law.  Access to cash services is particularly important for consumers at risk of financial exclusion or those who are less confident engaging with services online.

The CCPC welcomes the recommendation that under a revised Consumer Protection Code, mortgage lenders should be required to improve the take up of cheaper offers by customers and that a review of the Switching Code for payment accounts should be conducted as soon as possible following the mass migration of KBC and Ulster Bank customers.  The CCPC will engage closely with any such review.

The CCPC looks forward to continuing its work with Government Departments, Public bodies and with the retail banking sector toward successful implementation of the recommendations of the Retail Banking Review.

Notes:

In July 2022, the CCPC made a submission to the Department of Finance’s public consultation on banking.  In providing the response, the CCPC considered the themes arising in the Retail Banking Review Dialogue hosted by the Department of Finance in May 2022, and the comprehensive nature of the terms of reference for the Retail Banking Review.

In the submission, the CCPC expressed concerns about the impending increase in the concentration levels of the retail banking sector in Ireland as a result of the exits of KBC and Ulster Bank.

To address these issues, the CCPC has made a number of recommendations to promote competition and the consumer interest. A full list of these recommendations can be found in the document here.

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