Close Brothers Premium Finance Ireland

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1 Close Brothers Premium Finance Ireland Helping make insurance more affordable Central Credit Register (CCR) 1

2 What is the Central Credit Register (CCR)? Central Credit Register (CCR) The Central Credit Register (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) in line with the Credit Reporting Act 2013 What will the Central Credit Register do? The information collected will help lenders, consumers 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 consumer s credit history, which will help them to make decisions about finance applications. Consumers will have the opportunity to see what credit information lenders hold about them. What data will Close Brothers Premium Finance (CBPFI) need to verify? Under the CCR definitions, we will need to verify data for: Customers who are individuals Customers who are sole traders Customers who are not individuals (Businesses) Please note: These changes apply to individuals from December 2017 and apply to sole traders and businesses from March For further information on the verification documents required, please turn to page 11. 2

3 Why is the Central Credit Register (CCR) needed? Why is the Central Credit Register 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 premium financers, such as CBPFI with comprehensive information to support credit assessments Providing the CBI with better insights into financial markets and supporting functions of the Central Bank of Ireland 3

4 How will the journey look? We have updated i-prompt to allow you to upload customer ID&V documents directly onto our system. Overview of the journey SUBMIT PRINT Customer decides to pay for their insurance premium by monthly Direct Debit instalments Broker reads/ sends script to customer then submits finance request (via i-prompt or software house) Broker prints Running Account Credit Agreement (RACA) and sends to customer Customer signs RACA and returns to broker with ID&V documents Customer receives welcome pack confirming RACA has been received ID&V and RACA sent to CBPFI for verification and authorisation Broker uploads customer s signed RACA and ID&V onto i-prompt If you do not speak to the customer at the point of sale, you can send the script to the customer along with the Running Account Credit Agreement (RACA). Please ensure you encourage the customer to read and sign the script 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. 4

5 How will the changes look on i-prompt? How will the changes look on i-prompt? Step 1 Private individuals: 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 address and bank details to enable E- signature which will be available in early Please note: for private individuals we cannot accept a co-borrower. The credit agreement must be set up under one individual s name. 5

6 How will the changes look on i-prompt? How will the changes look on i-prompt? Limited company For limited companies you must confirm their trading name, trading address and contact details including telephone number(s), address, nature of business and bank details. 6

7 How will the changes look on i-prompt? How will the changes look on i-prompt? Partnerships For partnerships you must confirm the individual s details first. This must include the individual s titles, forename and surname, their address and contact details (including telephone number(s) and address), date of birth and nature of business. Trader type is now at the top of the screen, the information that is required for the customer will vary dependant on the trader type Once you have confirmed the individual s details, you can now add in the partnerships details by first of all confirming their eircode/ postcode (if applicable). You can now add in the partnerships trading name, address (if eircode/ postcode was not previously entered) and telephone number(s). All correspondence from CBPFI will be sent to the address shown under partnership. 7

8 How will the changes look on i-prompt? How will the changes look on i-prompt? Sole traders For sole traders you must confirm the individual s details first. Including the individual s title, forename and surname, their address and contact details (including telephone number(s) and address), date of birth and nature of business. If the sole trader operates under a different name and address to the individual you will need to confirm the sole trader details by clicking No on the box highlighted in red below. Here you can confirm their trading name, address and contact details. Please note, if any of the details are the same as the above, these will need to be re-entered here. All correspondence from CBPFI will be sent to the trading address. 8

9 How will the changes look on i-prompt? How will the changes look on i-prompt? Unlimited company For unlimited companies you must confirm their trading name, trading address and contact details including telephone number(s), address, nature of business and bank details. 9

10 How will the changes look on i-prompt? Step 2 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 note, the ID&V requirements apply to private individuals from 31 December Sole Traders and businesses will need to provide these documents from March

11 How will the changes look on i-prompt? Document upload Below is a list of verification documents that CBPFI can accept from the customer: Verification method: a) Passport, or (b) Driving license If neither a or b available then: c) National Identity card, or (d) Residence/ Working Visa. Verification method: A utility/ telephone bill, financial statement, insurance schedule or official letter/ document which shows the customer s name and address dated within the last 6 months. Verification method: Payslip, P60, P45, P21 (ROI), Social Services Card, Drugs Payment Scheme Card, Medical Card, GP visit card, European Health Insurance Card, Tax Assessment, Notice of Tax Credits. Verification method: Signed Running Account credit agreement from the customer. The customer must provide three separate ID&V documents within 30 days of the 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. File size (for uploading) must be 1.5MB or under. If any of the documents have already been received, the browse facility will be greyed out on i-prompt to reflect this. 11

12 How will the changes look on i-prompt? Further changes 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 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. Under Update Client s Details the name and address fields will now be greyed out. You can still amend their telephone numbers and address 12

13 Frequently Asked Questions - Overview What is the Central Credit Register (CCR)? The Central Credit Register (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). 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 Central Credit Register (CCR) will contribute to consumer protection and financial stability by: Providing borrowers with an individual report detailing their credit agreements Providing premium financers, 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 Central Bank of Ireland 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 March 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. 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 March We ll be in touch with you prior to then to ensure that you are prepared. Where can I find out more information about the CCR? Information on the CCR can be found at the following sites:

14 Frequently Asked Questions ID&V Do the ID&V documents have to be dated within a certain timeframe? All documents need to be dated within the last 6 months. For documents such as Driving License and Passports, these just need to be valid (not expired). Will customers need to provide ID&V documents for renewals? No, the CCR requirements are that the regulations apply to new Credit Agreements only and not renewals. What if the customer doesn t provide ID&V documents? The new regulations require ID&V documents to be provided for all finance and lending applications. Without acceptable ID&V documents, we will be unable to authorise finance for the customer. Can we accept a policy schedule as proof of address? Yes, we can accept the renewal document for the policy being funded provided that the information matches the agreement. 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 finance agreement. 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 finance agreement. Does the 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 finance agreement. Can originals be sent in? We appreciate that customers may not want to send their original documents in the post therefore, we have taken the position of accepting clear and legible copies/images of the documents. How do I upload the documents to i-prompt? Please refer to page 10 and 11 in this guide for more details. 14

15 Frequently Asked Questions ID&V What documents will be accepted for ID&V? The list of acceptable documents is as follow: Verification method: a) Passport, or (b) Driving license If neither a or b available then: c) National Identity card, or (d) Residence/ Working Visa. Verification method: A utility/ telephone bill, financial statement, insurance schedule or official letter/ document which shows the customer s name and address dated within the last 6 months. Verification method: Payslip, P60, P45, P21 (ROI), Social Services Card, Drugs Payment Scheme Card, Medical Card, GP visit card, European Health Insurance Card, Tax Assessment, Notice of Tax Credits. Verification method: Signed Running Account credit agreement from the customer. 15

16 Frequently Asked Questions - PPSN Why do I need to capture the customer s PPSN? 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. Are brokers allowed to capture a customer s PPSN? While 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 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 Credit Reporting Act does not commit an offence under section 262(9) of the Social Welfare (Consolidation) Act 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 collect 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 The collection of the PPSN number may only be collected for the purposes of reporting and the use of it for any other matter may be an offence. We would advise that brokers should destroy any records of PPSN once it has been forwarded to CBPFI following collection. If in doubt, brokers should seek guidance from their own data protection advisers. 16

17 Frequently Asked Questions - Other When will the digital journey be available? The new digital journey will be available by the end of February We will communicate further details to you soon about the launch of this new feature. Our aim was to deliver the new digital journey by the end of 2017, however we are keen to incorporate the recent broker feedback we have received to ensure that we provide the best possible solution for you. Why can I no longer 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. 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, eg, marriage certificate. What is needed for changes of name - New loans? 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. With regards to single borrower view of PPSN in the CCR, it should match up the two names against the one PPSN reference. What is needed for changes of name - Post loan 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. Driving license or passport). As per new loans we will ask for marriage certificate or deed poll as acceptable form of ID but also accept driving license/passport and inform broker. 17

18 Our commitment to you At CBPFI, we re here to support you with the enhanced regulatory requirements and we remain committed to working closely with you over the coming months. If you have any queries regarding the CCR, please do contact your Sales Manager who will be happy to help or your query to 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 Close Brothers Premium Finance Ireland Alexandra House The Sweepstakes Ballsbridge Dublin 4 T: