Close Brothers Premium Finance

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

2 Contents What is the Central Credit Register 3 Why is the Central Credit Register needed 4 Broker digital journey 5 Customer digital journey 6 Non-digital journey 7 Changes to i-prompt 8 Verification documents 10 Frequently asked questions 12 2

3 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 loan applications. Consumers will have the opportunity to see what credit information lenders hold about them. What data will 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 10. 3

4 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, this was 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 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 4

5 How the Central Credit Register (CCR) will affect how we do business with you? How the Central Credit Register (CCR) will affect how we do business with you? Over the last few months, we have been liaising with the Central Bank of Ireland (CBI) to help us work with you in order to meet the new regulations. As part of the new regulations we are now required to capture Identification and Verification documents (ID&V) for all new business customers. We are taking this opportunity to transform our business by introducing electronic signature (E-sign) and an online portal which our customers will be able to use to upload their identification documents. Central Credit Register digital journey route: Customer decides to pay for their insurance policy by monthly Direct Debit Instalments Broker reads/ sends script to customer then submits loan (via i-prompt or software house). Loan details include bank details and address CBPFI sends to customer with a link to provide ID&V information and E-sign But don't worry if your customer chooses not to go down the digital journey as we will also provide you with the ability to upload their ID&V documents directly onto i-prompt. Customer uploads ID&V documents on portal Customer receives welcome pack confirming RACA has been received ID&V and RACA sent to CBPFI for verification and authorisation Customer E-signs Credit Agreement Please note, if you want your customer to go down the digital journey route, it is important that you do not upload the customer s signed RACA on to i-prompt direct. By doing this, it will not allow the customer to access our online portal. 5

6 How will the E-Sign journey work for the customer? Central Credit Register digital journey route (customer): Customer receives invitation from CBPFI Customer must verify their account by using their bank account or mobile to log in The customer will then be able to view their SECCI, RACA, payment terms, paperless SEPA Direct Debit Mandate and give digital consent. They can then upload ID&V documents and sign their Running Account Credit Agreement (RACA) (Signing their RACA) (SECCI and preview of RACA) (Q&A) (ID&V uploads) (Payment terms, digital consent and paperless Direct Debit Mandate) The verification documents and signed RACA will be sent to CBPFI for authorisation 6

7 How will the non-digital journey look? If your customer chooses not to go down the digital journey route, we have updated i-prompt to allow you to upload their ID&V documents directly on to our system. Central Credit Register non-digital journey route: SUBMIT PRINT Customer decides to pay for their insurance policy by monthly Direct Debit Instalments Broker reads/ sends script to customer then submits loan (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 on to i-prompt If you do not verbally 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. 7

8 How will the changes look on i-prompt? How will the changes look on i-prompt? Step one: We have made small changes to how you enter in the customer s loan details, please see below: 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 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. This will give the customer the opportunity to upload their own ID&V documents and sign online Please note, for private individuals we cannot accept a co-borrower, the credit agreement must be set up under one individuals name. 8

9 How will the changes look on i-prompt? Step two: Once you have successfully confirmed the loan, if you choose not to go down the digital journey route (non E-sign), you will now need to upload the customer s ID&V documents along with their signed RACA. This can be uploaded in the customer s loan. Click on the Documents link from the main menu bar in the customer's loan then click on Add Paperwork. For further information on the verification documents that CBPFI can accept please see next page. 9

10 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 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 10

11 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 customers names or address once the loan has been confirmed. The customer can call CBPFI at any point to change their name/ address on the system. In order to change their details the customer will have to send CBPFI proof of name/ address. Under Update Client s Details the name and address fields will now be greyed out. You can still amend their telephone numbers and address 11

12 Frequently Asked Questions What happens if I don t collect the bank details when setting up the loan? If you collect and enter the bank details when confirming the loan, we will be able to provide the customer with access to our portal where they will be able to upload their ID&V documents as well as E-Sign the RACA. If your process requires you to collect bank details later on, you will need to upload the documents via i-prompt and obtain a wet signed RACA. What happens if a customer doesn't provide an address? A valid address is required in order to take advantage of our fast and simple direct journey. Without this information you will need to upload the customer s identification documents and RACA directly into i-prompt. 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 What if my 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 offer finance to your customers. I do business with CBPFI via a software house/integrated partner will the digital journey still work? Yes it will still work as the digital journey takes place after the loan has been placed with CBPFI. How does the credit agreement get signed if I haven't enabled the digital journey? You can still follow your current process for obtaining the signed credit agreement. However, you will also need to upload the identification documents directly into i-prompt. 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. 12

13 Frequently Asked Questions 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. At CBPFI, we are taking this as an opportunity to improve the way we work with you and our customers by providing a digital journey and the ability to E-Sign the credit agreement. Who does the customer need to contact if they have problems with the digital journey? Customers will be directed to you in the first instance as they may have queries relating to the journey or information contained in documentation. 13

14 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) Close Brothers Premium Finance Ireland Alexandra House The Sweepstakes Ballsbridge Dublin 4 T: