At what stage should a mortgage lender have to provide offer information?

Brendan Burgess

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The Irish government has to transpose the Mortgage Credit Directive into Irish law. The Department of Finance has a consultation process on some issues where the government has discretion. This is one of the most important areas and I am keen to make a submission which would reflect all sides of the argument.





Discretion 15 – The European Standard Information Sheet (ESIS) may be required to be supplied before the creditor makes a binding offer (Article 14.4).

The European Standard Information Sheet (ESIS) is a standardised notice that will allow consumers to directly compare different mortgage offers from different banks.

Ireland may provide for the obligatory provision of the ESIS before the provision of an offer binding on the creditor (bank).

If Ireland opts for this, then the ESIS shall only be required to be provided again where the characteristics of the offer are different from the information contained in the ESIS previously provided. An example of such a change would be an adjustment in the interest rate.

Consultation Question 15: Should Ireland oblige creditors to provide consumers with the
ESIS before the provision of a binding offer? If so, why?
 
This strikes me as the type of regulation which achieves very little, but imposes a big paperwork obligation on the lender. Ultimately consumers pay for excessive regulation.

Lenders should be allowed to give Approval in Principle and sketch out the terms of the loan - amount, interest rate and term. If they are required to complete a complex ESIS, it will slow the process of giving AiP which is not in anyone's interest.
 
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