My submission on the review of the Central Bank's Consumer Protection Code

Brendan Burgess

Founder
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The closing date for submissions on this is the end of this month, i.e. this day week.

I would encourage people to make submissions.

I attach my submission. While there are lots of issues I would like to raise, I have focussed solely on pricing as it's the most important issue and, as usual, the Central Bank wants to wash its hands of it.

Summary

  • When a consumer is taking out a mortgage or an insurance policy, the absolutely key issue is the price of that product
  • Yet the Central Bank has been reluctant to take any action on the issue of pricing.
  • The Central Bank will devote considerable resources to discussing vulnerability and financial literacy. The reality is that almost all mortgage customers are vulnerable and financially illiterate. The Central Bank should protect all customers and not just focus on minority groups.
  • This actual Review itself is a good example of the Central Bank’s washing its hand of the issue. In 9 hours of round tables on the review, it allocated “the 15 minutes left before the coffee break” to deal with pricing issues.
  • Bizarrely, the only time the Central Bank has intervened to prohibit unfair pricing practices has been on insurance while ignoring the much more significant issue of mortgage pricing.
Recommendations for changes to the Consumer Protection Code

  • Financial Services providers should be prohibited from charging existing customers higher prices than they charge new customers with the same characteristics
  • Mortgage providers should be prohibited from offering cashback to new customers
  • Financial services providers should be prohibited from incorporating artificial features into their products whose sole purpose is to trick customers into making poor choices through ignorance or inertia.
 

Attachments

  • Submission on review of Consumer Protection Code Brendan Burgess.docx
    48.1 KB · Views: 170
May be worth mentioning that searching "review of the Central Bank's Consumer Protection Code" will give the correct location for feedback in the first result.
Also there is a short form multiple choice survey with space for additional comments at the end for people like me
 
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