ACOI Compliance Plus 25 May 2010 Ann Fitzgerald, CEO

1. ACOI Compliance Plus 25 May 2010 Ann Fitzgerald, CEO

2. NCA Role in Financial Services • Information • Education • Advocacy • Administrative transfer from March 2010 • Legal transfer from January 2011 • Staff on secondment from the Central Bank

3. Advantages of New Approach NCA & CB concentrate on core strengths “Whole of Wallet” approach from NCA perspective Consumer doesn’t differentiate between regulatory bodies Efficiencies in terms of resources and industry funding

4. Funding of New Approach 100% funding by the Industry (50% industry funding pre-transfer) Levy effective from 1 Jan 2011 Central Bank to collect on NCA’s behalf – most cost effective solution for industry Allocation amounts and model being finalised Timescale for collection dependent on CB’s own levy timetable. Est Sept/Oct 2011 NCA formal communication with industry shortly

5. Key Priorities for 2011 Provision of information on consumer rights through NCA call centre, website, publications and outreach Delivery Autumn 2011 series of new, interactive cost comparison tools for personal finance products Pilot/Roll Out of Workplace Financial Education Programme “Money Skills for Life” Enhanced focus on Advocacy in Financial Services – giving consumers a strong voice.

6. Giving Consumers a Strong Voice Imperative that a strong Financial Services industry is balanced by a strong consumer voice And that the Regulator and policy makers hear from an informed consumer voice NCA now responds to various industry actions/practices And also to consultation papers issued by the Central Bank

7. The Consumer Protection Code – NCA Response to Consultation CPC hugely important from consumer and industry perspective Detailed NCA submission – 30 pages – agreeing/disagreeing with various proposals. Important that CPC, when finalised, is explained to consumers

8. Some Issues Definition of Vulnerable Customer Lack of regulation of Hire Purchase Conflicts of Interest in relation to Tracker Mortgages Know your customer/suitability requirements post sale

9. Some Issues (2) Need for a further review, involving consumer interests, of the Intermediary Market. Difficulties around “fair analysis” and “limited analysis”. Issues around Remuneration: Trail Commission/Commissions & Index Linked Increases/Persistance Rates Levels of Qualification/Grandfathering

10. Some Issues (3) Unregulated Activity by Regulated Firms Need for Clear Blue Water – separate corporate structure, premises, letterheads etc Welcome proposals to enhance responsibilities of product producers. Should lead to more careful product design and more responsible marketing.

11. Key statistics and issues NCA help-line – 60,000 p.a. approx 18% are personal finance 8,000 since July 2010 when the NCA began taking personal finance calls Banking dominates –lending, debt problems and administration issues Insurance - pricing and claims / refusals of cover Problems with Hire Purchase agreements Deposit protection

12. Key statistics and issues www.itsyourmoney.ie ‘Go to’ NCA site for consumers looking for personal finance information Average 45,000 visits per month Newsletter issued to over 19,000 subscribers Most popular content: saving & investing info, mortgage calculator, budget planner, savings rate comparisons, deposit protection info.

13. Compliance Role & Consumer Protection Critical Role of Compliance Function Need to restore trust in industry Problems not confined to banking as complaints to FSO show Banking Products/Investments/Insurance – all very important consumer products with long term implications Industry has to demonstrate commitment to compliance matters, fair play, transparency Consumers should see ACOI as allies in achieving this. alsjdflj

14. Thank you. Questions ?