The Credit Reporting Act 2013 (the "CRA") established an official statutory register (the "Register") operated by the Central Bank of Ireland ("CBI") to record the amount of credit in the Irish economy. The Register will also enable creditors to check a potential borrower's credit status before advancing credit.
Banks established in Ireland and authorised by the CBI will already be aware of the implications of the CRA if they have consumer credit customers, due to information-gathering and reporting obligations under the CRA having been introduced for consumer credit during 2017. However, credit providers such as alternative lenders and other business lenders along with purchasers of non-consumer debt in the secondary markets who have had no exposure to consumer credit, now need to be aware of the potential application of the CRA which imposed reporting obligations effective from 30 September 2018.
For more information on the credit reporting obligations arising from the CRA, please see our previous client update Ireland Reminder – Credit Reporting Obligations1.
Anyone involved in lending, extending credit or imposing interest in any context should consider whether it has any obligations under the CRA.