On 28 March, the Central Bank published its guidance on its newly launched Consumer Protection Risk Assessment Model (CPRA). In last month's edition of the Arthur Cox Regulatory Update, we reported on the Central Bank's Consumer Protection Outlook Report, which highlights the Central Bank's intention to carry out a programme of consumerfocused thematic inspections. The aim of the CPRA is to support these inspections by providing supervisors with a framework to assess how effectively risks to consumers are being managed within regulated firms.
The CPRA assesses management of Consumer Protection Risk under the following five headings:
» Module 1 - Governance & Controls: considers whether a firm's organisation structure is appropriately designed to allocate roles and responsibilities in relation to the effective management of Consumer Protection Risks.
» Module 2 - People & Culture: addresses the firm's culture to assess whether it encourages personal accountability and is supported by appropriate incentives.
» Module 3 - Product Development: focuses on whether products are advertised and marketed in a clear, fair and non-misleading manner.
» Module 4 - Sales/Transactions Process: looks at how management information to monitor and track sales performance affects consumer outcomes.
» Module 5 - Post Sales Handling: evaluates whether post sales systems and controls result in fair consumer outcomes.
Selected firms will receive formal notification from the Central Bank informing them of the planned thematic on-site inspection.
The Central Bank's Guidance on the CPRA is here.
A link to the Central Bank's press release is here.