In our response to the public consultation on the inception impact assessment on the review of the Consumer Credit Directive (CCD), ACCIS states that the review should in the least touch upon the following two elements: (i) to include the principle of full-file credit information sharing; and (ii) to reinforce creditworthiness assessments. The principle of full-file sharing of credit information – that combines both positive and negative information from both banks and nonbank lenders – should be enshrined in the review of the CCD as a cornerstone of credit information markets. The provisions in the CCD on assessing creditworthiness should also be reinforced. In particular, the CCD should recognize that creditworthiness assessments include affordability risk and that those assessments should be based on relevant information as opposed to sufficient information.