In our response to the public consultation on the evaluation of the Consumer Credit Directive (CCD), ACCIS recalls that creditworthiness assessments are an important regulatory requirement to protect consumers from over-indebtedness and recommends five ways to improve consumer outcomes in consumer credit:
- Bring the CCD data requirements in line with the Mortgage Credit Directive (MCD) – “all necessary and relevant factors”
- Recognise that a creditworthiness assessment covers the affordability risk for the borrower
- Emphasise the importance of consulting external databases, aligning the CCD with the relevant provisions in the MCD
- Emphasise the value of consulting positive credit data
- Recognise the value of consulting non-credit data and other relevant data
In our view, the Directive should support that all necessary relevant data is made available to lenders for creditworthiness assessment purposes, which depending on the circumstances of the individual and the credit applied for can include credit data, non-credit data or other relevant data sources.