Consumer Advisory Group

The role of the Consumer Advisory Group ('CAG') is to advise the Central Bank on the performance of its functions and the exercise of its powers in relation to consumers of financial services including:

1. The effects of the Central Bank's Strategic Plans on consumers of financial services;
2. Initiatives aimed at further enhancing the protection of consumers of financial services; and
3. If the Central Bank so requests, documents, consultation papers or other materials prepared by the Central Bank. 

Theodor Kockelkoren

Theodor is the Chair of the Consumer Advisory Group. He is currently heading State Supervision of Mines, the Dutch regulatory institute focusing on energy extraction and subsoil activities. The State Supervision of Mines promotes safety for people and environment. It has thus a pivotal role in ensuring a safe energy transition in the Netherlands. Previously, Theodor served as a board member and executive director of the Authority for the Financial Markets and the Dutch conduct of business regulator for the financial sector. He has also served as Chairman of the G20/OECD taskforce on Financial Consumer Protection and was partner with McKinsey & Company. 

Liam Delaney

Liam is a Professor of Behavioural Science and Head of the Department of Psychological and Behavioural Science at the London School of Economics. His career has focused on the intersection of economics, psychology, and public policy applications and he has developed a number of programmes in this area. Previously held positions include Professor of Economics at University College Dublin, Visiting Professor of Economics at Stirling University, Deputy Director of the UCD Geary Institute and Deputy Dean of Stirling Management School. Professor Delaney has a keen interest in the measurement foundations of behavioural welfare economics and has built several interdisciplinary projects examining how to measure real-world economic preferences. He has published widely in economics and psychology journals, including the Journal of European Economics Association and Psychological Science. His current areas of research include ethical foundations and trustworthiness of behavioural public policy, mental health and economic policy, and the measurement foundations of behavioural welfare economics.

Dr. Tadhg Nagle

Dr. Tadhg Nagle is a Lecturer (Business Information Systems) at Cork University Business School (CUBS), University College Cork (UCC), and associate faculty at the Irish Management Institute (IMI). Specialising in the business value of data, Tadhg has created several tools and techniques (such as the Data Value Map to aid organisations in getting the most out of data assets. He has also developed a brand of applied research (Practitioner Design Science Research) that arms practitioners with a simple and scientific methodology in solving wicked problems. He is currently an Associate Investigator on the SFI Funded FinTechNext project investigating the value and impact of Open Banking.

Pat O'Sullivan

 Mr. O'Sullivan’s career spans 46 years as a practitioner across various sectors within the financial services industry. He started his career in International Banking with Bank of Ireland in 1974 and after 10 years moved to First Active where he held various senior management roles over a 20 year period; from Branch Manager to Head of Mortgage Operations, Head of Customer Services & Head of Operations. From 2004 to 2005, he held the role of Secretary of the Irish Mortgage Council (affiliated to the Irish Banking & Payments Federation, now BPFI) and, in 2005, was appointed Director of Financial Services with the Irish Brokers Association (now Brokers Ireland). In 2008, he was appointed CEO of LIA (Life Insurance Association), a position he held until his retirement in 2020. LIA has played a key role in Ireland in improving the standards of professionalism amongst staff of regulated firms who give financial advice to consumers.

Patricia Rickard-Clarke

Patricia Rickard-Clarke is a solicitor, a Fellow of the Institute of Banking and a member of the Society of Trust and Estate Practitioners Special Interest Group on Decision-Making Capacity London. She was a partner in McCann FitzGerald Solicitors until 2001. She was appointed a part time Commissioner of the Law Reform Commission in 1997 and was the full time Commissioner from 2001 to 2012. She was the lead Commissioner with regard to the Commission’s work on: Vulnerable Adults and the Law (which included recommendations for the reform of the law on Decision-Making Capacity) and on Personal Debt Management and Debt Enforcement (which included recommendations for the introduction of personal insolvency legislation).

From 2012 to 2016 she was a member of the Council of the Hospice Foundation and of its Think Ahead Project Advisory Group of the Forum on End of Life. She was a member of the Council of the Royal College of Physicians of Ireland from 2013 – 2017.

She is currently the Chair of Safeguarding Ireland clg and Deputy Chair of SAGE Advocacy clg.

Isolde Goggin

Isolde Goggin was chairperson of the Irish Competition and Consumer Protection Commission (CCPC), the body charged with competition (antitrust) enforcement, merger control, consumer information and education, and consumer enforcement, from 2014 to 2021. From 2011 to 2014 she was Chairperson of the Competition Authority, and oversaw its amalgamation with the National Consumer Agency to form the CCPC. She has held a variety of roles in the competition, consumer protection and telecommunications regulation areas (including as Chairperson of ComReg, the Commission for Communications Regulation) and has a particular interest in Better Regulation.

Susanne Rogers 

Susanne Rogers is a Research and Policy Analyst with Social Justice Ireland, an independent think tank and justice advocacy organisation that advances the lives of people and communities through providing independent social analysis and effective policy development, to create a sustainable future for every member of society and, society as a whole. Susanne leads on community development and social inclusion policy for Social Justice Ireland, as well as researching and developing policy and strategies in the areas of income distribution, social inclusion, public participation, access to services and housing. Susanne has an honours degree in Theology and English literature (All Hallows, DCU), an Advanced Diploma in Money Advice Practice (University of Ulster) and a Masters in Social Justice and Public Policy (Waterford Institute of Technology). 

Susanne has worked for a national debt advice organisation, directly with individual clients and also at national policy level. She was a registered Approved Intermediary, authorised by the Insolvency Service of Ireland and successfully supported debtors in their application for a Debt Relief Notice. Her subject matter expertise was recognised as she was invited to take part in an EU expert mission to the Insolvency Service of Cyprus in 2016.

Lucie Tedesco 

Lucie Tedesco is an accomplished financial services executive, with over 34 years’ experience in financial sector policy and regulation, financial consumer protection, governance, risk management, law, strategy and operations. She is a former Commissioner of the Financial Consumer Agency of Canada (FCAC), a federal agency responsible for supervision and enforcement of market conduct requirements applicable to federally regulated financial entities and for the promotion of financial consumer rights and the development of programs to strengthen Canadians’  financial literacy. Prior to that role, Ms. Tedesco held senior positions with Export Development Canada, and more recently, served as Strategic Adviser and Counsel at McCarthy Tétrault LLP in the Banking and Financial Services Regulatory Group. As Commissioner of the FCAC, Ms. Tedesco was a member of the Office of the Superintendent of Financial Institutions’ Financial Institutions Supervisory Committee; the Canadian Department of Finance’s Senior Advisory Committee; and a member of the Board of Director of the Canada Deposit Insurance  Corporation (CDIC). Ms. Tedesco served on the Board of the Investment Industry Regulatory Organization of Canada and as Chair and Vice-Chair of the International Financial Consumer Protection Organisation (FinCoNet). She is currently a Governor of The Ottawa Hospital, The University of Ottawa and on the Board of the Financial Services Regulatory Authority of Ontario. Ms. Tedesco earned a Juris Doctor degree and a Bachelor of Arts degree from The University of Ottawa. 

Dr. Amie Lajoie

Dr. Amie Lajoie is a senior researcher with expertise in socio-economic rights and household over-indebtedness with over ten years of professional experience in civil society and academia. Amie currently works as a policy analyst for the Money Advice and Budgeting Service (MABS), where she delivers evidence-based research and public policy recommendations on subjects related to personal debt, retail banking, digital literacy and financial exclusion, energy poverty and consumer protection. Previously, Amie was a Senior Researcher for the Dublin-based think tank TASC, specialising in social inclusion and economic inequality. She has a number of research publications on topics such as women’s human rights, financial capability, adult literacy, and young people and financial decision-making. Amie has presented, and provided testimony, to several Irish government departments and ministries, Oireachtas Committees and the Low Pay Commission, and sits on the advisory sub-committee for the Vincentian MESL (Minimum Essential Standard of Living) Research Centre. She holds a PhD in Political Science from the University of Galway and MA in Human Rights from the University of York, United Kingdom. 

Meetings

2017 - Present

February 2017

Ger Deering, Financial Services Ombudsman, provided members with an overview of his office's Dispute Resolution Model. Work is progressing on the next phase of a project in relation to commission payments to intermediaries. Next steps will include, inter alia, incorporating feedback arising from the Discussion Paper into a draft Consultation Paper, and developing proposals to further strengthen protections for consumers. The Group was provided with an overview of the latest Mortgage Switching Research results. Members were presented with the Consumer Protection Outlook Report (CPOR) 2017. The CPOR outlines the Directorate's consumer protection objectives, an assessment of the current and emerging consumer environment and risks to Consumer Protection objectives, for full consideration by regulated firms. Members were provided with an overview of the Moneylending sector, its' regulatory framework, consumer research and areas of concern within the sector. Consumer Protection propose to commence a review of the Moneylenders Code in Q4 2017. Additional operational updates provided to the Group included: the protection of consumers in a digitalised financial services environment and whether or not enhancements are necessary to reflect this new environment; the Tracker Mortgage Examination Review; and an update on the conferences the Central Bank will facilitate in April.

2016 Meetings

November 2016

This meeting marked the end of tenures for both the Chair, Anthony Walsh and member, Elaine Kempson. Their valued contributions and commitment to the Group was acknowledged by both the Governor and the Director of Consumer Protection. The management team provided the group with a brief overview of their relevant sectors and members' views were sought on the emerging consumer protection environmental and sectoral risk assessments as well as priorities for the 2017 work programme, including a possible assessment of the Consumer Protection rules framework in the medium term. A discussion took place around Fintech and how it is affecting the work of the Directorate, and members were asked to inform our thinking in this area. The Central Bank's Communication unit provided an overview on the status of the Central Bank's project to re-develop the Central Bank's website, including the development of a new section with information specifically aimed at the public. The new website is due to launch in Q1 2017.

September 2016

The meeting began with initial discussions on motor insurance pricing, structured products, mortgage arrears and the tracker mortgage examination. Members were updated on Consumer Protection's annual risk assessment process and how it will help determine the Directorate's objectives for 2017. The Group was presented with the findings of both the thematic inspection on Health Insurance renewals, as well as Structured Retail Products. Members were provided with an overview of the main changes introduced in the Payment Services Directive and also an update on the Department of Finance consultation on National Discretions under MiFID II and IDD relating to inducements to intermediaries. The Group was advised on the progression of the Tracker Mortgage Examination review and were updated on the Mortgage Switching research being undertaken by the Directorate.

May 2016

Jill Forde, Head of Communications, provided members with an overview of the Central Bank's emerging communications strategy and new website developments. The Group was advised that the Directorate is considering carrying out consumer focused research in order to gain a better understanding of consumer experiences, behaviours, perceptions and attitudes towards mortgage switching. The output of this research will help inform CPD's consideration of any future work that may be required in the area of mortgage switching. Cyril Roux, Deputy Governor joined the meeting to outline and discuss the Central Bank's strategic direction and plan, including its objectives and key priorities over the next few years. Members were also provided with an overview of the current position on mortgage arrears with a particular emphasis on Long Term and Non-Performing Loans. Other areas of discussion focused on the Payments Account Directive in terms of its transposition, the Minimum Competency Code as well as future CPD projects and inspections.

February 2016

Following a general discussion on topical issues, an overview of the Retail Intermediary sector was presented to members which generated a discussion on key consumer risks. The proposal to respond to the EU Green paper on Financial Services was discussed as well as the risks and benefits arising from current commission arrangements in place between product producers and intermediaries across the insurance, banking and investment sectors. The Group was presented with CPD's approach to influencing a consumer focused culture in the provision of financial services as a key strategic priority over the next three years. Members were also given an overview of how market intelligence, including data on consumer complaints, is used to support a risk and evidence-based approach to our work.

2015 Meetings

November 2015

Following a presentation on the outputs from internal consumer risk assessments, the focus of this meeting was in seeking input from members on strategic priorities for the Consumer Protection Directorate for 2016 and beyond in order to inform our annual work planning and the preparation of the 2016 Consumer Protection Outlook Report.

August 2015

Views of the Group were sought in relation to the on-going review of the Code of Conduct for Business Lending to Small and Medium Enterprises, particularly the responses received to the public consultation on this project. Members were updated on the proposed public consultation on enhanced transparency measures for consumers with variable rate mortgages and on progress in work related to the transposition of the EU Payments Account Directive, particularly on Member State discretions. A general discussion took place on work underway in the area of health insurance.

May 2015

Following a general discussion on topical issues, an overview of the Life and Non-Life insurance markets from both a prudential and conduct of business perspective was presented to members which generated a discussion on key risks and issues. The implementation of the European Supervisory Authority product oversight and governance guidelines and technical standards was discussed, focusing on some of the key principles. An update on the research into Hire Purchase and Personal Contract Plans was presented at the meeting. The findings from the recent review of Debt Management firms compliance to date with Central Bank requirements was delivered and next steps for this industry sector were outlined.

April 2015

The Registrar of Credit Unions delivered a presentation outlining the Irish Credit Union sector and its key priorities and challenges including regulatory developments which their division are currently focusing on. Members also received a copy of the Netherlands Authority for Financial Markets report on the outcome of the peer review of the Consumer Protection function of the Central Bank of Ireland. A discussion took place on how the Central Bank is approaching the regulation of a changing payments sector including innovation and emerging changes in payments products, services and providers.

2014 Meetings

November 2014

An overview of the Consumer Protection Outlook Report - which outlined the range of consumer protection issues and risks which the Directorate will focus on during 2015, was presented. As part of the ongoing discussions around the 5 'C's framework within which the Directorate operates, a discussion took place on Compliance and how the Directorate utilises industry Board meetings, speaking engagements, seminars and Roadshows to promote compliance in industry. Members were asked to comment two EU consultation papers on product oversight and governance, to assist the Central Bank's input into the drafting of guidelines. A brief update on the transposition of the Mortgage Credit Directive and the consultation paper on Macroprudential measures were also discussed.

August 2014

A verbal update was given to members of topical issues currently under review by the Consumer Protection Directorate (CPD). Following this, a presentation was delivered on the proposed development of a Consumer Protection model that supports prudential supervision and conduct of business.

An update on the 2014 peer review of the Consumer Directorate by the Netherlands Authority for Financial Markets was provided to the group.

The Directorate has commenced the annual sectoral risk assessment process for 2015, and members were invited to submit their views on areas of concern, which could be considered for work plans for the following year. The Directorates new approach to engaging with EU and International Stakeholders was outlined, and members input requested on how the Directorate should measure positive outcomes from participation at an EU level.

Colleagues from the Financial Stability Division participated in a Q&A session on the June SME Market report. Member's views were sought on related CPD projects including the SME Code Review and on-site SME themed review.

May 2014

A verbal update was given to members of topical issues currently under review by the Consumer Directorate. Members then discussed how the Consumer Directorate promotes a challenging and outcome focused approach to its work, the work of those we regulate, and the Irish market place.

A discussion took place on Virtual Currencies and whether they should be regulated, including an update on developments in relation to this in the European context. Members also discussed the issue of Crowdfunding and peer-to-peer lending both in an Irish and International environment. The Central Bank proposes to issue a warning notice to consumers and industry in June 2014 on this topic.

The team involved in the development of a central credit register discussed the progress towards implementation of the register which will have data available from several key financial sectors. The register is intended to promote responsible lending and help drive better lending decisions.

An update was given to members on the proposed Debt Management code including the proposal to issue a second consultation document in June.

February 2014

A verbal update was given to members of topical issues the Consumer Directorate have been dealing with in recent months, including the restructuring of the banking system and sale of loans to unregulated entities. A discussion took place on how regulators, industry and consumers need to come together to try and rebuild and maintain consumer confidence in the financial services industry.

The Registrar of Credit Unions gave a presentation on the sector in Ireland outlining the context and challenges including the establishment of a Commission on Credit Unions. Following this a discussion took place on the Health Insurance sector, around the proliferation of products and the impact of increased premiums on consumers.

Members were informed of new powers available to the Central Bank to establish a customer redress scheme for problems which are widespread or regular in the financial services sector, these include the Central Bank having the power to direct a regulated financial service provider to make appropriate redress to customers.

Financial Services Consultative Panels

The Central Bank Reform Act 2010 replaced the Financial Services Consultative Consumer Panel and the Financial Services Consultative Industry Panel with the new advisory arrangements set out above.