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CBI Public Statement: Update on Central Credit Register error

By News

The Central Bank of Ireland issued a public statement on 21 August 2023 in relation to an archiving error that affected the retention period of some information on borrowers’ credit reports held on the Central Credit Register (CCR). Today (13 October 2023) the Central Bank is providing an update on the matter.

As previously outlined, certain borrower information was retained on the CCR for up to an additional three months, and was available for inclusion in credit reports between 1 June and 7 August 2023. While the information was an accurate representation of what was previously reported by lenders, the additional three months of information should not have been held or made available in credit reports during this period. This constitutes a breach under data protection legislation.

The error was first brought to the Central Bank’s attention by a member of the public on 3 August. It was fully resolved by 7 August 2023, with the database reflecting the correct five-year retention period. Credit reports provided from 7 August 2023 do not reflect any additional information.

Once the error was rectified, the Central Bank focused on establishing any impact of this incident on borrowers. The main mechanism through which borrowers could be impacted is where the CCR contained information around loan performance over these additional three months, which may have adversely affected decisions by lenders to extend new credit or decisions by borrowers to seek new credit.

As the information held on the CCR is one of many factors that lenders use when making credit decisions, assessing the impact of this error has been a complex process. The CCR does not decide if a loan is approved or not, lenders make that decision. The CCR also does not calculate a credit score. Our assessment of the impact has required extensive engagement with 270 lenders to determine whether, and if so how, the additional credit information influenced their credit decisions.

To date, the Central Bank’s investigation has established that:

  • The records of 20,872 borrowers who had performance data pointing to repayment difficulties in May, June or July 2018 (the three additional months that should have been deleted as planned) were accessed by either lenders or borrowers.
  • These borrowers were associated with 31,013 enquiries by lenders (as borrowers may have made more than one credit application). Within that:
  • For 30,963 credit enquiries, lenders have confirmed that their credit decisions were not impacted by the excess data. There are a range of reasons for not being impacted, including lenders’ own lending policy and the timeframe that it considers.
  • For 9 credit enquiries, lenders have confirmed that the excess data was one of the factors which influenced their credit decisions. These enquiries related to personal loans and credit card products.
  • For 41 credit enquiries, lenders have not yet been able to confirm if there was any impact. The Central Bank continues to engage with lenders in relation to this cohort.
  • There were 820 borrowers who accessed their own report, which included information that pointed to repayment difficulties during the additional three months. The records of some of these borrowers were also accessed by lenders, as above.

A phased communication process is underway and the Central Bank has written to those identified as being at highest risk of being impacted by the error. All borrowers associated with applications where lenders have confirmed that the excess data influenced their credit decisions have been contacted. The Central Bank has engaged with the lenders to ensure that there is a contact point in place for impacted borrowers should they wish to discuss their previous application or re-apply for credit. The lenders have also confirmed the excess information previously received will not impact on any new applications.

In light of this incident and to strengthen controls in this area, the Central Bank is also initiating a broader external review of the data management and data protection controls in place with respect to the operation of the CCR.

The Central Bank has engaged with the Data Protection Commission (DPC) throughout this incident. We have received notification from the DPC of the commencement of an Inquiry into this breach. The Central Bank takes our data protection obligations seriously and will continue to engage fully with the DPC on these matters.

Vasileios Madouros, Deputy Governor for Monetary and Financial Stability, said: “The Central Bank of Ireland sincerely regrets, and apologises for, this error. While we have a range of controls in place in the operation of the CCR, it is clear they were insufficient to prevent this specific incident. This falls short of our own standards and we have implemented immediate measures to prevent this error from reoccurring. We are also commissioning a broader external review of data management and data protection controls in place when operating the CCR. The CCR is an essential service to enable better credit decisions by borrowers and lenders, and it is crucial that we hold ourselves to the highest standards in operating it. We will continue to engage fully with the Data Protection Commission.”

Further information on how the Central Credit Register processes data can be viewed at Our public contacts helpline can be reached on 0818 681 681. Borrowers can request a copy of their credit report through the CCR website.

Further information

Media Relations:

Ewan Kelly: / 086 158 7094

CUDA comments on the CBI Report on Financial Conditions of Credit Unions

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The Central Bank of Ireland have today (30th March 2023) published its ninth edition of the Financial Conditions of Credit Unions Report.

Commenting on the Central Bank’s report on the Financial Conditions of the Credit Union sector, ‘Kevin Johnson, CEO of the Credit Union Development Association, which works with over 50 credit unions, said

“Loan volumes are up, and the loan-to-asset ratio is definitely improving, but not by as much or as quickly as we would like. We believe that there’s an absolute need to resolve this by expanding the loan profile of credit unions and prudently growing loan books across the sector.  

Competition in the mortgage market has reduced following the departures of Ulster Bank and KBC, and with the non-banks struggling to offer competitively priced products, there’s a clear opening for credit unions to substantially expand their mortgage products. CUDA has been at the forefront of this, with its members initially entering the mortgage market in 2018 targeting specific lending needs, since 2021 we have worked with credit unions to expand their offerings and we are now working to expand this to more credit unions. 

New legislation that is progressing through the Oireachtas and scheduled for enactment this year will support this, as it will allow credit unions to refer lending business to each other which means that even those credit unions without mortgage lending underwriting skills will be able to facilitate their members. 

Each credit union is a separate legal entity with its own Board and management team, and they are not currently permitted to share business. These changes will help credit unions make a greater financial, social, and environmental contribution as their legislation framework is modernised.

Credit Unions have significantly modernised in the past decade – their structure, legal and regulatory status, product offerings, and service delivery methods have advanced considerably. In particular their digital capabilities were accelerated during the Covid-19 pandemic. Members can still access the traditional set of personal loans and savings, and now they can also avail of current accounts, ‘one stop shop’ retrofit loans, mortgages, revolving credit, debit cards, community loans, agricultural loans, as well as loans for small businesses.  These are accessible face to face, over the phone or via online facilities.  Recent rises in interest rates will have a significantly positive impact on the ROA for all credit unions as this will result in them getting a better return on their investments.”

Credit Union Development Association (CUDA) delighted to see publication of the Credit Union (Amendment) Bill 2022

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Over many years credit unions have operated within outdated legislation – legislation not fit for purpose in a modern era. For some time now, CUDA has called on the Government to introduce enhancements to the existing credit union legislation to ensure credit unions can reach their potential on behalf of their members.

Today, the Government has published a new Credit Union (Amendment) Bill. On behalf of its members and the credit union sector at large, CUDA welcomes this development. According to Kevin Johnson, CEO CUDA, “this unique opportunity will enable credit unions to offer and deliver more benefits through enhanced products and services to existing and future credit union members”.

Credit Union legislation was last overhauled 10 years ago by the Credit Union and Co-operation with Overseas Regulators Act 2012.

The published amendments will allow greater collaboration and choice when developing credit products and offerings to consumers such as sharing large community project loans amongst a number of credit union participants (“loan sharing” or “loan participation”), and the ability to offer a full range of services to consumers, irrespective of the fact that a credit union may not have that product themselves e.g. mortgages, by introducing the member to a colleague credit union that does offer the product or service (“loan introduction”).  These are standard practices amongst credit unions in other jurisdictions such as Canada.

CUDA particularly welcomes the changes that recognise the great work of volunteer directors, who provide a professional service pro bono. The changes will allow them to focus more on the overarching governance and strategic direction and policy making of the credit union, while allowing a credit union assign new roles, focusing on implementation and operations, to its professional management team.

There is no doubting the trust members place in their credit union. The relationship is unique. CUDA is pleased that the legislative changes will allow credit unions continue their special relationship with members and the community through environmentally friendly methods – including the introduction of digital enhancements to their existing services and facilitating additional loans to the community. However, CUDA is quick to note that credit unions are very aware of the importance of face-to-face interactions with their members. Something that is greatly diminishing in other areas of the banking.

CUDA commends the great work achieved by all stakeholders, noting that the process started out with interested parties having differing views and priorities. The pandemic brought an additional layer of complications. CUDA says that the published Bill is an example of what can be achieved through meaningful cooperation.  CUDA would like to take the opportunity to express its appreciation for the productive contributions of Minister of State, Séan Fleming TD, Minister for Finance, Pascal Donohoe TD, the team at the Department of Finance led by Brian Corr, the Registrar of Credit Unions, Elaine Byrne, and her team at the Central Bank, and our colleagues in CUMA, ILCU and NSF.

CUDA looks forward to the speedy implementation of the legislation to ensure credit unions can continue to deliver their first-rate service – ensuring the best outcomes for credit union members, their communities and the wider Irish economy.

CUDA Congratulates New Registrar of Credit Unions on her Appointment

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The Central Bank of Ireland has today announced the appointment of Elaine Byrne as the new Registrar of Credit Unions (CBI press release available here.)

CUDA CEO, Kevin Johnson stated ‘We have had the pleasure of working with Elaine in her role as Deputy Registrar for the past 16 years.  In congratulating Elaine on her appointment we very much look forward to a constructive and positive engagement with her and her team.  Elaine takes on the important role of Registrar at an incredibly busy time for credit union regulation, an agenda that includes implementation of the outcomes from the Credit Union Policy Review, role of CUs in the Consumer Protection Code review, impacts of the Individual Accountability Framework, business development initiatives, role of credit unions in the Retail Banking Review, various EU / EBA directives as well as our ongoing work on capital and liquidity requirements for credit unions.