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Central Bank Updates

The Central Bank of Ireland (‘CBI’) has published updated guidance on the Consumer Protection Code 2012 (‘Guidance’).

The primary clarification in the Guidance for insurers relates to rebates. The CBI considers that the inclusion of a policy condition that rebates will not be refunded to the consumer and additional premiums will not be sought from a consumer (under specified levels), is not prohibited under the Code. The Guidance further clarifies that any insurance intermediary must obtain prior written agreement from the consumer every time it intends to deduct any charges from a premium rebate.

Additionally, there are clarifications regarding email as a durable medium, unsolicited contact practices and regulatory disclosure requirements in electronic advertising.

The CBI has issued a number of other notable publications in recent months, including: