The inclusion of Credit Unions within the scope of MCC represents a significant shift in how Credit Unions across Ireland will operate, emphasising the importance of competency in financial advice and product selling. The revised MCC mandates that Credit Union staff engaged in savings/investment and lending operations attain the appropriate MCC qualifications, as set out by the Central Bank of Ireland.
At LIA, we are committed to assisting Credit Unions in navigating the updated Minimum Competency Code (MCC) requirements. To address queries and provide clear guidance, we have compiled a Frequently Asked Questions (FAQ) below.
Summary:
- For Lending and Mortgage Activities: Staff members partaking in these areas are required to obtain specific qualifications as outlined by the Central Bank of Ireland, including LIA’s APA Loans which will cover all lending and mortgage activities and the CUA designation which will cover consumer credit activies.
- For Term Deposits Activities (exceeding 1 year): Staff members involved in managing or advising on Term Deposits equal to or greater than 1 year must achieve the qualifications specified by the Central Bank of Ireland, which include LIA’s Credit Union Adviser (CUA) and/or APA Investment professional designations.
- Important Deadlines: The final date to acquire these qualifications is set for 1st October 2028. However, individuals operating in these sectors must ensure they are registered for the relevant examinations by 1st October 2024.
APA Loans will cover you for:
Consumer Credit including:
- associated payment protection insurance;
- and associated permanent health insurance.
Mortgage Credit Agreements, Housing Loans and Home Reversion Agreements including:
- associated mortgage protection;
- associated permanent health insurance;
- associated payment protection insurance;
- associated home and contents insurance;
- associated endowment assurances and pension plans in relation to their use in
- associated accumulating funds to repay housing loans or mortgage credit agreements;
- associated mortgage indemnity guarantee insurance; and
- associated structural defect insurance.
On the 7th August 2024, the updated Credit Union Adviser (CUA) designation has been recognised by the Central Bank of Ireland for the purposes of the Minimum Competency Code (MCC) in respect of Consumer Credit and Associated Insurances, and for Term Deposits. This recognition will take effect from 1 October 2024 when these additional competencies come in scope for credit unions. The CUA designation is already, and continues to be, recognised under the MCC for the activity of a credit union acting as an insurance intermediary. Holders of the current CUA designation , who do not hold either the QFA designation or the APA (Loans) designation (both of which are already accredited under the MCC for Consumer Credit Agreements and Associated Insurances), will be required to undertake a short process of online learning (CPD module with quiz) in respect of the new material relating to Consumer Credit Agreements and Associated Insurances contained in the updated CUA qualification, in order to be accredited under the MCC in respect of Consumer Credit and Associated Insurances and Term Deposits. We will write to those CUA holders (i.e. those who do not hold either the QFA designation or the APA (Loans) designation) directly setting out how this process of online learning and assessment will be carried out.
Yes, if their role or responsibilities are directly involved in providing advice or information on, or arranging or offering to arrange, savings and investment products, including Term Deposit with a term greater than 1 year.
The MCC does not apply to credit union directors, per se. However, credit union directors engaged in the lending or investment processes within a Credit Union are required to comply with MCC regulations.
Compliance Officers, Risk Management Officers, and Finance Officers may need to obtain APA Loans and APA Savings and Investment if their roles involve offering advice or information on these regulated products.
The MCC applies when “providing advice or information to consumers on retail financial products”.
Therefore, if a credit union official is discussing lending, or Term deposits greater than 1 year, even just for information purposes, then they will be required to meet the MCC requirement for lending and savings and investment.
Yes as a QFA you meet the MCC requirements for the following retail products.
- Life Assurance
- Pensions
- Savings and Investments
- Mortgage Credit Agreements, Housing Loans, Home Reversion Agreements and Associated Insurances
- Consumer Credit Agreements and Associated Insurances
The UCC Pathways Diploma in Credit Union Practice meets MCC for Consumer Credit, but does not meet the MCC for Mortgage Credit Agreements or Housing Loans.
While the CUA designation will meet MCC requirments for Term Deposits, those that do not hold the CUA designation can complete the APA Savings and Investment course to meet this requirement. If you want to advise on other savings and investment products, outside of Term Deposits, the APA Investment designation will be required.
Holders of the current CUA designation , who do not hold either the QFA designation or the APA (Loans) designation (both of which are already accredited under the MCC for Consumer Credit Agreements and Associated Insurances), will be required to undertake a short process of online learning (CPD module with quiz) in respect of the new material relating to Consumer Credit Agreements and Associated Insurances contained in the updated CUA qualification, in order to be accredited under the MCC in respect of Consumer Credit and Associated Insurances and Term Deposits. We will write to those CUA holders (i.e. those who do not hold either the QFA designation or the APA (Loans) designation) directly setting out how this process of online learning and assessment will be carried out. More information can be found here.
In the case of NCI, we can offer an exemption against QFA Regulation for the NCI subject Law & Regulation for Financial Services and against QFA Loans for the NCI subject Loans. There are a number of NCI qualifications that included those subjects. If someone has passed both the NCI subject Law & Regulation for Financial Services and the NCI subject Loans, we can grant that person the APA (Loans) designation.
Depending on the module options chosen, the following courses may include one or both of such subjects.
- Certificate in Credit Union Business (NCI)
- Diploma in Financial Services for Credit Unions (NCI)
Holders of the Diploma in Credit Union Operations (University College Cork and Irish League of Credit Unions) and the Advanced Certificate in Credit Union Practice (University of Ulster and Irish League of Credit Unions) can apply to LIA for the award of the designation Credit Union Adviser (CUA). Transferring members must provide confirmation that their CPD obligations, up to and including the date of transfer, have been met.
We are happy to discuss additional exam sittings with Credit Unions where there is a demand.
The Chairperson of a Credit Union will need to hold qualifications relevant to their role and responsibilities, especially if they are directly involved in regulated activities. We would need to determine what their role and responsibility are before we would offer some guidance.
Yes that’s fine as long as they are not selling or providing advice or information on products that fall under the scope of MCC. If they are involved in MCC activities, they will need to be supervised by someone who holds the necessary MCC qualifications.
LIA offer special accommodations to students with additional needs. We would encourage you to contact our education team, education@lia.ie, we would love to speak with you and talk about the options available.
The final date to acquire these qualifications is set for 1st October 2028. However, individuals operating in these sectors must ensure they are registered for the relevant examinations by 1st October 2024.
For more information about how LIA can support you, please contact the education team: education@lia.ie.
For inquiries specifically related to your MCC requirements, the Central Bank of Ireland offers support through their dedicated email: competency@centralbank.ie.