Central Bank of Ireland publishes updated customer profiles for assessment of Section 149 notifications

Under section 149 of the Consumer Credit Act 1995, credit institutions must notify the Central Bank of Ireland if they wish to introduce any new customer charges or increase the level of any previously notified customer charges. In assessing these notifications, the Central Bank has regard to the potential impact of the proposed charge on customers. In the case of notifications relating to personal current accounts, the Central Bank uses a number of notional activity profiles to assist in this assessment.

The Central Bank has today published updates to the notional customer activity profiles (PDF 362.5KB). This is the first update to the profiles since 2015. The profiles are evidence-based and informed by data and research on consumer behaviour and trends.

There are four notional customer activity profiles:

1. Standard – uses the majority of the functionality available on their account. Regular user of online banking and contactless transactions and occasionally incurs limited out-of-order charges.
2. Non-Standard – similar usage pattern to a standard profile customer, but uses overdraft/unauthorised overdraft facilities and frequently incurs out-of-order transaction fees.
3. Electronic – significant user of the more automated functionality of their account and of electronic/online and contactless transactions. 
4. Manual - user of more manual-type transactions, such as over-the-counter (OTC) transactions. Unlikely to use contactless transactions and has a greater reliance on cheques.

The key changes in the updated profiles are as follows:

• An overall reduction in OTC withdrawal usage figures, particularly for Manual profile customers, due to a greater shift towards cashless transactions;

• A significant increase in Point of Sale (POS) Debit transactions, including online transactions, for all customer profiles;
• A significant decrease in POS Debit Contactless transactions for Electronic and Standard profile customers, but an increase for Manual profile customers;
• An overall decrease in credit transfer usage figures, reflecting different transaction methods being used; and,
• An increase in Direct Debit/Standing Order Charge figures for all customer profiles except the Electronic profile, which remains unchanged.

The updated profiles reflect data based on pre-COVID behavior.

The Central Bank is committed to regularly reviewing the profiles used in the assessment of Section 149 notifications. It will continue to have regard to data and research on consumer behaviour, in line with its mandate of ensuring the financial system operates in the best interests of consumers and the wider economy.