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:The effects of the Central Bank's Strategic Plans on consumers of financial services; Initiatives aimed at further enhancing the protection of consumers of financial services; and If the Central Bank so requests, documents, consultation papers or other materials prepared by the Central Bank.I was appointed while a UCD academic in 2018 and extended to a second term in 2021 and completed my term in December 2024. I attended quarterly meetings and commented on a quite large array of documents received in the intervening periods. As fitting for a body of this nature, the proceedings are transparent and the minutes can be seen on the website.
Many items recurred regularly including the development of the consumer protection code in Ireland, inertia in the health insurance market, vulnerable consumers, central bank strategy, digitalisation, and various impacts of Brexit on financial services. Some interesting event-type issues including the withdrawal of Ulster Bank from the Republic of Ireland, meaning that their customers had to switch their banking in a set time-frame with the ensuing communication and technical issues. Over the period I was there, obviously covid was one event that impacted the agenda and organisation, as did cost-of-living issues arising after the invasion of Ukraine. The development of initiatives like MICAR regulations to deal with the increasing use of cry*t0-currencies and new strategies on firms covered under the Markets in Financial Instruments Directive were interesting to witness. Globally, many of these issues will define a lot of our financial lives in the 21st century.
Some general themes that animated how I worked on this include:
Respect for the secretariat and officials. It will probably be obvious to most people but being respectful and recognising you are working with people who have packed agendas and assuming good faith is something I have always tried to do in policy contexts.
Having said the above, your job as an independent member of an advisory board is not just to nod along and be a passive recipient of information. One input that I made consistently throughout the six-year term was the need for two-way conversation, in particular for the independent committee members to bring agenda items rather than just receive them. This is not as obvious as it sounds. In something like the Central Bank, the officials themselves have far more information and day-to-day understanding of the rhythms of policy and regulation than the independent advisors. Raising issues not part of the standing agenda can sometimes make you feel like you are just chipping in and I am sure there were occasions where I raised issues around questions like emerging digital risks, emerging thinking on consumer behaviour etc., that must have felt like academic flights of fancy to people dealing with established issues with set action points and deadlines. One of my formative experiences was the Irish financial crisis and there are a lot of accounts that put a culture of not breaking consensus in discussions around financial services as being a contributing factor and I was always conscious of that when weighing up whether to raise questions and objections. There were many times led by a strong chair when independent members were able to add agenda items, have separate meetings to the officials, request follow-ups etc., The OECD reviewed consumer protection in Ireland recently including the advisory group and made some more recommendations in that regard, including adding consumer groups.
The third thing that animated my thinking was the belief that behavioural science broadly defined is a useful input. That is maybe not surprising for people who know me and in fairness why else would I be in such a room if not to provide thinking from these areas? But again, there is a line to be walked between relevance to the issues at hand, the capacity of the different groups to absorb evidence, and the quality of the evidence base. As well as the international literature in the area, there is also a strong community of researchers and scholars working on behavioural aspects of regulation and policy in Ireland (e.g. recent annual conference here). Throughout the six years I tried to point where possible to relevant and cogent behavioural work across areas of consumer decision making including pensions, mortgages, insurance, credit cards, novel emerging digital projects etc., and made a number of recommendations and provided some support on Central Bank research in these areas. Behavioural consumer research is a valid input into consumer protection and financial regulation and I was glad to have the opportunity to be part of the policy process in this regard.
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