Paschal Donohoe (Dublin Central, Fine Gael) | Oireachtas source

One of the Department’s main concerns is to ensure that SMEs have access to sufficient lending or liquidity and that access to credit for SMEs is maintained. The Government has announced a range of measures to assist companies to deal with the consequences of the Covid-19 restrictions and to ensure that they have access to sufficient liquidity.

Lenders are obliged, under the Credit Reporting Act 2013, to submit information to the Central Credit Register, CCR. Submissions of information to the CCR must be consistent with the arrangements agreed and in accordance with lenders' obligations under the Credit Reporting Act 2013. The CCR does not produce credit scores. Rather, the information on a credit report provided by the CCR is factual in nature and the information is provided to the CCR by lenders. It contains no guidance, recommendation or prohibition for lenders on what decision they should make on an application for credit or repayment arrangements agreed with borrowers. Subject to complying with applicable law and regulatory requirements, it is a matter for lenders, of course, to make their own lending decisions in accordance with their own credit policies and risk appetites.

The Central Bank, as the regulator, has advised lenders that in their reporting to the CCR, they will need to apply judgment, for example, around whether a restructure has been agreed in response to an identification of financial distress and should be reported as such. The Central Bank’s SME regulations also set out the required treatment of SMEs by regulated entities with regard to the various aspects of business lending. This includes detailed provisions around the credit application process, requirements regarding security, credit refusals and withdrawals, the handling of complaints, the managing of arrears and having in place policies for engaging with SMEs in financial difficulty.

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