Borrowers whose loans are sold to unregulated entities are now protected by the Consumer Protection (Regulation of Credit Servicing Firms) Act 2015 which has just been enacted. The purpose of the Act is to ensure that consumers retain the protections they had prior to the sale of their loan. This Act will require entities dealing with the consumer to be authorised by the Central Bank and subject to its Codes of Conduct. Dealing with the consumer is credit servicing and the definition of credit servicing is broad.
Owners of loan books, including Special purpose Vehicles, who deal directly with consumers, that is, who are servicing their own loan books, will be regulated. Otherwise they can have the loan book serviced by a regulated credit servicing firm. In other words, some regulated entity will be responsible for all credit agreements.