You are missing the point of my question.Well they'll go back at least 5 years for your credit history. I wouldn't have thought that going back less that a year of your accounts/general finances was unusual?
Again, while similar, it's not the same. In your case, they requested and you provided additional information. It was your choice to provide it. And self employed income is always more thoroughly reviewed.There does seem to be some logic to it behind the scenes where if they see some things, they request longer periods to review.
It's an interesting question. More generally, did they seek your permission to look at your current accounts at all even for the last 6 months? I don't think they or any lender do. It's possibly covered under their data privacy notice that they can use certain data in approval of new lending products.But should they be allowed and did they expressly get my permission to do so?
No, it shouldn't be "if they like" and it's not a prerogative. And you are also missing the point. With any other bank, my application is assessed on what I provide. If they are unhappy or have concerns, they can request more and it is my choice to provide it or not. I have no problem with this.Surely they can go back greater than 6 months if they like. They need to satisfy themselves as to your affordibility, creditworthiness etc etc. Its their perogative. I dont think there is an explicit restriction on them from doing so.
It's an interesting question. More generally, did they seek your permission to look at your current accounts at all even for the last 6 months? I don't think they or any lender do. It's possibly covered under their data privacy notice that they can use certain data in approval of new lending products.
I doubt they need any consent from you to look at this. They are the Data Controller so your current account details are hardly private to them. They may have regulatory obligations around money laundering to ask you questions. While it is true that you have been treated differently than a non-AIB customer would have been, it doesn't follow that they have done anything wrong.No, it shouldn't be "if they like" and it's not a prerogative. And you are also missing the point. With any other bank, my application is assessed on what I provide. If they are unhappy or have concerns, they can request more and it is my choice to provide it or not. I have no problem with this.
Again with another example, if I did not bank with AIB, they would not have queried that lump sum because they never would have seen it. So in essence, they have treated my application differently because I am an existing banking customer
Yes, this is what I am getting at with my question. The application only requests 6 months of non-AIB statements, it doesn't actually state what they will do with AIB account info. I have scanned (but not thoroughly read) some terms and conditions and I don't see any mention of what rights they reserve to use account info. The Data protection notice does contain several generic 'how we use your data' but nothing specific.
In my case the mortgage was with Ulsterbank and all my other accounts are with Ulsterbank. I didn't actually provide anything, it started when they queried something in the previous few months of the application, then one I told them it was sole trader type income, I started getting questions going back two years along with other requests.Again, while similar, it's not the same. In your case, they requested and you provided additional information. It was your choice to provide it. And self employed income is always more thoroughly reviewed.
The application only requests 6 months of non-AIB statements, it doesn't actually state what they will do with AIB account info. I have scanned (but not thoroughly read) some terms and conditions and I don't see any mention of what rights they reserve to use account info. The Data protection notice does contain several generic 'how we use your data' but nothing specific.
The level of information gathered should be appropriate to the nature and complexity of the product or service being sought by the consumer, but must be to a level that allows the regulated entity to provide a professional service
A regulated entity must gather and record sufficient information from the consumer prior to offering, recommending, arranging or providing a product or service appropriate to that consumer. The level of information gathered should be appropriate to the nature and complexity of the product or service being sought by the consumer, but must be to a level that allows the regulated entity to provide a professional service and must include details of the consumer’s
This is my point, it is not defined for AIB accounts. The info required is defined for non-AIB accounts, for non-PAYE income and most other relevant items. I wouldn't have refused permission (it made no difference to me) but that still doesn't justify them looking. Interestingly, having looked through the consumer protection code it mentions in Section 3.33I'm not sure if that specifically answers your question on "how far back can they go?" for AIB customers, but to me it seems reasonable for the lender to define what they feel is sufficient information is for underwriting. Put it another way, would you have refused them if they'd asked for specific permission?
A regulated entity must ensure that there are effective Chinese walls in place between the different business areas of the regulated entity, and between the regulated entity and its connected parties, in relation to information which could potentially give rise to a conflict of interest or be open to abuse
But the industry norm is typically 6 months so it should apply to AIB and non-AIB accounts. When the underwriter looks at my application, they should only see 6 months of my statements.
The threshold is "conflict of interest or be open to abuse" and I don't see how what AIB have done comes anywhere near either of these.There should be sufficient barriers in place to prevent them going further back unless specifically requested and acknowledged by the consumer
A regulated entity must ensure that in all its dealings with customers and within the context of its authorisation it:
2.1 acts honestly, fairly and professionally in the best interests of its customers and the integrity of the market;
2.5 seeks from its customers information relevant to the product or service requested;
2.11 without prejudice to the pursuit of its legitimate commercial aims, does not, through its policies, procedures, or working practices, prevent access to basic financial services;
The Code does not say this thoughYou are right that the code does not state there needs to be absolute consistency between information they hold or gather but at a very high level, they should seek this info from the customer and not go digging for it themselves.
They didn't 'gather' it except to maintain your bank account records. You are dealing with a single corporate entity for both you current account and mortgage. It's perfectly reasonable for them to look at your entire record.Thanks for that, I had been reading the consumer protection code last night. However, I disagree that it is a 'right' but rather an obligation of the lender to satisfy themselves of a consumers affordability and perform the appropriate due diligence. I don't particularly care how much information they need or want, however, I do care how they gather it and it should be clear from the beginning.
Section 5 of the code is suitably vague to allow plenty of interpretation but the use of "sufficient" and "appropriate" does not imply the lender can do what they like with information they already have access to.
This is my point, it is not defined for AIB accounts. The info required is defined for non-AIB accounts, for non-PAYE income and most other relevant items. I wouldn't have refused permission (it made no difference to me) but that still doesn't justify them looking. Interestingly, having looked through the consumer protection code it mentions in Section 3.33
This is the basic point I am making. I have no problem providing 6/12/24 months of accounts if that is required. But the industry norm is typically 6 months so it should apply to AIB and non-AIB accounts. When the underwriter looks at my application, they should only see 6 months of my statements. There should be sufficient barriers in place to prevent them going further back unless specifically requested and acknowledged by the consumer
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