BRUSSELS, 3 September 2021 – ESBG responded to the European Commission’s public consultation on its proposal for a Directive on Consumer Credits on 30 August. In their response, ESBG members call on the Commission to broaden the scope of the definition of ‘lender’ to any kind of lender (including platforms) to ensure all are supervised at the same level for the same lending activities (including non-banks).
ESBG also calls for keeping the 200 EUR threshold for the lower limit of the scope, as a smaller amount would incur high processing costs disproportionate to the return (and the same can be said for short-term loans of less than three months).
The Commission announced the draft text of the proposal on 30 June. The previous Consumer Credit Directive (CCD), dating from 2008, does not consider recent developments which have a wide impact on credit loans, such as digitalisation. It also overlaps with other legislative texts which have since been updated. These changes should be reflected in the CCD text.
On the required information, ESBG members welcome the Commission’s proposal to provide consumers with simplified, streamlined pre-contractual information. They are concerned, however, that the newly proposed one-pager (SECCO) might actually be in addition to the existing SECCI. If so, this would go against the goal of reducing the information overload on the consumer. As a solution, ESBG believes that the SECCO should be an alternative to the SECCI, and not an addition. We also call on the Commission to embrace digitalisation by allowing information to be provided via a computer or tablet, and not interpret ‘durable medium’ to mean strictly printed paper.
In addition, regarding the creditworthiness assessment, ESBG considers that it should be proportional to the type of credit. The creditworthiness assessment should not be the same, for example, for short-term overdrafts and a considerable loan. In the case of payment in few instalments, the consultation of a database of unpaid credits could be sufficient to grant credits of small amounts and of a duration of less than three months, and this consultation should become compulsory.
Download
related
May 17, 2022
Data Act – An open data economy should be multilateral and cross-sectoral
ESBG's response to the European Commission consultation on the proposed Data Act calls for a horizontal regulatory approach to establish a consistent and harmonised rules for all sectors. ESBG is the…
May 12, 2022
Overtime for Ukrainian war refugees: DSGV employees donate over 100,000 euros through extra work
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
May 12, 2022
Stand with Ukraine: Erste family provides extensive humanitarian aid
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
May 12, 2022
The German Savings Banks Association ( DSVG ): More than 100,000 accounts already opened for Ukrainian war refugees
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
May 12, 2022
CaixaBank has been leveraging its network of branches in Spain to assist asylum seekers and refugees fleeing Ukraine
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
May 12, 2022
Ukraine: ESBG members reaffirm their social responsibility
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
April 28, 2022
ESBG response to ESMA’s consultation on guidelines of MiFID II suitability requirements
ESBG's response to the European Securities and Market Authority (ESMA) consultation on some MiFID II sustainability aspects. European banks calls for clear procedures and to avoid unnecessary…
April 4, 2022
Developing a proportionate, fair and efficient IRRBB framework in the EU
On 4 April 2022, ESBG responded to the EBA consultation specifying technical aspects of the revised framework capturing interest rate risks for banking book (IRRBB) positions.
March 24, 2022
ESBG members waive bank transfer costs to support Ukrainian people
European Savings and Retail Banking Group members are standing in solidarity with people in need in Ukraine.
March 7, 2022
European Commission review of the Mortgage Credit Directive
SBG sent its response to the European Commission questionnaire on what to include in the upcoming Review of the Mortgage Credit Directive (MCD).