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
European Banking Authority (EBA) on ESG risk management
The European Savings and Retail Banking Group (ESBG) submitted its response to the consultation launched by the European Banking Authority (EBA). ESBG insists on the need for consitency with CSRD and CSDDD, the addressees of this guideline should also
Enhancing Transparency in Bank Disclosures: ESBG delivers comprehensive response to the EBA’s Pillar 3 data hub consultation
On 14 December 2023, the European Banking Authority (EBA) published a discussion paper on the Pillar 3 data hub processes and its possible practical implications.
IASB Exposure Draft (ED) on Financial Instruments with Characteristics of Equity
On 29 November 2023, the International Accounting Standards Board (IASB) proposed amendments in an Exposure Draft to tackle challenges in financial reporting for instruments with both
ESBG’s response to the EFRAG Comment Letter on Financial Instruments with Characteristics of Equity
On 29 November 2023, the International Accounting Standards Board (IASB) proposed amendments in an Exposure Draft to tackle
ESBG advocates for increased clarity and streamlining of supervisory reporting requirements
On 14 March, ESBG submitted its response to the European Banking Authority (EBA) consultation on ITS amending Commission Implementation Regulation (EU) 2021/451 regarding supervisory reporting
WSBI-ESBG advocates for robust implementation of the BCBS Pillar 3 framework for climate-related financial risks
On 14 March, WSBI-ESBG submitted its response to the Basel Committee on Banking Supervision (BCBS) consultation on its Pillar 3 disclosure framework for climate-related financial risks
ESBG stresses the need for consistency and clarity in its Response to the SFDR Review Consultation
ESBG submitted its response to the European Commission’s consultation on the SFDR review, aiming to enhance transparency in sustainability-related disclosures within the financial services sector
ESBG response to the EBA’s consultation on Guidelines on preventing the abuse of funds and certain crypto-assets transfers for ML/TF
The guidelines on the “travel rule” delineate the actions that Payment Service Providers (PSPs), Intermediary PSPs
ESBG responds to the SRB consultation on the future MREL policy
The European Savings and Retail Banking Group (ESBG) submitted its response to the consultation launched by the Single Resolution Board (SRB) in December 2023 on the future of the Minimum Requirement for own funds
ESBG’s response to the Commission’s consultation on the GDPR
The primary EU legislation ensuring the fundamental right to data protection is the General Data Protection Regulation
