The European Savings and Retail Banking Group (ESBG) supports the Commission’s initiative to launch a retail payments strategy for the EU and the respective public consultation. In anticipation thereof, together with the other European Credit Sector Associations (ECSAs), on 1 April 2020 we published a paper “Payments Policy for Europe: Direction for the five years”. ESBG welcomes this opportunity to provide feedback to the Commission via this consultation as an additional means to get our views across as input for the Commission’s retail payments strategy. ESBG and its Member Banks stand ready to further engage with the Commission on these strategic issues in the weeks and months to come.
ESBG has only responded to Section 2 (Questions for all stakeholders) of the Consultation. The answers are provided from a Member Banks’ point of view. Only the questions that ESBG could respond to as an association of savings and retail banks and that ESBG has responded to are contained in this Position Paper. The responses to these questions have been submitted online to the European Commission.
As the answers given to the yes/no/other and the 1/2/3/4/5/NA questions (or, the tick boxes) had to be synthesised from a variety of Member positions, these not always reflect the messages that ESBG and its Members want to bring across. Therefore, we would like to urge the Commission, in their assessment of our response, to attribute more weight to the verbatim provided than to the boxes actually ticked.
Moreover, ticking certain boxes is sometimes restricting us to provide some further rationale with our tick. This is especially the case for questions 15, 18 and 28. Therefore we urge the Commission specially to take the verbatim provided in this document at 15.1, 18.1 and 28.2 into account as these comments could not be provided in the online questionnaire due to these restrictions imposed.