BRUSSELS, 10 February 2015 – ESBG welcomes the opportunity to provide comments on the EBA Consultation Paper ‘Draft Guidelines on product oversight and governance arrangements for retail banking products’. ESBG respects EBAs decision to try to enhance consumer protection in the area of retail banking products by carefully thought out detailed regulations.
Against the background of those far-reaching Guidelines ESBG would welcome EBA to ensure at the same time that the Guidelines will be compatible with the existing directives in the same area (such as ‘Consumer Credit Directive’ (CCD), ‘Mortgage Credit Directive’ (MCD), MiFID II, ‘Payment Account Directive’ (PAD) and ‘Payment Services Directive’ (PSD).
ESBG would also like to draw EBAs attention to the fact that smaller credit institutions might not be able to comply with the extended regulation requirements of the Guidelines. Risk is that such smaller institutions as a consequence withdraw from the market for regular financial products. The unintended effect could be a weakening of competition.
>> See specific remarks to EBA regarding draft guidelines