We look with concern to unregulated creditors and the consequences that they can bring to the stability and well-functioning of the market.
The
Directive on Consumer Credit (CCD) provides a solid framework for fair
access to credit for European consumers. For the sake of market
stability and consumers’ safety, all creditors should be supervised and
required to respond to the same rules on consumer protection, Know Your
Customer (KYC), Anti-money laundering (AML), and reporting requirements –
in accordance also with national laws.
For the above-mentioned reasons, we suggest that any effective
evaluation of the Directive should focus on the following key points: 1)
Avoiding gold-plating practices from the Member States, since the
provisions of the Directive should be consistently applied throughout
the EU, without creating fragmentation. 2) The timely implementation and
enforcement of existing rules to reduce regulatory fragmentation rather
than providing additional requirements 3) the supervision of all
creditors to ensure the same level of consumer protection. 4) The
provision of a future-proof and technology-neutral text that enables the
Directive to be effective despite fast technological developments.
EBF
© EBF
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