29 March 2012

EBF: Observations on the IMCO draft Report on Access to Basic Payment Account

The European Banking Federation has followed the actions undertaken by the European institutions aiming at preventing social exclusion through the adoption of measures promoting financial inclusion for consumers, notably the granting of a right to access to a basic payment account (BPA).

EBF says it is important to state at the outset that measures aiming at promoting financial inclusion should be flexible enough to allow adaptation to the very different national situations. Further, it is important to make a distinction between the social (a right to an access to a BPA) and internal market (cross-border access for non-residents in the country of the account) policy approaches.

As a general observation, it is appropriate to differentiate between consumers unable to obtain access to a bank account, and those who do not wish to have one and distinguish, within the total number of unbanked EU consumers, those who are excluding themselves because they prefer – for whatever reason – not to have a bank account from those who cannot access basic banking services. Any national initiative can only be targeted at the latter group.

Payment services providers must be allowed to charge ‘reasonable fees’ since there are costs involved with provision of the service. Therefore, any future initiative should allow the imposition of reasonable fees, in the light of specific national circumstances, to consumers.

It should be also acknowledged that payment services providers, when opening a payment account, have to conduct customer due diligence controls in order to comply with the requirements of the anti-money laundering legislation.

What is more worrisome to the EBF, is that payment services providers should not be required to open a BPA based on ‘non-standard proof of identity’ (ECON draft Report – letter J). Further, once the payment account has been opened, payment services providers should be allowed to terminate the basic payment account contract in exceptional circumstances under relevant Union or national legislation on money laundering and terrorist financing or on the prevention and investigation of crimes. Additional observations have been presented in the EBF observations on the ECON draft Report on Basic Banking Services.

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