The European Banking Federation (FBE) released a position paper on the proposal for a Directive on Consumer Credit. 
FBE  deplores the fact that no technical and forward looking analysis has been undertaken on the impact which the proposed Directive will have on the credit
market. Although credit institutions play a vital role in sustaining economic growth within the Union, the Federation is affraid that the proposed Directive runs the risk of penalising: 
- creditors, whose costs and risks would significantly increase; 
- suppliers and manufacturers, who need their customers to be provided with credit in due time; 
- consumers, because flexibility will be reduced whilst the range of products which are now available to them will be restricted. Simple requests that customers take for granted today, could become a thing of the past.
FBE  also criticises that the lack of balance in the Proposal between the responsibilities of lenders and those of borrowers is striking. The Federation belives that much of the specific criticism raised by the industry could be met if the proposed measures would be more targeted. Accordingly, the Commission should: 
• examine if each of the measures proposed is in conformity with the principle of proportionality, and  
• verify whether there is a real need to make all the Proposal’s provisions applicable without distinction to all products which fall within its scope.  
FBE  Paper 
      
      
      
      
        © FBE
    
      
      
      
      
      
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