02 May 2006

EBIC Comments on Modified Proposal on Credit for Consumers Directive

EBIC issued further comments on a number of detailed remarks on the content of the Modified Proposal for a Directive on Credit for Consumers, underlining that an impact assessment on the proposal should be undertaken to analyse the economic and legal consequences for the EU. On the issue of harmonization and mutual recognition for example EBIC currently finds unclear which elements of the directive are fully harmonised, i.e. how uniform implementation in all Member States would be guaranteed, and which are partially harmonised but also left to the discretion of Member States.

Also, EBIC is very much concerned that the emphasis given to the existence of the mortgage/real estate collateral with respect to the exclusion of mortgage equity withdrawal loans has led the Commission to deviate from the definition of Home Loans as it exists in the Code of Conduct and therefore to leave aside the criterion of the purpose of the loan.

Other issues criticized by EBIC include the Scope (Article 2) and Definitions (Article 3), Standard information (Article 4), Right of Withdrawal (Article 13) and many others.

Full statement

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