The scope of application of the proposed directive to financial services is not entirely clear when it comes to investment services and to information obligations in off-premises contracts.
The relationship between investment services, which come under the law related to off-premises contracts, and financial services whose price depends on fluctuations in the financial market outside the trader's control, which are exempted from the law related to off-premises contracts, is unclear and should be clarified.
Generally speaking, there is a need to distinguish the scope of application of the proposed Consumer Rights Directive in general and the scope of application of the individual chapters relating to: (1) information obligations, (2) off-premises and distance contracts, (3) consumer sales and guarantees, and (4) unfair contract terms.
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