07 March 2012

European Banking Industry Committee's observations on the Recommendation on access to a basic payment account and the IMCO Working Document

EBIC accepts that action is needed in a number of Member States in order to increase the percentage of consumers with bank accounts. Therefore, it welcomes the adoption of a Recommendation on access to a basic payment account (BPA) which is flexible enough to take into account the very different national situations.

When considering possible legislative measures, the focus should be on bringing banking penetration levels in those Member States in which these are low up to the levels already achieved in Member States with a high percentage of banked consumers.

EBIC argues it is important to make a distinction between the social (access to BPA) and internal market (cross-border access for EU residents) policy approaches. The granting of a right to a basic payment account (BPA) to EU residents within the current initiative has been identified as an issue deserving further inquiry as to its scope and appropriateness.

In EBIC’s view, if the very purpose is to combat financial exclusion, the right to a basic bank account should be granted only to consumers resident in his/her respective country. It should be noted that for the purposes of the anti-money laundering due diligence requirements, payment services providers in specific Member States will have to verify the status of being ‘legally resident’ in the Union, which might well be challenging.

EBIC reiterates that social and cultural factors related to financial exclusion cannot, however, be easily removed through legislation. The form and content of any measure at EU level to combat social exclusion through the promotion of financial inclusion should be taken in compliance with the principles of subsidiarity and proportionality, and with due care for preserving the diversity of the banking sector.

Given the varying degrees of action needed at national level, EBIC calls for a longer period during which the measures adopted as a result of the Commission Recommendation have been in force before assessing their impact.

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