The European Savings Banks Group (ESBG) is highly concerned about the approach chosen by the Commission to prepare the revision and updating of the current Consumer Credit Directive.
ESBG claims that there has been a lack of transparency and proper consultation of the credit industry. According to the Group, the Commission proposal did not consider the economic and legal context in which each of the national provisions on consumer credit have been developed.
Other points of criticism are among others:
the draft proposal overlaps with existing Directives and fails to show a coherent approach with regard to the existing ‘acquis communautaire’.
the proposal to prevents consumers from making their own decisions
the provisions on data collection are not in line with the current legal and economic reality
guarantors acting for private purposes but providing guarantees for credits used for professional purposes should be excluded from the directive.
Position Paper
© European Savings Banks Group
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