|
|
EBF particularly welcomes the mention that “there is no need to revise the Directive, but that instead priority should be given to ensuring that it is correctly transposed".
Indeed, the Consumer Credit Directive was adopted in April 2008 after more than six years of intense discussions amongst all interested parties. In many cases, the new rules had to be implemented by lenders in a very short timeframe. The EBF therefore recognises that some adjustments at national level may still be necessary in some Member States, as a few of them did not transpose some of the provisions of the Directive due to the short deadline that had been set.
In addition, the EBF welcomes the fact that the motion for a resolution does not refer to a possible merger between the Consumer Credit Directive and the Directive on credit agreements relating to residential property (CARRP).
The EBF strongly believes that consumer credit and mortgage credit are two different products, with very distinct characteristics. Should the two texts be aligned at EU level, the EBF believes that they should be handled separately so that their distinct features are appropriately taken into consideration in the interests of lenders, borrowers and the wider economy.