Evaluation of the Consumer Credit Directive: EBF position

13 May 2021

We look with concern to unregulated creditors and the consequences that they can bring to the stability and well-functioning of the market.

The Directive on Consumer Credit (CCD) provides a solid framework for fair access to credit for European consumers.  For the sake of market stability and consumers’ safety, all creditors should be supervised and required to respond to the same rules on consumer protection, Know Your Customer (KYC), Anti-money laundering (AML), and reporting requirements – in accordance also with national laws.

For the above-mentioned reasons, we suggest that any effective evaluation of the Directive should focus on the following key points: 1) Avoiding gold-plating practices from the Member States, since the provisions of the Directive should be consistently applied throughout the EU, without creating fragmentation. 2) The timely implementation and enforcement of existing rules to reduce regulatory fragmentation rather than providing additional requirements 3) the supervision of all creditors to ensure the same level of consumer protection. 4) The provision of a future-proof and technology-neutral text that enables the Directive to be effective despite fast technological developments.

EBF

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