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The EBF agrees that clear, easily accessible and comparable information on fees allows consumers to make an informed choice between payment account offers. EBF members therefore had invested a substantial amount of time and work in developing the draft EBIC Principles on transparency and comparability of personal current account fees. This work would have assisted European consumers in accessing, understanding and comparing information on bank account fees, thus achieving the desired goals. Hence, the EBF very much regrets that this work did not result in an agreement with the European Commission. Since then, some Members States and banking communities have taken a number of initiatives at national level. The EBF would strongly encourage the Commission to give these initiatives a chance to succeed, before further analysis is made. The EBF does not consider further EU legislative proposals at this stage to be appropriate.
On switching, the EBF believes that the Common Principles on bank account switching agreed at EBIC level are the right approach. They simplify the bank accounts’ switching process. Noticeably, where the Common Principles are used, consumers consider the process to be running smoothly. This said, there is always the possibility to improve their efficiency. Indeed, this should be seen as an on-going effort since self-regulatory initiatives are medium-term projects. While acknowledging the potential to improve the efficiency of the process further, the EBF believes this will not be driven by legislation but by an enhanced awareness and communication between the interested stakeholders. Owing to the different conditions and particularities of the national markets in the EU, the EBIC Common Principles should remain voluntary. Therefore, EBF remains committed to promoting bank account switching and with this increasing consumer mobility.
EBF members fully understand the objectives of financial inclusion and agree with the EU Commission on the need for consumers to access financial services to enable them to participate fully in the economic and social life of modern society. The recently adopted Recommendation, addressed to the Member States, is the right initiative at EU level. It allows Member States to take appropriate measures in order to facilitate, where necessary, access to bank accounts by taking into account their specific conditions.
The EBF welcomes, in general, measures aimed at restoring confidence in the banking sector. However, we encourage the Commission to take an all encompassing view of the results of certain studies quoted in the consultation, as well as to consider all available findings, especially in the context of the current crisis faced by banks. In line with the principles of better regulation, it is expected that EU regulatory policy solutions are built on the strengths of evidence-based tools, particularly in the three areas under consideration, where the specifics in the national markets require more flexibility to be left to national level.