IFF criticizes ‘total harmonisation’ of Consumer Credit

22 September 2003

The report, prepared by the institute for financial services (IFF) and commissioned by the Federation of German Consumer Organisations criticizes the “total harmonisation” approach of the proposal which cuts into existing national consumer protection legislation, and the incomplete clarification of the interest rate regulation.

Among others, the current proposal should therefore be modified to incorporate consumer protection and the prevention of over indebtedness into its goals, reinsert the minimum harmonisation clause and the article concerning ‘circumvention’.

Also, there is no need for regulation for a central database. It is a matter for creditors to protect themselves against irrecoverable debt. The protection of creditors is not a valid objective of consumer credit protection legislation.

Full paper

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