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“An integrated EU consumer credit market cannot be expected to be created by harmonisation of legislation alone and to be achieved solely with the modified proposal for a Consumer Credit Directive”, the study concludes.
The study also notes that cost reductions and economies of scale from selling consumer credit products in other EU Member States may be limited from a creditors’ point of view, reducing the incentives for creditors to cross borders even with reduced legal fragmentation.
Finally the report comes to the conclusion that the “approach of full harmonisation with flexibility and of mutual recognition for issues where there is flexibility could lead to a ‘regulatory’ mix that creates confusion among consumers and affects consumer confidence adversely.”
'Full harmonisation, as previously suggested by the Commission, is totally unacceptable. But it would be sensible to consider a moderate and cautious review of consumer credit law, based on common standards in key target areas combined with broad exclusions in others” Mr Lechner said.
He could support harmonisation in the areas of right of withdrawal, effective interest rates, contractual and pre-contractual information and early repayment.