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EBF Chief Executive Guido Ravoet wrote a letter to Commissioner Barnier to express the concerns of the EBF with regard to the forthcoming EC initiative on bank accounts intended to cover access to basic payment accounts, transparency and comparability of bank account fees and bank account switching.
EBF believes that the evidence to justify the need for value added, subsidiarity and proportionality of a binding EU legislative initiative in the area of access to bank accounts, fee transparency and switching remains questionable. This is even more the case when trying to demonstrate the need to cover cross-borders aspects.
On access to payment accounts:
The EBF is broadly supportive of granting financially excluded citizens access to a basic bank account at a reasonable cost and at a domestic level. However, it is unclear to EBF why customers who are not to be considered as financially excluded should be given a right to hold such an account when they could access a regular payment account or rely on the Single Euro Payments Area (SEPA). In EBF view, the rationale for a basic payment account is combating financial exclusion and EBF believes that this should be the European Commission’s specific focus.
On bank account switching:
EBF believes that a requirement to impose switching mechanisms of this nature would be totally unjustified and disproportionate. Given that any shortcomings differ from country to country, the EBF believes that the Common Principles on bank account switching agreed by the European Banking Industry Committee (EBIC) and approved by the European Commission and the Council of the EU still constitute the right approach given that they acknowledge the differences in national markets across the EU.
On transparency and comparability of bank account fees:
The EBF believes that existing EU legislation, coupled with national and self-regulatory measures, already provides solid ground for the transparency and comparability of bank fees. Furthermore, the Payment Services Directive (PSD), which will be reviewed soon, contains comprehensive information requirements and has already established a common legal framework for payment services fee transparency. To this end, it would seem appropriate to determine the effectiveness of the instruments already in place before considering any further legislative interventions.