EBIC letter on modified proposal for the Consumer Credit Directive

09 January 2006

In a letter to the Austrian Presidency, EBIC set out a number of points that should be clarified or improved in the discussion about a new modified consumer credit directive. The committee proposes that small amount credits should be fully excluded up to an amount of Euro 500. Also, all home loans, even unsecured, as well as mortgage credit should be excluded from scope since they are different from consumer credit in that they are long term products with their own specificities.

Other issues include:

Responsible Lending and Borrowing - Current terms would shift the balance of liabilities inappropriately and exclusively towards financiers.

Information Requirements - EBIC strongly opposes overloading consumers with excessive information, creating unnecessary burdens and costs.

Right of Withdrawal – EBIC proposes that the withdrawal period be reduced to seven days.

Early Repayment - A right to early repayment should only be allowed under narrowly defined circumstances.

Letter

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