EC consultation on the New Consumer Agenda: EBF response

CONSULTATION RESPONSE

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EC consultation on the New Consumer Agenda: EBF response

BRUSSELS, 6 October 2020 – The EBF has responded to the European Commission consultation on the New Consumer Agenda. More specifically, we would like to highlight the following points:

New Consumer Agenda

➢ Importance of financial educational campaigns aimed at increasing consumers’ awareness

• Financial education and financial literacy would provide consumers with a sounder understanding of financial services and product and put consumers in the driving sit by allowing them to be better equipped in navigating the financial world;
• Within the scope of protecting consumers, it is important to increase measures taken to reduce frauds against consumers. In this regard, education of consumers and information campaigns are of great importance to increase the general knowledge of consumers on financial services and also reduce the risks of being affected on an individual level.

➢ Need to boost digital skills

• The pandemic highlighted how important it is for consumers to acquire an adequate level of digital skills and to know how to use alternative channels for services and information fruition. To boost digital skills should be one of the main objectives of regulators at national and European level.

Consumer Credit Directive

➢ Ensure the enforcement and adequate implementation of existing rules to reduce regulatory fragmentation

• We would encourage to focus on further clarifying and enforcing the existing rules in order to ensure that all lending businesses (including non-banking businesses) are captured by the scope of the Directive and equally supervised. Policy-makers must always apply the principle of “same activities, same rules and same supervision” in order to ensure consumer protection and market integrity.

➢ Need for clear and simple information to be provided to consumers

• Consumers receive the same information at different stages, which leads to a flood of information for them. We believe that an effective pre-contractual and contractual information should contain the relevant parameters of the credit contract, but also be simple and concise enough to ensure that consumers are not overwhelmed with the information provided and can read it on digital devices.

➢ Flexible creditworthiness assessment that would ensure financial inclusion

• We believe that flexibility is a key quality of a proper assessment of creditworthiness. Any standardisation of such a process would lead to serious risks of financial exclusion, due to the fact that consumers may be rejected by all consumer credit providers. Common standards for credit worthiness assessment would set an average which could exclude low income borrowers financed by more specialised institutions such as borrowers with atypical profiles in reason of irregular income.
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For more information:

Elona Morina, Policy Advisor – Retail & Innovation

e.morina@ebf.eu +32 474982375

About the European Banking Federation: