Distance Marketing of Financial Services Directive: EBF response
The EBF acknowledges that the Distance Marketing of Financial Services Directive (DMFSD) aims at creating a common framework for cross-border market of financial services, while attaining a high level of consumer protection. We see the relevance of the Directive for the creation of a truly European cross-border market and we recognise that banks across the EU implemented the DMFSD rigorously after its adoption. The Directive and its requirements represent today a consolidated and well-known toolbox for both consumers and providers.
We believe the majority of the requirements in the text of the legislation proved to cope well with any subsequent evolutions both in the market as well as in technology thanks to their flexible nature. We particularly praise the design of the Directive, that by being principle-based rather than rule-based, was able to adapt to evolving use of digital devices and continues ensuring a high level of consumer protection. We are in favour of a technologically neutral legislation and regulatory stability. Before considering a review of the text, we recommend however a sound cost-benefit analysis of the current text given that IT investments and gold-plating practices often result in additional obligation and costs for services providers, without the achievement of clear benefits for consumers.
For more information:
Elona Morina, Policy Adviser – Retail and Innovation, firstname.lastname@example.org
About the EBF:
The European Banking Federation is the voice of the European banking sector, uniting 32 national banking associations in Europe that together represent some 4,500 banks – large and small, wholesale and retail, local and international – employing about 2.1 million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that securely handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to creating a single market for financial services in the European Union and to supporting policies that foster economic growth.