Consumer credits

The Mouvement des entreprises de France is the first network of entrepreneurs in France representing more than 173 000 member companies comprising all sectors of activity and 95 % of which are SMEs/ETI. The mission of the French Business Movement is to promote and represent the interests of French companies vis-à-vis the French and European public authorities and to develop entrepreneurship.

Filed in French · English published by the European Commission

The Dutch Banking Association (DBA) would like to make some additional remarks on the Consumer Credit Directive (CDD) proposal. These remarks come in addition to the reaction of the European Banking Federation (EBF).

The Federation of European Publishers welcomes the opportunity to provide its views to the European Commission regarding the proposal for a review of the Directive on consumer credits. The review aims, among other elements, to remove the exemption from the scope of the current rules with regard to: Consumer credit agreements below the amount of EUR 200; Credit agreements where the credit is granted free of interest…

ASSILEA, Associazione Italiana Leasing, is the trade association of banks and financial intermediaries operating in Italy in the leasing sector. Welcoming the opportunity for discussion provided by the Authority in the above consultation, ASSILEA has attached some of the specific comments resulting from the comparison with the operators concerned. Thank you for this opportunity. yours sincerely, [name removed]

Filed in Italian · English published by the European Commission

REPLY OF THE SPANISH ASSOCIATION OF MICRO-LOANS (AEMIP) TO THE NEW PROPOSAL FOR A DIRECTIVE ON CONSUMER CREDIT. Below we refer to the contents of the full document contained in the attached PDF “Aemip Consumer Credit Directive Review”. (1) ON THE SPANISH ASSOCIATION OF MICRO-LOANS. (2) COMMENTS ON THE PROPOSAL FOR A DIRECTIVE ON CONSUMER CREDIT. 2.1.

Filed in Spanish · English published by the European Commission

Consumer credit in France and our other European markets is balanced, between supervised lenders engaged in responsible lending and, on the other hand, consumers whose information, protection, prevention of over-indebtedness are effective. Still, there is room for improvement, e.g. in the inclusion of certain new types of credits or the supervision of all types of creditors including crowdfunding.

We are pleased to comment on the Proposal for a Revised CCD and to provide the following insights, which take account of the changing business environment and draw on our experience regarding implementation of the MCD.

“The Spanish Finance Houses Association (ASNEF), the voice of the Spanish specialized consumer credit providers welcomes the opportunity to contribute with it´s comments to the European Commission’s proposal for a Consumer Credit Directive (CCD). Please find enclosed our comments on the Directive proposal.

In order to pursue the stated — broadly shared — objectives, the EU Commission is proposing measures that strengthen more formal than substantive protection for lenders. At the same time, due attention is not paid to the growing need to simplify the content of pre-contractual and contractual documentation and the procedures to be put in place to access credit, not least in view of the increasing use of digital…

Filed in Italian · English published by the European Commission

The proposal brings a series of positive advances related to the protection of consumers in consumer credit markets. In particular, BEUC welcomes the fact that several important safeguards advocated for in its position paper on the revision of the Consumer Credit Directive (CCD) are now reflected in the revised proposal (see…

The European Commission recently published a new proposal for a Directive on consumer credits repealing and replacing the existing Consumer Credit Directive (2008/48/EC). With the proposal, the Commission aims to increase consumer protection for consumer credits. The Commission recognises that consumer credits help consumers finance all sorts of projects and goods.

The European Commission recently published a new proposal for a Directive on consumer credits repealing and replacing the existing Consumer Credit Directive (2008/48/EC). With the proposal, the Commission aims to increase consumer protection for consumer credits. The Commission recognises that consumer credits help consumers finance all sorts of projects and goods.

Eurofinas, the voice of European specialised consumer credit providers, welcomes the opportunity to respond to the European Commission’s consultation on its proposal for an updated European consumer credit framework.

PBA positively assesses the objectives to be achieved by the new EU consumer credit legislation aiming at achieving a smoothly functioning internal market and adapting the legislation to the changing technological tools used to provide credit.

The EBF and its members have extensively contributed to the consultations prior the CCD review. Regrettably, proposals for improvement on technological developments or administrative burden have not been considered. This is a missed opportunity to further integrate and modernise credit markets in Europe. A successful and efficient lending framework should consider both the needs of clients and providers.

The German Banking Industry Committee (GBIC) takes this opportunity to express its opinion on the draft proposal of the Consumer Credit Directive (2021/0171) published on 30 June 2021. GBIC shares the goal of the Draft Directive of offering consumers a high level of consumer protection (recital no. 12).

The Krajowa kasa Krajowa – an organisation which brings together all cooperatives operating in Poland – Kasa Ozednościowo Kredytowe – encloses the position on the draft Directive of the European Parliament on consumer credit (2021/0171 (COD)). We trust that the comments and proposals will be taken into account in the further legislative work on this draft.

Filed in Polish · English published by the European Commission

The Krajowa kasa Krajowa – an organisation which brings together all cooperatives operating in Poland – Kasa Ozednościowo Kredytowe – encloses the position on the draft Directive of the European Parliament on consumer credit (2021/0171 (COD)). We trust that the comments and proposals will be taken into account in the further legislative work on this draft.

Filed in Polish · English published by the European Commission

The Association of Credit Card Issuers Europe (ACCIE) represents the specialized European credit card issuing industry. ACCIE is happy to submit feedback on the Commission’s proposal on the Revised Consumer Credit Directive (CCD), and wants to draw attention to the following key points regarding the creditworthiness assessment (CWA) and caps on the cost of credit: - The CWA should be proportionate to the level of…

For more than 17 years, ALB Romania has supported and promoted the non-banking financial services provided by its members, recommending best practices and the highest standards of professional behavior and contributing to the development of the business community in the field of non-banking financial services.

In addition to the opinion and position of the Polish Association of Loan Institutions, I am sending the Legal and Economic Report: Analysis of the Consumer Credit Directive revision in the context of Lendtech 'activities and regulatory issues pertaining to credit-granting institutions and I encourage one to read its content.

Over the years, the Polish Association of Credit Institutions (PZIP) collects information on the consumer credit market by sharing its knowledge and data on the consumer credit market in the course of numerous legislative processes in Poland as well as at European level – an organisation entered in the Transparency Register under number 685873935918-08.

Filed in Polish · English published by the European Commission

Polish Association of Loan Institutions (PZIP) has been gathering over the years information about the consumer loan market, sharing its knowledge and data on the consumer loan market in the course of numerous legislative processes in Poland, as well as at the European level - being an organization entered in the Transparency Register under the number 685873935918-08.

ACCIS represents the largest group of credit reference agencies in the world. ACCIS brings together 40 members across 28 European countries and 11 associate and affiliate members from all other continents. ACCIS broadly welcomes the Commission’s proposal to review the Consumer Credit Directive (CCD).

Alternative Financial Services Association of Latvia welcomes EC initiative to review the consumer crediting regulatory framework and hereby is delivering its opinion on the draft Directive of the European Parliament and of the Council on consumer credits 2021/0171.

Filed in Latvian · English published by the European Commission

The Federation of German Consumer Organisations (vzbv) supports the European Commission’s aim to achieve significant improvements in consumer protection in the European consumer credit market. However, vzbv sees a need for additions and corrections in some of the proposed rules: WIDER VIEW OF CREDIT PRODUCTS AND CREDIT SERVICES The proposed extension of the scope is likely to significantly improve consumer…

The proposal for a revision of the CCD does not take into account the significant digital evolution in recent years, the increasing use of digital devices and requests for simplification on advertisements, the rules of which would remain largely unchanged.

Filed in Italian · English published by the European Commission

The ZAW welcomes the opportunity to comment on the European Commission's proposal for a Consumer Credit Directive, which will have a significant impact on the advertising industry, in particular due to the mandatory standard information for advertising. You will find our statement in the annex.

1.Definitions, Article 3 of the Regulation A definition of “prior requirement” and “explicit consent” should be added as these two concepts are crucial for the application of Article 17. Otherwise, Member States would have discretion to interpret those terms, thus jeopardising harmonisation. 2.

Filed in German · English published by the European Commission

American Express welcomes the opportunity to provide feedback on the European Commission’s proposed revision of the Consumer Credit Directive, and is supportive of the Commission’s efforts to establish a single market for credit with harmonised and strengthened consumer protection measures.

Please find attached the European Savings and Retail Banking Group's response to this public consultation. ESBG represents the locally focused European banking sector, helping savings and retail banks in 21 European countries strengthen their unique approach that focuses on providing service to local communities and boosting SMEs.

Anasf shares the possibility, identified in recital 43 and in Article 16 of the European Commission’s proposal for a Directive, to provide advice in the form of personalised recommendations in combination with the granting or intermediation of credit, provided that it is clear to the consumer what the advice service consists of, precisely because of the importance of this service in other areas.

APNU fully supports a review of Directive 2008/48/EC, which will ultimately lead to the associations mission: build a reliable, socially responsible lending practice focused on a long-term cooperation, which will be positively perceived by consumers as well as regulators.

Dear all, IPF is a leading international home credit and digital provider of consumer finance with a business model that dates from the 19th century. IPF provides simple, personalized loans to almost one million European citizens from Poland, Czech Republic, Hungary, Romania, Spain, Estonia, Lithuania and Latvia.

4finance Group’s response to the proposal for a new Consumer Credit Directive The EC was in part prompted to revisit the Consumer Credit Directive by the rapid pace of change in consumer lending since 2008 – the reappraisal is therefore welcome. However, in its present form the proposals risk appearing more a list of actions than a coherent plan to shape the future of consumer credit in Europe.

DECO welcomes this proposal reviewing Directive 2008/48/EC on credit agreements for consumers (CCD) to better adapt it to the evolution in the market and tackle arrears. We consider that some provisions will tend to increase the level of consumer protection, reflecting the views expressed by consumer representatives: the extension of the scope to include loans below 200 and up to 100.000 EUR; the introduction of…

As an umbrella organisation for state-recognised debt advice, we comment on those parts of the proposal for a directive which are directly related to the activity of debt advice. By its very nature, all the rules relating to consumer credit have a greater or lesser impact on the activity of debt advice, especially since any consumer credit transaction risks becoming a problematic contractual relationship.

Filed in German · English published by the European Commission

Finance Denmark supports a revision of the Consumer Credit Directive. Consumers are today seeking digital solutions where credit offers must be able to be submitted and signed digitally. If consumers want to obtain information or compare different offers, this is often done online rather than on paper. Of course, legislation should reflect these developments.

Filed in Danish · English published by the European Commission

1. This initial feedback by the General Council of the Bar of England and Wales (the Bar Council) is submitted in response to the European Commission’s Inception Impact Assessment on the Review of the Consumer Credit Directive (2008/48/EC) (the Impact Assessment) . 2. The Bar Council represents approximately 17,000 barristers in England and Wales.

ASUFIN (Asociación de Usuarios Financieros), as a Spanish consumer organization specialised on financial products, welcomes the review of the Consumer Credit Directive, as we consider that there are certain issues that should be taken in consideration for the best protection of the consumers.

Commercial radio is funded almost entirely by advertising, enabling it to remain free-to-air and free-to access to millions of listeners. It relies on its advertising business model to be present on every platform, including online, enabling it to create content and innovate. Unnecessary restrictions on advertising should be avoided.

Credit helps consumers to finance their buying of a home, their children’s education, or the purchasing of consumer goods. But if credit is misused, becomes unsustainable and causes over-indebtedness, the consequences for borrowers, lenders and the economy’s stability can be immense.

The European Cancer Patient Coalition (ECPC) represents the patients of its 450 members across 46 different countries afflicted by all types of cancer. ECPC works for a Europe where all cancer patients have access to the best health care available and the greatest conditions to improve their quality of life during and after the fight against cancer.

A. Problems: 1 Inadequate scope (emergence of new non-bank traders such as loan platforms and new forms of consumer credit such as microloans, which are less than EUR 200 not covered by the Directive). 2 Content and form of information: The requirements for providing information in advertising and at the pre-contractual stage do not reflect the increasing use of digital devices (tablets, smartphones) in credit…

Filed in Spanish · English published by the European Commission

COFACE-Families Europe represents millions of families as consumer units throughout the European Union, via its membership. It focuses on many topics related to the consumer agenda among which digitalization, financial services, energy poverty and vulnerable consumers.

The Association of Credit Card Issuers Europe (ACCIE) represents the specialised European credit card issuing industry. ACCIE is pleased to submit commentary to this consultation, and fully supports the goal of the Consumer Credit Directive (CCD) to ensure high level of consumer protection in consumer credit agreements.

The microfinance sector welcomes the review of the Consumer Credit Directive, and appreciates this early opportunity to provide input. Consumer protection is at the heart of microfinance, and we believe that such incremental improvements to European regulation will lead to better outcomes for both the industry and for citizens.

Finance Watch is generally very supportive of the document prepared by the Commission. In particular, we welcome the following points, which we consider to be very important: - The positive and important role that consumer protection plays in boosting consumer confidence in the use of credit; - The importance of a market from which dangerous products should be excluded, along with exploitative practices; - The…

The Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies (CRAs) in the world. CRAs are independent organisations that securely hold data about consumers. Lenders use the information held by CRAs to assess the creditworthiness of borrowers.

Thank You for the opportunity to give a feedback on Inception impact assessment. Consumer Rights Protection Centre of Latvia (main consumer law enforcement authority) mostly agrees with assessment and support comprehensive revision of the 2008/48/EC Directive.

Summary Inadequate scope: In the case of loan agreements of small amounts in themselves above EUR 200, there is, in principle, an extremely high amount of processing costs which is disproportionate to the yield – and this is the case for manageable risks as a whole. Therefore, the revision of the Directive should consider whether the lower limit can be significantly raised.

Filed in German · English published by the European Commission

Enclosed a fw comments based on expected we expressed already unsuccessfully to the Luxembourg legislator when the current Directive was up for implementation. The Roadmap identifies the main problem areas which we share. Our preferred action.

Filed in French · English published by the European Commission

The members of the European Association of Cooperative Banks (EACB) would like to hereby share their view on the European Commission’s inception impact assessment of the CCD review. Generally speaking, we believe that regulatory stability is of paramount importance considering the circumstances that banks are currently facing.

EESC - Consumer Credit Directive - Inception Impact Assessment Altroconsumo's comments to the public consultation of the European Commission on credit consumer directive revision. The different themes and problems that emerged in the presented document can be solved with different tools. However, considering the long transposition times of the new directives, we could immediately work on a legislative revision.