Banks and Consumers

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BANKS AND CONSUMERS − description of the product and the services − offer of additional information or advice offered as needed − − − − − explanation of the product’s purpose description of the financial obligations arising from the contract, both current and potential (e.g. interest, commissions and other fees) description of any risks associated with a product description of the content of the accompanying legal obligations list of any costs that arise, particularly in the event that a contract is terminated early Cooling-off period Consumers should be given time to reflect on their decision prior to concluding a contract or they should be granted a corresponding right to cancel. However, a right to cancel should not mean that the bank is required to bear the risk of price fluctuations on the financial markets. No harmonisation of products Legislators should ensure flexibility in the design of financial products. Restrictions on product specifications should generally only be considered as a last resort. Appropriate information combined with the opportunity for reflection is usually an adequate “safety net” 86
BANKENVERBAND for consumers, without the need to restrict the choice of products. “Customised” advice on request, but without obligation Consumers should receive, on request, advice tailored to their personal needs. Consumers themselves – because only they can judge this properly – must ensure that all the necessary information is available to them before they assume any financial obligations. Any publicly debated general obligation for banks to provide advice would unfairly shift responsibility for customers’ decisions to banks. Simple customer complaints system Legislators should see that customers are provided with a simple and efficient means of settling any dispute with a bank. The European Commission’s declared aim of improving the “quality and coherence” of the consumer policy acquis in the EU must be welcomed. The “better regulation” approach, i.e. lean, unbureaucratic and efficient legislation, can help to ensure better competitive conditions and economic dynamism in this area as well. Not only European, but also national legislators have a role to play in the continued integration of the financial services markets. For example, when transposing EU rules into national law, they should resist the temptation to make them “tougher” or “better” – otherwise the goal of a European level playing field is in danger. What is needed instead is consolidation of the sometimes contradictory consumer protection provisions throughout the EU. BETTER REGULATION APPROACH The private commercial banks believe that all present and future regulatory proposals should be guided by the following principles so as to ensure in particular high-quality and, above all, consistent consumer policy in future. All national and European institutions should be required to follow this approach. − All regulatory measures must be clear, necessary and reasonable. − New regulations should only be introduced once a full analysis of their impact has been performed and after extensive consultation has taken place with the financial services sector and consumer organisations. − All individual measures should be monitored continuously to determine their actual effect. − For the benefit of all market participants, the various measures should be interpreted and enforced consistently by legislators. 87
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BANKS AND CONSUMERS The comprehensi
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Contents I Banks and consumers - a
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BANKS AND CONSUMERS I Banks and con
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BANKENVERBAND II What is consumer p
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BANKENVERBAND lasting business rela
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BANKENVERBAND THE ECONOMIC IMPORTAN
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BANKENVERBAND customers. Some clien
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BANKENVERBAND financial services ar
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BANKS AND CONSUMERS III Consumer po
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BANKS AND CONSUMERS CERTIFICATES Ce
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BANKS AND CONSUMERS which the recom
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BANKS AND CONSUMERS 3 Partners for
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BANKS AND CONSUMERS 4 Future develo
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BANKS AND CONSUMERS Ordinance comes
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BANKS AND CONSUMERS 2009 The Single
Page 37 and 38: BANKENVERBAND IV The private commer
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Page 49 and 50: BANKENVERBAND EUROPEAN STANDARDISED
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Page 92 and 93: BANKS AND CONSUMERS VII Annex Rules
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Page 98 and 99: © Bank-Verlag Medien GmbH 40.001 (
Page 100 and 101: 40.001 (01/12) Cost of Bank Service
Page 102 and 103: BANKS AND CONSUMERS Useful internet
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