In our feedback on the proposed review of the Consumer Credit Directive, ACCIS welcomes the Commission’s proposal to review the Consumer Credit Directive (CCD). We think that the revised rules increase the level of consumer protection, facilitate access to consumer credit across the EU and address the key, specific challenges brought on by the COVID-19 crisis.
In particular, we welcome:
- The improvements in consumer protection that will come from extending the scope of the CCD.
- The clarification that the assessment of creditworthiness should be “thorough” and be based on “information on the consumer’s income and expenses and other financial and economic circumstances” (Article 18(2)). Concerning the information that should be used to perform a creditworthiness assessment, we also welcome the alignment of the CCD with the text in the Mortgage Credit Directive (MCD) and the reference that Recital 47 makes to the European Banking Authority Guidelines on loan origination and monitoring (EBA/GL/2020/06).
- The recommendation for creditors to consult credit databases to assess the credit status of a consumer in Recital 49.
At the same time, we believe that there is still some room for improvement concerning the performance of creditworthiness assessments and the provisions concerning access to, and content of credit databases.