In our response to the public consultation on loan origination and monitoring organised by the European Banking Authority (EBA), ACCIS recalls that creditworthiness assessments that use more comprehensive data are more accurate in predicting credit risk and affordability. Thus, ACCIS fully supports that credit decisions are taken when creditors have a “sufficiently comprehensive view” of the borrower’s financial position (paragraph 85).
Our main comments relate to paragraph 88, where ACCIS suggests some adjustments. We encourage the EBA to better differentiate between sources of data and sources for data verification, with credit referencing agencies being instrumental for both activities. Along with others such as the World Bank and the European Commission, we also encourage the EBA to recognise the importance of external databases in creditworthiness assessments.