EU consultation paper on promoting cross border competition in banking and insurance - closes 16 Mar

Brendan Burgess

Founder
Messages
52,204
http://europa.eu/rapid/press-release_IP-15-6286_en.htm?locale=en

Giving Europeans more choice in financial services: the European Commission consults
Brussels, 10 December 2015

Consumer financial services such as bank accounts, mortgages and insurance are an essential part of daily life. But many people find it hard to access these services across borders; and many businesses find it hard to provide them.

For the next three months, the European Commission will be consulting on how to create a stronger European market for consumer financial services. The aim is to find a system that works for consumers across the EU, giving them access to the best financial service deals, with more suitable products, a bigger choice and more competitive prices.

The European Commission is today launching a consultation to look at financial services from the perspective of European consumers in order to boost competition, transparency and choice. The consultation looks at the retail market across Europe for products such as insurance, mortgages, loans, payments and bank accounts. It will seek to identify the unjustified barriers that consumers face when they want to use such services across borders, and find answers on how best to remove these barriers.

The Commission's goal is to make it easier for those companies that so wish to offer financial products at the retail level in other EU Member States, which would give consumers access to a far greater range of products. People should also be able to take those products with them if they move to another EU country to work, study or retire.

Jonathan Hill, European Commissioner for Financial Stability, Financial Services and Capital Markets Union, said: "Financial products like bank accounts, mortgages and insurance are hugely important in the daily lives of millions of Europeans. But people often miss out on the best deals, or pay over the odds because of the barriers that exist in the European market. In this, as in other areas, the single market can bring benefits by helping consumers enjoy more competition and pick from the best that Europe has to offer. I hope that citizens and businesses will respond to this consultation to share their experiences and suggest how we can best tackle these barriers."

Some illustrations of barriers or problems people in the EU may encounter include:

  • You want to open a bank account or buy a savings product but it is not available to residents of your Member State;
  • you want to move to another Member State to work or retire, but find you cannot keep your existing current account or debit card, or that your health insurance premiums would go up dramatically (i.e. your financial services are not "portable");
  • you transfer money into another currency, or use a credit card while on holiday, and face high fees or poor exchange rates;
  • you find extra or hidden costs such as insurance when renting a car, which you were not aware of when booking;
  • you want to get your mortgage from a provider in another country, but worry you will not be protected if something went wrong;
  • you already have a bank account, credit card, loan or insurance policy but it is expensive or awkward for you to "switch" providers, even if you could get a better return or lower price (one Eurobarometer survey showed that 85% of respondents with a personal loan or credit card had not switched or tried to switch providers).
Sometimes there will be valid and objective reasons why services vary, are priced differently or are not available in other Member States —for instance because of different costs or risks. But those barriers can also pose practical difficulties, including for the 13.6 million EU citizens who live in a member state other than their own.

In practice, this means that many Europeans may not be enjoying the widest range of products or they are paying over the odds. It also means financial service providers find it hard to expand, and offer their services to a bigger market – given the extra cost or complexity involved in operating across borders. Just 3% of consumers have purchased a banking product such as a credit card, current account or a mortgage from other EU member state; within the euro area, cross-border loans amount for less than 1% of the total. Not all consumers and businesses want to be active on a cross-border basis. The purpose of the consultation is to make sure that those who do want to purchase cross-border financial services are able to do so, subject to an adequate level of consumer protection and security standards.

The consultation also considers the impact of digital technology on the market. Digital services such as online banking, peer-to-peer lending or price comparison websites present many opportunities for the providers and consumers, but can also pose a regulatory and consumer-protection challenge.

In parallel to the consultation, the Commission is seeking feedback via social media. People can post a short video setting out the problems have faced accessing financial services across Europe, with the hashtag #MyMoneyEU. More details: http://ec.europa.eu/finance/finservices-retail/mymoneyeu/index_en.htm

Background and next steps

Originally announced in the Capital Markets Union Action Plan [IP/15/5731], this consultation follows a number of other initiatives in this area, some of which are still in the process of being implemented across the EU.

These include:

  • The Payment Accounts Directive, which improves the transparency of bank account fees and make it easier to switch accounts from one bank to another, among other things.
  • The Mortgage Credit Directive, to make responsible mortgage lending the norm across Europe.
  • The recently-agreed Insurance Distribution Directive, which ensures that consumers benefit from greater choice and information when they buy insurance products.
  • The Commission’s [broken link removed] to aims to reduce barriers and prevent discrimination within the single market.
  • The Commission's Digital Single Market Strategy, to boost access to digital products and services, and end unjustified geoblocking.
The Commission hopes that today's consultation will stimulate debate across the EU and garner a broad range of views and evidence on how to best achieve a well-functioning and competitive market in financial services at the retail level. Citizens, stakeholders such as consumer groups and businesses and other interested parties have until 18 March 2016 to respond.

After analysing responses to the consultation, the Commission will look to reduce the barriers which stop consumers from accessing financial products and services across borders.

A conference in early 2016 will examine the evidence offered by the consultation and discuss priority areas. An Action Plan on Retail Financial Services will follow later next year.

For more information:

See also: MEMO/15/6287

Details on the social media campaign and the Retail Finance Consultation

Capital Markets Union Action Plan
 
We should make submissions to highlight how Irish banks are charging twice the interest rate charged in the rest of the Eurozone.

Brendan
 
The green paper is an excellent well researched document.

Some great ideas in the works by the EU:
  • Instant SEPA transfers in seconds from bank-to-bank being planned.
  • New legislation pending preventing discrimination based on residence in the EU to make the current non-discrimination rules stronger.
  • Cross border KYC / AML changes allowing remote e-approvals in being planned.
  • Significant discussion on the effects of FinTech on the financial services industry.
How do you make mortgages and insurance products pan European?
  • Take inspiration from the UCITS passport rules for funds.
  • Take inspiration from the new EIOPA standardised pan-European Personal Pension product rules which are in the works.
  • Standardised pan-European Personal Pension product can be adopted for a pan-European life assurance product.
  • New passporting regimes.
  • Convergence in supervisory standards to limit issues with host state regulators.
Responses to the consultation are via an online questionnaire here. I will be making a submission.
 
I am reading through this paper with a view to making a submission. (It's a well written paper and not as bad as most EU stuff.)

The biggest problem is customer inertia, especially when it comes to financial products.

The biggest expenditure is mortgage interest. Yet, people continue to pay Bank of Ireland 4.5% and Danske 4.95% when they could switch to Ulster Bank or AIB and cut their rate by over 25%. But very few do.

So if we can't get them to switch within Irish banks, what would be the chances of getting them to switch to a German mortgage lender?

Of course, if German rates of 3% fixed for 20 years were to become available,then Irish people would switch.
Likewise, if someone introduced a tracker rate mortgage ECB + 2.5%, then people would switch.
 
I have extracted the bits which I considered relevant to mortgages on the attached.
 

Attachments

  • Extracts.docx
    64.5 KB · Views: 271
I am thinking along the following lines...

As the biggest expenditure is mortgages, try to get that right. Take specific steps to promote cross-border mortgages. Trying to solve health insurance, life insurance, payments and everything else in the one go won't work. Focus on one and try to solve it.

For a German lender to provide mortgages in Ireland, they would have to have a detailed knowledge of the Consumer Credit Act, the Consumer Protection Code, CCMA, Data Protection Act and a house of other pieces of legislation. They would need access to the ICB reports. In making credit decisions, they would need to know a fair bit about the Irish market. Valuation of property would be difficult from Frankfurt. You would suspect that the local valuer was probably in league with the borrower. They would need to know Irish conveyancing law and practice.

So my solution is a Euro mortgage. A plain vanilla low admin product where borrower and lender fully understand all aspects of the product.
  • Variable mortgage rate
  • Free to repay early without penalty
  • Fixed rate option with clearly spelt out early repayment penalties
  • An administrative repossession procedure. For example, the lender would not need to go to court to get an order for possession. If a certain event occurs e.g. the equivalent of 3 months payments in arrears, they can appoint a receiver to sell the property.
  • A European Ombudsman service for disputes on this product
  • A non-recourse product maybe (although this would imply very low Loan to Values)
If a country wanted to participate in this product, then they would have to adapt their rules to facilitate the product. For example, a whole raft of Irish legislation would have to be changed, and maybe even the constitution would need to be changed, to allow the appointment of a receiver to the family home.
 
Switching would be much, much easier with an IBAN portability layer. Why can't I keep my IBAN when I move to a different SEPA-reachable bank, like a mobile phone number? Let banks take care of the internal mapping - when I change banks, I should keep my IBAN and my direct debits/credits should be re-routed by the banks.
 
Good Irish Times article by Fiona Reddan here

Could Irish people save money by looking overseas for loans or deposit accounts?

"Cheaper mortgages

Ireland has some of the highest mortgage rates in Europe, with all but lucky tracker mortgage holders paying over the odds to service their home loan debts. The average variable mortgage rate in Ireland is 3.4 per cent and, despite efforts from the Government to “encourage” the banks to lower their rates, Irish variable rates are still considerably higher than the euro zone average.
In France for example, the average rate is 2.73 per cent, 2.03 per cent in Luxembourg, and 2.39 per cent in Austria. This is not the only EU country with above-average rates – house buyers in Cyprus for example are paying an average rate of 4.43 per cent – but it means that Irish consumers are not benefiting from historically low interest rates in the way that many of their European peers are.

For now, though, there may be a possibility for Irish homeowners with foreign property to seek out a cheaper loan elsewhere. Consider the example of a couple with a mortgage-free investment apartment in Germany. They might find that it is possible to re-mortgage their Irish mortgage with a cheaper loan with a German lender by using the apartment as collateral. The savings, as set out above, could make the bureaucracy such a move would entail, worthwhile."

I will contact Fiona about repeating the Central Bank's misleading the public about average mortgage rates being 3.4%
http://www.irishtimes.com/business/...rseas-for-loans-or-deposit-accounts-1.2509802
 
Whist I realise that the biggest benefits will come from cross border mortgages, I think we need to start with 'smaller' cross border financial services and build up from there.

In recent months we have seen cross border FX offerings, current account offerings and soon deposit offerings. All steps in the right direction. The next obvious step is for cross border life assurance products.

Raisin might provide a template for other financial services to be offered cross border basis with an online marketplace bringing all the offerings together.
 
Hi Ciarán

I am happy enough with my current account from AIB. I pay around €80 a year in charges. I get access to a branch on the rare occasions I use it. There online service is fine. I have an overdraft facility - I think I pay another €25 admin fee for that, but I am not sure.

I have a sterling account in Newry with Ulster Bank because I do a few transactions in sterling. That was easy enough to open.

I don't bother with deposit accounts. Most of my money is tied up in shares and if I have an unplanned need for cash I use my overdraft or sell shares.

So I am at a bit of a loss as to why I would bother opening a current account or deposit account anywhere else. Of course, I could probably switch banks in Ireland and get a cheaper or free current account.

If I had a €200,000 variable rate mortgage with 80% Loan to Value, and was paying 3.55%, having switched to AIB I would be raging. I could be paying around 2% in other Eurozone countries which would be a saving of €3,000 a year. I could also probably get a long-term fixed rate around 2% cheaper than I could get in Ireland. This means that it would actually be attractive to fix my mortgage.

My concern is that if the EU devotes its resources to helping people open bank accounts in other countries, they may sit back satisfied that they have doubled the level of cross-border accounts from 3% to 6%. I would much prefer them to focus on the much more significant, although much more difficult, prize of transborder mortgages.

Brendan
 
Hi Brendan,

So I am at a bit of a loss as to why I would bother opening a current account or deposit account anywhere else.

Better rates for deposit accounts is one reason. The rates that Raisin say they will offer will be a lot higher that what Irish banks offer. Better FX rates (Revoult) is another reason. By making service offering pan European it opens the door to more options, more choice and more competition.

Granted, mortgages are the holy grail and the pan European offering that will derive the most benefit. I hope pan European mortgages happen soon but you don't build Rome in a day and starting with smaller financial products might lead to a gradual pan European service creep towards eventually offering all financial products on a pan European basis.
 
Last edited:
Back
Top