Response to consultation on Guidelines on the establishment and maintenance of national lists or registers of credit servicers

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Question 1: Do you have any comments on the information on credit servicers to be included in the lists or registers as proposed in Guideline 4.1

EBA could keep and manage a centralized register/list of all European servicers and the member states they are allowed to operate in, to facilitate those who would like to get in touch with such servicers.

The register should be organized in matrix form in order to allow the possibility to apply filters such as geographical area, type of services, etc once it has been downloaded. The servicer should be given the opportunity to make updates to their data directly on the registry by accessing a reserved area.

At last, among contact details for submitting consumer complaints, it could be proper to include “Certified electronic mail address” of the credit servicer (where applicable) in view of the introduction of certified electronic mail valid throughout the EU.

Question 2: Do you have any comments on the accessibility requirements of the lists or registers, as proposed in Guideline 4.2?

It would be useful to have the opportunity to download a report stating the date of access to the list/register and information acquired.

Question 3: Do you have any comments on the approach for updating the lists or registers, as proposed in Guideline 4.3?

Given the need for instant and trackable updating of registers by the CAs, information could also be transmitted via certified email (where applicable) in view of the introduction of certified electronic mail valid throughout the EU.

Question 4: Do you have any comments on the approach for providing an overview of competent authorities that handle complaints under the CSD in the EU, as proposed in Guideline 4.4?

It would be useful to define the minimum required information that must be contained in the complaint (i.e. name/surname of the borrower, ID number of his file, name of the financial institution which originated the loan, name of the servicer now in charge of the collection, borrowers contact details).

Name of the organization

Prelios Innovation Srl