Response to consultation on Guidelines on product oversight and governance arrangements for retail banking products
Question 1. Do you have any comments on the targeted amendments and consequential changes made to Chapter 2 of the POG Guidelines on ‘subject matter, scope and definitions’?
We welcome the amendments made to the text of the Guidelines, as we believe they bring order to the text and mean that continuous updates are no longer necessary.
Question 2. Do you have any comments on the targeted amendments made to Guidelines 2, 3, 7, 8 and 12?
The addition of paragraph 8.3 to guideline 8 and the inclusion of guideline 12.1a are, in our opinion, correct and in line with what is already provided for non-banking products. The aim is to ensure greater transparency in the banking ESG products’ sector.
We suggest deleting, where applicable, the phrase “where applicable”, as this option could result in products with ESG characteristics being excluded from the required checks, leading to potential greenwashing. We believe that uniform checks should be required for all producers/distributors, rewarding those who stand out for their particular focus on sustainability.
Appropriate ways need to be identified to bring added value to the end customer – particularly the younger segments of the population – through these products. It would be useful to incentivise ESG products, especially “green” mortgages, through the EBA's provision of best practices that are taken up as positive examples to follow.
Question 3. Do you have any comments on the consequential changes made to chapter 6 of the POG Guidelines on ‘third-party arrangement’?
We believe that the new wording of guideline 6 on arrangements with third parties may cause uncertainty about the responsibility of the senior management of the entity outsourcing services to service providers with regard to the risks associated with those services. We therefore propose the following rewording:
*see document attached*