Response to consultation on Guidelines aimed at standardisation of fee terminology for payment accounts in the EU
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Like the EBA, we regard Option B2 as the more appropriate option on which the Guidelines should be based. It is true that collecting and requesting data regularly from banks and payment service providers under Option B1 could be a costly and resource-intensive process for those firms. However, under Option B2, the national competent authorities should not be entirely free in their decision about which data and information to use. For example, the market participants affected could be consulted regarding the content and scope of the data to be collected.
In our view, the EBA should base the Guidelines on Option C1. The EBA rightly assumes that the common template proposed in Option C2 would contribute to a higher degree of standardisation. However, it should be considered that the services to be identified by the Member States are products that providers design so as to distinguish themselves from their competitors and thereby compete for customers. There are concerns that such a standardised template could impair product diversity in the individual sub-markets and they should therefore not be used.
Question 2: Are there any additional requirements that you would suggest adding?
For the reasons mentioned above, no additional requirements should be imposed on the national competent authorities.Question 3: Do you agree with the analysis of the cost and benefit impact of the guidelines?
In our view, the EBA should apply Option A2 to the Guidelines. If national competent authorities consider that additional criteria are important for ensuring that the new fee presentation formats reflect established practice, they should be authorised to apply them. As explained above, the new fee presentation formats will only add value for consumers if the national competent authorities can apply all criteria that are relevant to established practice when identifying the most representative services.Like the EBA, we regard Option B2 as the more appropriate option on which the Guidelines should be based. It is true that collecting and requesting data regularly from banks and payment service providers under Option B1 could be a costly and resource-intensive process for those firms. However, under Option B2, the national competent authorities should not be entirely free in their decision about which data and information to use. For example, the market participants affected could be consulted regarding the content and scope of the data to be collected.
In our view, the EBA should base the Guidelines on Option C1. The EBA rightly assumes that the common template proposed in Option C2 would contribute to a higher degree of standardisation. However, it should be considered that the services to be identified by the Member States are products that providers design so as to distinguish themselves from their competitors and thereby compete for customers. There are concerns that such a standardised template could impair product diversity in the individual sub-markets and they should therefore not be used.