Response to consultation on Technical Standards on standardised terminology and disclosure documents under the PAD
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Broader approach gives possibility for banks to include into FID and SoF wider scope of services and allows to describe and differiante services by various parameters like channels, minimum or maximum amount, customer age or other specific service conditions.
Also it needs to be specified/ clarified term descriptions and translations to local language:
1) Terms: Providing debit card and Providing credit card are too narrow. In LT there is main fee for maintenance of debit card/ credit card, not providing a debit/ credit card. Providing debit/ credit card is just one of other fees, it is one-time fee. We propose to use broader service name: Debit card/ Credit card. Also, we propose to clarify the definintion of Providing a debit card"- “The amount of each transaction made using the card is taken directly and in full from the customer’s account. “
“Directly” in this sentence means not a time period, but the way amount is taken from customer’s account.
In current LT version “visa iškart nurašoma” means all amount is immediately taken from account. We think that corrections should be done in order not to have misunderstanding of definition.
2) Account provider translation in LT (LT: Sąskaitos teikėjas) is not usual term/ not used in LT. Suggestion to use account service provider, service provider (LT: Paslaugų teikėjas or Sąskaitos tvarkymo paslaugų teikėjas).
3) Credit transfer translation in LT (LT: Kredito pervedimas) is not usual in term used by customers in market. Usually it is used „Pinigų pervedimas“, „Mokėjimo pervedimas“. For customers it maybe mixed with loans (should be removed word „Kredito“). Although this term is officialy used in Payments law.
4) LT: Periodinis nurodymas/ EN: Standing order – should be removed word “tam tikrą pinigų sumą” (EN and LT translations differs), because customer can transfer periodically some percentage of amount or whole amount that is in account. It is described narrower term."
1) For customer it would be simplier to understand FID and SoF documents if both documents would have the same structure. Parameters that describe service should be in the same column, for example, in column Service". Currently in FID service detalizations are under "Fees" column and in SoF - under Service" column.
2) What service fees should be added under section "Other services". In example there is added service "Providing a copy of old statement". It should be given explanations whether to FID should be added all fees, not only related with standardized services.
3) Payments section: in FID example it is provided only credit transfer to another account in the country, e.g. domestic payments in euros. It is not clear and should be given instructions whether and where to add foreign payments, payments between own accounts, direct debits, standing orders;
4) In FID example it is provided service fees only in euros. It should be given clarifications whether FID should include fees in other currencies in cases national currency is not EUR.
5) FID template is not suitable for cases when different service packages have very different services"
2) SoF does not detail whether SoF should show all fees that were taken of particular account or fees only related with standardized services. We have practise when one payment account is servicing account for other accounts."
1) It should be given instructions how to fill SoF in cases customer has more than one account and for them are applied common pricing, e.g. it is applied customer level, not account level pricing
2) It is not clear which service fees should be added under section Other services". In example there is added service "Providing a copy of old statement". It should be given explanations whether to SoF should be added all fees that were applied for particular account (for example, when payment account is servicing account for other account) or only related with standardized services.
3) It should be explained how it must be showed service package that are priced proportionally based on used time (for example, it can be terminated in the middle of the month)
4) It should be clarified how to fill SoF template is cases when in different service packages have very different services
5) Table "Detail of the fees included in the package of services" (see Annex-SoF template, p.95) should have the same structure as "Detailed statement of fees paid on the account" (see Annex-SoF template, p.95) since it is missing "Total" column.
6) Payments section: in FID example it is provided only credit transfer to another account in the country (domestic payments). It is not clear and should be given instructions whether and where to add foreign payments, payments between own accounts, direct debits, standing orders;
7) In SoF example it is provided service fees only in euros. It should be given clarifications and examples whether and how SoF should include fees in other currencies in cases national currency is not EUR."
Question 1: Do you agree with the EBA’s decision to take a broad approach to defining ‘service’? Please explain your reasoning.
Yes, we agree on broader approach just it needs to be clarified some definitons of terms and translations (see Q2).Broader approach gives possibility for banks to include into FID and SoF wider scope of services and allows to describe and differiante services by various parameters like channels, minimum or maximum amount, customer age or other specific service conditions.
Question 2: Do you consider the services that the EBA has selected for standardised terms and definitions to be suitable to achieve the aims of the Directive? Please explain your reasoning.
In general suggested terms are suitable and reflect main usual daily banking services used by customers except Arranged Overdraft (LT: Sąskaitos kreditavimas) service. In Swedbank Lithuania it is not provided such service.Also it needs to be specified/ clarified term descriptions and translations to local language:
1) Terms: Providing debit card and Providing credit card are too narrow. In LT there is main fee for maintenance of debit card/ credit card, not providing a debit/ credit card. Providing debit/ credit card is just one of other fees, it is one-time fee. We propose to use broader service name: Debit card/ Credit card. Also, we propose to clarify the definintion of Providing a debit card"- “The amount of each transaction made using the card is taken directly and in full from the customer’s account. “
“Directly” in this sentence means not a time period, but the way amount is taken from customer’s account.
In current LT version “visa iškart nurašoma” means all amount is immediately taken from account. We think that corrections should be done in order not to have misunderstanding of definition.
2) Account provider translation in LT (LT: Sąskaitos teikėjas) is not usual term/ not used in LT. Suggestion to use account service provider, service provider (LT: Paslaugų teikėjas or Sąskaitos tvarkymo paslaugų teikėjas).
3) Credit transfer translation in LT (LT: Kredito pervedimas) is not usual in term used by customers in market. Usually it is used „Pinigų pervedimas“, „Mokėjimo pervedimas“. For customers it maybe mixed with loans (should be removed word „Kredito“). Although this term is officialy used in Payments law.
4) LT: Periodinis nurodymas/ EN: Standing order – should be removed word “tam tikrą pinigų sumą” (EN and LT translations differs), because customer can transfer periodically some percentage of amount or whole amount that is in account. It is described narrower term."
Question 3: Do you consider the drafting decisions taken by the EBA for the standardised terms and definitions, and the resultant provisions in Recitals of the draft RTS, to be suitable for achieving the aims of the Directive of enhancing transparency and comparability? Please explain your reasoning.
It is suitable for achieving the aims of the Directive but it needs to be taken into account that there is a need for some more flexibilty (some more differenciation could be allowed, more space/columns allowed for additional information about specific fee components etc.)Question 4: Do you consider the terms and definitions proposed by the EBA in the Annexes to the draft RTS, and the resultant provisions in the Recitals of the draft RTS, to be adequate for achieving the aims of the Directive of enhancing transparency and comparability? If not, please provide alternative terms and definitions and their underlying rationale.
All definitions are adequate for achieving the aims of the Directive of enhancing transparency and comparability, except as we mentioned in Q2, terms: Providing debit card and Providing credit cards terms that are too narrow. In LT there is main fee for maintenance of debit card/ credit card, not providing a debit/ credit card. Providing debit/ credit card is just one of other fees, it is one-time fee. We propose to use broader service name: Debit card/ Credit cardQuestion 5: Do you consider the FID template that is being proposed in the draft ITS and its Annex to be suitable to achieve the aims of the Directive? Please explain your reasoning.
FID template is not suitable for cases when it is applied customer level pricing, e.g. In cases when customer has more than one account and for those accounts are applied common pricing logic and fees are not separated account by account.Question 6: Do you consider the common symbol in the FID template that is being proposed in the draft ITS and its Annex suitable to achieve the aims of the Directive? Please explain your reasoning.
Yes, proposed FID symbol is clear, suitable and guides/ indicates to purpose and contenet of the documentQuestion 7: Do you consider the proposed instructions for the completion of the FID template contained in Articles 2 to 11 of the draft ITS, to be suitable to achieve the aims of the Directive? Please explain your reasoning.
Generaly yes, but it should be given more examples and more instructions on how to fill FID document (see comment to Q8). Also FID document should be adjusted to cases when service provider applies customer level fees, not to account level.Question 8: Do you consider the proposed instructions for the completion of the FID template contained in Articles 2 to 11 of the draft ITS, to be clear and easy to follow? Please explain your reasoning.
Generaly yes, but it is not fully clear and should be given instructions on how it should be filled:1) For customer it would be simplier to understand FID and SoF documents if both documents would have the same structure. Parameters that describe service should be in the same column, for example, in column Service". Currently in FID service detalizations are under "Fees" column and in SoF - under Service" column.
2) What service fees should be added under section "Other services". In example there is added service "Providing a copy of old statement". It should be given explanations whether to FID should be added all fees, not only related with standardized services.
3) Payments section: in FID example it is provided only credit transfer to another account in the country, e.g. domestic payments in euros. It is not clear and should be given instructions whether and where to add foreign payments, payments between own accounts, direct debits, standing orders;
4) In FID example it is provided service fees only in euros. It should be given clarifications whether FID should include fees in other currencies in cases national currency is not EUR.
5) FID template is not suitable for cases when different service packages have very different services"
Question 9: Do you consider the SoF template that is being proposed in draft ITS and its Annex to be suitable to achieve the aims of the Directive? Please explain your reasoning.
SoF does not fully satisfy Directive aims, since: 1) FID and SoF structure differs. For customer it would be simplier to understand FID and SoF documents if both documents would have the same structure. Paratemers that describe service should be in the same column, for example, in column Service". Currently in FID service detalizations are provided under "Fees" column and in SoF - under Service" column.2) SoF does not detail whether SoF should show all fees that were taken of particular account or fees only related with standardized services. We have practise when one payment account is servicing account for other accounts."
Question 10: Do you consider the common symbol that is being proposed in the draft ITS and its Annex to be suitable to achieve the aims of the Directive? Please explain your reasoning.
Yes, proposed SoF symbol is suitable, clear and guides/ indicates about the purpose and content of the documentQuestion 11: Do you consider the proposed instructions for payment services providers on how to complete the SoF template contained in Articles 2 to 16 of the draft ITS, to be suitable to achieve the aims of the Directive? Please explain your reasoning.
Generally yes, but it should be clarified on how to complete SoF (see comments for Q12)Question 12: Do you consider the proposed instructions for payment service providers on how to complete the SoF template, contained in Articles 2 to 16 of the draft ITS, to be clear and easy to follow? Please explain your reasoning.
It is not fully clear how to complete SoF and it should be given explanations and examples:1) It should be given instructions how to fill SoF in cases customer has more than one account and for them are applied common pricing, e.g. it is applied customer level, not account level pricing
2) It is not clear which service fees should be added under section Other services". In example there is added service "Providing a copy of old statement". It should be given explanations whether to SoF should be added all fees that were applied for particular account (for example, when payment account is servicing account for other account) or only related with standardized services.
3) It should be explained how it must be showed service package that are priced proportionally based on used time (for example, it can be terminated in the middle of the month)
4) It should be clarified how to fill SoF template is cases when in different service packages have very different services
5) Table "Detail of the fees included in the package of services" (see Annex-SoF template, p.95) should have the same structure as "Detailed statement of fees paid on the account" (see Annex-SoF template, p.95) since it is missing "Total" column.
6) Payments section: in FID example it is provided only credit transfer to another account in the country (domestic payments). It is not clear and should be given instructions whether and where to add foreign payments, payments between own accounts, direct debits, standing orders;
7) In SoF example it is provided service fees only in euros. It should be given clarifications and examples whether and how SoF should include fees in other currencies in cases national currency is not EUR."