The EPC Publishes its Response to the European Commission’s Green Pape...

The EPC Publishes its Response to the European Commission’s Green Paper on Retail Financial Services

23 March 16

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The European Payments Council ( ) today publishes its response to the European Commission’s green paper on retail financial services. In December 2015, as part of its strategy to boost competition, transparency and choice in retail financial services, the European Commission launched a public consultation. The Commission’s main goal is to make it easier for companies wanting to offer retail financial products in other Member States. This, in turn, will give consumers access to a far greater range of services.

The European Payments Council ( ) has welcomed the opportunity to respond to the public consultation.

The ’s general comments:

  • The supports the European Commission’s overall objective of “creating a true European market for retail financial services”. However, the green paper does not appear to recognise the achievements of the payments industry to date in harmonising payments in Europe (development of and migration to schemes, card standardisation).  
  • The would be interested to know how the European Commission defines and measures the quality of products when calling for “better products”. The ’s view is that such an assessment should be left to the market and in particular to end-users and free competition.
  • The would also be interested to see the analysis and understand the reasons behind the statement that air travel is an example of “a well-developed Single Market”. For example, in Section 2.1, the question arises about whether the concentration of service providers is actually not lower in the retail financial sector in comparison with the air travel sector taken as an example of a “well-developed Single Market”.
  • The has concerns about the reference to the “portability of bank account numbers” mentioned in Section 2.1. The is unaware of the existence of any feasibility, impact or cost and benefit analysis supporting such an option.

Overall, the paper seems to rely largely on anecdotal evidence. The expects this to be complemented with analysis and rigorous quantitative research as the basis for public policy or any legislative initiative.

The has also provided responses to some of the specific questions posed in the European Commission’s paper.  

The looks forward to the European Commission’s conclusions based on the responses to the consultation and on the outcome of the 2 March 2016 public hearing on the green paper.

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