Dokumente

Proposal for a New Consumer Credit Directive

11.09.2003 - vzbv and Institute for Financial Services (iff)

Proposal for a Directive of the European Parliament and of the Council on the harmonisation of the laws, regulations and administrative provisions of the Member States concerning credit for consumers

Expertise and Alternatives developed for Federation of German Consumer Organisations (vzbv) by Prof. Dr. Udo Reifner, IFF (Institute for Financial Services (iff))

You can download the document (90 pages, 502 KB) in the document download area.

Overview

This report was commissioned by the the Federation of German Consumer Organisations (vzbv). It provides a general critique of consumer-friendly elements in the proposed new EU Consumer Credit Directive and identifies elements of its recommendations which are more problematic, as well as discussing the issues which lie at the root of this critique, namely the "Total Harmonisation” approach of the Proposal and the incomplete clarification of the Interest Rate Regulation. Part 3 sets out an annotated amended draft Consumer Credit Directive to take into account the objectives of consumer protection and the prevention of overindebtedness.

Recommendations
The present new consumer credit Directive as proposed has positive and negative aspects which do not compensate for each other. If the disadvantages were eliminated, the proposal could facilitate a significant step towards a sane and responsible consumer credit market. This report identifies these elements and provides a number of new proposals which, from a consumer perspective, could significantly improve its scope, effectiveness and adequacy.

The recommendations are transposed into an alternative Draft of the Consumer Credit Proposal which is annexed to this report.