There is additional requirement I suggest to add.
There is certain percentage of customers in payment difficulties, for which no efficient help can be provided and the foreclosure is the only viable option. These are, for instance, customers avoiding any contact with the creditor, customers spending lifetime prison, customers highly unlikely to repay their other debts in their hole life.
Nevertheless, the Requirements regarding arrears and foreclosure under Article 28 MCD in their paragraph 3.3. (page 11) state: “The creditor should provide support … to consumers in payment difficulties …” despite the fact that in certain cases such support cannot be provided.
My suggesting is to amend this requirement either to request creditors to offer support (not to provide it) or, to request creditors to provide adequate support (which might allow for no support in cases described above).