We agree with the proposed Guidelines, which are already common practice at DB. We have one further comment:
Provision of information and assistance to the customer / consumer engagement policy (para 3.1):
In the process leading to the mortgage agreement, we follow a step-by-step process with customers, discussing the amount of finance needed, how to structure the credit, if and how state help schemes can be tapped and how to secure the repayments. On our website and in via online banking, we offer budget / liquidity planners, checklists and tutorials on how to invest into property. Customers can also receive personal, individual advice in our branches or via telephone banking. If a customer gets into payment difficulties, he / she is immediately supplied with comprehensive and clear written information. We therefore believe that our customers are receiving adequate information at all times.
We believe that the Draft Guidelines are complete and have no additional suggestions.