European Association of Co-operative Banks

The national exercise of drafting provisional lists of most representative payment services will ultimately lead to the provision of a standardised fee information document (“FID”) using (European) harmonised terminology, which is to enable consumers to compare different payment account offerings.
Such price comparison tool can indeed be relevant if consumers can also apply this tool to their national markets; familiarity with language and a certain set of payment services will remain an important factor on the basis of which consumers take their decision when it comes to switching/choosing a certain payment account offering.

It is thus important that national specificities are reflected in the final national list with most representative payment services.

A.
For this reason, the EACB would argue for Option A2 (“considering criteria in addition to those mentioned in Article 3(2) of the Directive for the establishment of the list of most representative payment services” ) instead of the proposed Option A1 (“considering primarily the criteria mentioned in Article 3(2) of the Directive for the establishment of the list of most representative services, and only exceptionally any other relevant criteria”), as it would give competent authorities more discretion in their decision making.
Going for the “maximum harmonisation” option (A1) entails the risk that certain services relevant to a particular market (e.g. cheques, e-invoicing), will be excluded from the final national list that will form the basis for the FID.

B.
The EACB agrees with the EBA that Option B2 - allowing competent authorities to base their decision either on data available from existing, credible sources or from new data collection exercise- is the preferred option when taking into account the costs/benefits of such exercise. In the case of new data collection exercises, it is encouraged that market participants are consulted on the content and scope of the data to be collected.

C.
The EACB is in favour of Option C1. Where the EBA rightly assumes that the common template proposed in Option C2 would contribute to a higher degree of standardisation, the EACB would like to argue that such standardisation process should not have the negative and unintended consequence of an impoverishment/ innovation stop of payment services offered to the consumer.
Indeed, providers may design products so as to distinguish themselves from their competitors, thereby competing for consumers.
There are concerns that, precisely because the services would be limited to the pre-determined categories and terminology, product diversity in the individual sub-markets could be impaired.
Else Boekestein
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