Directorate General of the Treasury of the French Ministry for Finances and Public Account
As mentioned in the background and rationale of the EBA paper, the interpretation by competent authorities of both alternative criteria used to establish the national provisional list of the most representative services (criteria of services most commonly used by consumers in relation to their payment account, and criteria of services that generate the highest costs for consumers), should be flexible, in order to reflect the MS national market.
Flexibility should also be maintained as regard the supportive data and evidence that competent authority should provide in order to justify their decision. In such context, statistical data are indeed a reliable piece of evidence. However, it is not the only one. Other sources and processes should also be taken into account when establishing this list. For example, a broad consultation of stakeholders representative of both consumers and PSPs can also help in determining the adequate services to be listed. France has already worked on standardization of most of words used in banking fees (95% of current operations have terms which are harmonized) and a list of the most representative services linked to a payment account and subject to a fee at national level was established in 2010 in order to facilitate, for the consumers, the lisibility, the understanding and the comparison of banking fees. Different actors were involved in the establishment of this list managed by a consultation committee which gathers consumers, banks and public authorities. This type of process should be acknowledged as a way to determine with the necessary objectivity the list of services and should be accepted as supporting data and evidence to justify the choice of inclusion/exclusion of services.
Dominique Agniau-Canel : Deputy head of “Banking services and means of payment”