From the perspective of the German Banking Industry Committee, which represents the interests of more than 2,000 German banks, there is currently no need for any cross-border comparison between fees for current accounts because, as a rule, consumers open their current account at a provider in the Member State that is their primary place of residence. A price comparison will only add value for consumers if the underlying services are tailored to the current account markets in the Member States concerned. In turn, this can only be achieved if the national competent authorities are able to consider the specificities of the relevant markets when identifying the most representative services.
In light of this, we welcome the Guidelines proposed by the EBA because they will give the national competent authorities broad discretion when identifying the most representative services.
For the reasons mentioned above, no additional requirements should be imposed on the national competent authorities.
In our view, the EBA should apply Option A2 to the Guidelines. If national competent authorities consider that additional criteria are important for ensuring that the new fee presentation formats reflect established practice, they should be authorised to apply them. As explained above, the new fee presentation formats will only add value for consumers if the national competent authorities can apply all criteria that are relevant to established practice when identifying the most representative services.
Like the EBA, we regard Option B2 as the more appropriate option on which the Guidelines should be based. It is true that collecting and requesting data regularly from banks and payment service providers under Option B1 could be a costly and resource-intensive process for those firms. However, under Option B2, the national competent authorities should not be entirely free in their decision about which data and information to use. For example, the market participants affected could be consulted regarding the content and scope of the data to be collected.
In our view, the EBA should base the Guidelines on Option C1. The EBA rightly assumes that the common template proposed in Option C2 would contribute to a higher degree of standardisation. However, it should be considered that the services to be identified by the Member States are products that providers design so as to distinguish themselves from their competitors and thereby compete for customers. There are concerns that such a standardised template could impair product diversity in the individual sub-markets and they should therefore not be used.