The packages of services to be paid separately from the account maintenance fees are supposed to be presented in their own table at the beginning of the fee information document. That is not the optimum solution from the standpoint of consumers. It would be better to place them at the beginning of the main table with the services. As regards the comparison aspect for consumers, these packages are rather inferior because there are very different versions of them on the market. We suggest that information about the fixed account fee and the individual prices for the respective account services should be provided first. The standard form filled out in the consultation paper is not clearly understandable, also due to the same price of EUR 120. It is not really comprehensible that EUR 120 has to be paid twice. Consumers not familiar with packages of this kind might understand this information to mean that the annual costs total EUR 120.
The designation “total annual costs” should be avoided as misleading and reduced to “annual costs”. After all, the word “total” misleads the reader to assume that the figure is a genuine all-inclusive price with no additional fees. An alternative would be to sum up both items (as “total annual costs”) and clearly indicate that additional charges are billed for transactions not included in a package.
The “channel” should in any case be added to the list of what service packages include. Actual practice in Austria shows that price differences can arise particularly for packages depending on how orders are issued or executed. The information that, say, 5 credit transfers are included is – in this context - of no real use because many packages include specifically just electronic transfers but exclude transfers done on paper. The conclusion from the suggested presentation would be that prices of packages cannot be presented correctly at all.
In our view, it is unclear what exactly falls under “Additional Information”. We do not really understand why “Standing Order, for instance, was placed under this item in the standard example and not under main services."
We advocate that the sum of the annual costs (fees and interest) be supplemented on the first page of the Statement of Fees (SoF). Unlike the pre-contractual Fee Information Document (FID), it is possible here to indicate the actual overall costs. That means the envisaged comprehensive cost indicator (for Member States availing themselves of the directive option) can be eliminated at this spot and the annual total price is provided for in the SoF in all Member States.
As with the fee information, the information in the Statement of Fees should also be supplemented for the service packages by adding the manner by which an order is issued or a transaction is executed (indication of the “channel”). This addition is indispensable in this context, too, in order to depict existing account products.
In the interest information, a differentiation should be made between interest earned and credit paid for the sake of clarification if Article 10 paragraph 2 is not applicable. Austrian banks right now are increasingly crediting no credit interest to newly available current accounts but they are charging debit interest.
[Consumer or consumer association"]"
The Austrian Federal Chamber of Labour is by law representing the interests of about 3.4 million employees and consumers in Austria. It acts for the interests of its members
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