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The Federation of Finnish Financial Services (FFI)

The aim at selecting a number of core services is to make it easy for the consumer to rapidly get an overview and to facilitate comparisons on the most common services related to a payment account. One of the key objectives should be to avoid consumer confusion in comparing fees and services between different service providers when payment account related services differ in functionality and contents. Broad approach will lead to a large number of sub-categories in the Fee Information Document (FID). Sub-categories will in turn most likely to result in a relatively long and complex list of services varying significantly between the PSPs. It’s likely that some PSPs will have a large number of sub-services with detailed content and price information, while others will not. A clear overview on the most common services may then not be achieved. It should be noted that in addition to the FID, the consumer will also receive his/her PSP’s inclusive price list. Hence, the FID should not be exhaustive in each category.
We would prefer focusing on the most frequently used services or services implying the highest costs following the EBA criteria, complementing the inclusive fee information the consumer will get in any case. In Finland, financial sector has been obliged to provide inclusive price information at their branches and websites as from 1 May 2000 (Government Decree 1359/1999 Section 11, repelled by the Decree 553/2013 Section 5, the Decrees transposing Directive 98/6/EY).

It should be clarified that the Union standardised terminology established by the EBA should be integrated to the national list to the extent they exist as services linked to a payment account at the Member State level (e.g. overdraft). In a Member State where the service is not provided, it should not be mandatory to integrate the service in the respective national list of the most representative services.
“Provision of a credit card with a payment account” does not reflect common practices on the Finnish payments market. In accordance with the statistics published by the Bank of Finland, most of the annual card payments (90 % of 1,4 billion card transactions) were made by using online- or offline-debit cards. Furthermore, about 78 % of all payment cards were online- or offline-debit cards. Debit card is a necessary means of payment, used by almost all consumers, and does not involve any risk of indebtedness. Credit cards do not seem to be one of the most representative consumer services in the Finnish payment market.

Credit card follows another logic and can hardly be seen as a basic feature of a bank account or as a basic payment service to be granted to everyone as it involves credit risks and risk of indebtness. Credit card is a separate service where the consumer has the choice whether the costs incurred should be transferred from a particular account or paid by other means. It is fairly rarely linked to a particular payment account. They are also often provided by another service provider (i.e. lender) than the one providing the payment account where credit card invoices are debited. From the FID perspective we question if a credit card is a representative service linked to a payment account at all. Besides, service providers should be obliged to inform only of their own charges and fees. We would also like to refer to Recital 12 of the Directive stating that “all provisions of this Directive should concern payment accounts through which consumers are able to carry out the following transactions: place funds, withdraw cash and execute and receive payment transactions to and from third parties, including the execution of credit transfers. As a consequence, accounts with more limited functions should be excluded. For example, accounts such as savings accounts, credit card accounts where funds are usually paid in for the sole purpose of repaying a credit card debt, current account mortgages or e-money accounts should in principle be excluded from the scope of this Directive. However, should those accounts be used for day-to-day payment transactions and should they comprise all of the functions listed above, they will fall within the scope of this Directive.”

“Overdraft on a payment account” does not exist in Finland as a service. We are aware that is the case in some other Member States. The Finnish meaning for “overdraft” is that consumer exceeds the current available funds on his/her account violating the agreement with the bank. Overdraft is considered unauthorised without exception, i.e. it is a breach of contract. The definition and the reasoning by the EBA are misleading and not applicable when informing the customer on penalty fees and interest due to an unauthorised overdraft. In particular in the context of the FID to be provided to the consumers, it would be inappropriate and misleading to include ‘overdraft on a payment account’ as a service. It could be interpreted as encouraging misbehaviour and breach of contract. Although overdraft and overrun are defined by the Directive as services linked to a payment account, it would be appropriate to leave room for Member State discretion because of divergent national practices and national legislation.
Definitions should focus on the service itself rather than defining precisely what is meant by the constituent elements of the service (paragraph 50). We would however like to highlight the fact that the FID must provide flexible space for payment service providers to elaborate further on specific features and usage of that service. Annual fee for a “debit card” without possibility to explain the specifics affecting on the price of the card product in question does not offer comparable information for the consumer. One card might include a travel insurance but another similar card does not.Credit cards should be excluded as the Directive states in Recital 12. Definition of overdraft drafted by the EBA may not compare common practices and legislation in all Member States. Regarding payment account with basic features, agreed overdraft is left for a Member State’s discretion under Article 17(5) of the Directive. Therefore the EBA should consider whether the concept of overdraft should rest upon national lists also in the future.
Terms and definitions drafted in Finnish do not fully reflect mode of expression, structure, grammatical correct idioms and logic of the Finnish language. It should be noted that Finland Swedish, being by the Finnish Constitution the other official language in Finland besides Finnish, may differ in terms, vocabulary and mode of expression from Sweden Swedish.

Usage of terms ‘account’ ('tili') and ‘payment account’ (‘maksutili’) is inconsistent. ‘Maksutili‘ (payment account) should be used. Respectively, ‘betalkonto’ should be used in definitions in Finland Swedish. Terms payer (in Finnish ‘maksaja’ and in Swedish ‘betalare’) and payee (in Finnish ‘maksunsaaja’ or ‘saaja; in Swedish ‘betalningsmottagare’ or ‘mottagare’) are not only legalistic terms but been used for a long time in consumer communications. There is no reason why such terms should be dispelled as they are idiomatic. In direct debits, the payer can mandate only the payee which should clearly come out in the definition as well.

Regarding the proposed terms by the EBA in Finnish:
- ‘Tilin tarjoaja’ is not used in common language. ‘Tilinpitäjä’ should be used instead.
- As ‘Debitkortin myöntäminen’ refers only to conclusion of a card agreement, ‘Debit-kortti’ shoud be used instead. A hyphen is used in the correct spelling.
- Term ‘toistuva maksu’ should be used instead of ‘toistuvaissuoritus’ as the latter is an idiom used only for a specific payment service provided to corporate/public sector customers on payments covering only certain types of recurrent bundled credit transfers, i.e. salaries paid by an employer or pensions and social benefits paid by a public entity/authority.
- ‘Luottokortti’ should be used instead of ‘luottokortin myöntäminen’, and when referring to the service provider granting a credit card, term ‘luotonmyöntäjä’ (lender) should be used instead of ‘tilin tarjoaja’.
- For (arranged) overdraft, term ‘tilinylitysoikeus’ should be used in order to match the definition proposed by the EBA. However, such a service does not exist in Finland. The Finnish meaning for overdraft is that customer exceeds the current available funds on his/her account. Overdraft is always unauthorised without exception, i.e. it is a breach of contract.

Finland Swedish may differ in terms, vocabulary and mode of expression from Sweden Swedish. Regarding the proposed terms by the EBA in Swedish:
- ‘Förvaltning av konto’ is used when referring to securites and investment funds. ‘Innehav av konto’ should be used instead.
- “Debetkort” was used instead of ‘tillhandahållande av debetkort’, and ‘kreditkort’ instead of ‘tillhandahållande av kreditkort’.
- ‘Kontokredit’ is not used in the meaning of ‘tilinylitys” (overdraft). The closest term for overdraft that matches the proposed definition by the EBA would be ”övertrasseringsrätt”.
- Term “girering” should be used instead of “betalning”, as ‘tilisiirto’ is used as the equivalent term in Finnish and only possible translation for ‘tilisiirto’ into English is credit transfer. “Betalning” is a generic term referring to any kind of a payment. “Kreditöverföring” is mainly used meaning SEPA credit transfer.
- “Autogiro” is used only in Sweden Swedish referring to the Swedish direct debit system. For direct debit service provided in Finland, term “direktdebitering” should be used.

We would suggest the following modifications to the terms and definitions in Finnish and (Finland) Swedish:
• Maintaining the account
- Tilin ylläpito: Tilinpitäjä ylläpitää asiakkaan maksutiliä.
- Innehav av konto: Kontohållaren upprätthåller kundens betalkonto.
• Providing a debit card
- Debit-kortti: Tilinpitäjä myöntää debit-kortin, joka on liitetty asiakkaan maksutiliin. Korttimaksun rahamäärä veloitetaan heti täysimääräisenä asiakkaan tililtä.
- Debetkort: Kontohållaren beviljar ett debetkort, som är kopplat till kundens betalkonto. Penningbeloppet för kortbetalningen debiteras genast till fullt belopp från kundens konto.
• Providing a credit card
- Luottokortti: Luotonmyöntäjä myöntää luottokortin. Asiakas maksaa sovittuna ajanjaksona kertyneiden maksujen määrän luotonantajalle sovittuna eräpäivänä. Luoton käytöstä perittävästä korosta ja muista maksuista sovitaan luotonmyöntäjän ja asiakkaan välisessä luottosopimuksessa.
- Kreditkort: Kreditbeviljaren beviljar ett kreditkort. Kunden betalar åt kreditbeviljaren på en avtalad förfallodag beloppen för de betalningar som gjorts under en avtalad period. I kreditavtalet mellan kreditbeviljaren och kunden avtalas om räntor och avgifter som debiteras för användningen av krediten.
• (Arranged) overdraft
- Tilinylitysoikeus: <no modifications suggested>
- Övertrasseringsrätt: <no modifications suggested>
• Sending money (only possible translation for the Finnish term ’tilisiirto’ is credit transfer)
- Tilisiirto: Tilinpitäjä siirtää maksajan ohjeiden mukaisesti rahaa maksajan tililtä saajan tilille.
- Girering: Kontohållaren överför medel från betalarens konto till mottagarens konto i enlighet med instruktioner givna av betalaren.
• Standing order
- Toistuva maksu: Tilinpitäjä siirtää säännöllisesti tietyn rahamäärän maksajan maksutililtä saajan tilille maksajan antamien ohjeiden mukaisesti.
- Återkommande betalning: Kontohållaren överför regelbundet ett visst belopp pengar från betalarens betalkonto till mottagarens konto i enlighet med instruktioner givna av betalaren.
• Direct debit
- Suoraveloitus: Maksaja sallii tilinpitäjänsä siirtää rahaa maksutililtään maksunsaajan tilille maksunsaajan ohjeiden mukaisesti. Maksaja ja maksunsaaja sopivat päivästä ja maksutilistä, jolta siirto tehdään. Rahamäärä voi vaihdella.
- Direktdebitering: Betalaren tillåter att kontohållaren överför pengar från betalkontot till betalningsmottagarens konto i enlighet med instruktioner givna av betalningsmottagaren. Betalaren och betalningsmottagaren avtalar om den dag och det betalkonto från vilket debiteringen sker. Summan kan variera.
We support EBA’s approach not to limit number of pages of the FID. There is likely to be need for specificying service features further as suggested in our answer to Q3. Limiting number of pages would not serve the consumer and would also be counterproductive.
The template as drafted in the Annex should be non-binding as output model in order to allow different needs resulting e.g. from the language, alphabet and contents of the service itself. Other pre-contractual documents like ESIS for mortgage credit (Directive 2014/17) or SECCI for consumer credit (Directive 2008/48) leave more freedom regarding the respective formats without simultaneously adversely affecting the comparability or readability thereof. The draft ITS does not seem to meet common requirements of Recital 20 of the Directive stating that “EBA should also take into account the fact that Member States may choose to provide the fee information document and the statement of fees together with information required pursuant to other Union or national legislative acts on payment accounts and related services”.

‘Fee’ means all charges and penalties that are payable by the consumer to the payment service provider for or in relation to services linked to payment account under Article 12(5) of the Directive. Payment service providers are also obliged to inform the consumer of taxes and other similar charges in accordance with other Union or national legislation, e.g. under Articles 3(2)(2) and 3(2)(3) of Directive 2002/65/EC concerning the distance marketing of consumer financial services. The draft ITS leaves open how the payment service provider should inform the consumer of taxes (e.g. VAT, tax at source) on the FID that the payment service provider is obliged to charge on behalf of tax authorities regarding the service provided. For example, in Finland, a bank is obliged to charge tax at source of the interest paid on the account on behalf of the Tax Authority and inform of it on the statement of account.
It should be clarified that apart from taxes the payment service provider is obliged to inform only of fees originated by the payment service provider itself. Fees originated by third parties, such as other payment service providers, should not need to be included in the FID.
A text next to the symbol such as “Standardised EU information sheet” should be added since many consumers will not be aware of the symbol and may not understand why they also receive the FID besides the bank’s or other payment service provider’s normal price list.
It should be ensured that it is possible for payment service providers to process the common symbol and the template in their IT systems without manual intervention. The common symbol should be provided by the EBA in a graphic form (i.e. printable separate logo) that is accessible, processable and printable in automated IT systems.

The template should be non-binding as output model regarding technical features e.g. column width in order to allow flexibility resulting from differences in language and alphabet (Latin, Greek, Slavic). E.g. number of characters and word length may vary significantly due to language and alphabet used. The template seems to provide an excessive space for fees and leaving practically no room for the service and brand name. Size of the columns should not be fixed. There should be an unlimited space for explaining the specifics regarding the service in question. In addition, for instance channel and customer group (student, VIP, senior etc.) are relevant regarding the actual fee. If relevant information was not provided, the FID would be misleading and hence would not fulfil its’ purpose for the consumer. Please see our answer to Q5 as well.

Packages should be separated from service-specific features. If a debit card includes a travel insurance, such information should be provided in context with the card. Clarification would be needed in order to avoid divergent interpretation at Member State level.

Please clarify what “comprehensive cost indicator” means. We would however suggest the comprehensive cost indicator was deleted.
It should be ensured that it is possible for payment service providers to process the common symbol in their IT systems without manual intervention. The common symbol should be provided by the EBA in a graphic form (i.e. as a separate printable logo) that is accessible, processable and printable by payment service providers in their automated IT systems. Please see our answer to O5 and Q7.
Please clarify the meaning of the box “Statement of fees”. If a running serial number of the SoF is to be informed, we consider it unsignificant information for the consumer as period of the SoF has also to be provided. In addition, if the SoF is provided annually once a year, a running number of SoF is even more unnecessary.

Interest may also be determined on the basis of tiered interest rate. Tiered net interest may depend on several variables such as the value of the reference interest rate, the daily closing balance of the account and changes in the interest reference rate. Hence the net interest percentage and the interest itself can fluctuate a lot depending on the applicable variables. Detailed information of all variables and changes in them listed in the box “interest rate” in detailed interest earned/paid would complicate and extend the SoF significantly as well as cause significant costs for payment service providers. Therefore we suggest that the SoF should be kept as simple as possible including basic information of the basis for calculating the interest and the total interest earned/paid. Presumably, for the consumer, the total amount of the interest earned/paid is more substantial for comparison purposes than an exhaustive list of detailed technical information.
It should be clarified that apart from taxes the payment service provider is obliged to inform only of fees originated by the payment service provider itself. Fees originated by third parties, such as other payment service providers, should not need to be included in the SoF. Please see our answers to Q5 and Q7.
A text next to the symbol such as “Standardised EU information sheet” should be added since many consumers will not be aware of the symbol.
The SoF should include information on the total amounts of fees and interests paid in relation to the payment account without dividing them by heads per an account holder. Division of fees etc. would be confusing and misleading for the consumer as the fees and interest are subject to an account. Division would also require far-reaching and costly changes in IT systems. We suggest that the EBA to consider whether the SoF should include a standard text indicating that the SoF includes the total amount of fees and interests regardless of number of account holders. Please see our answers to Q5 and Q7.
t should be ensured that it is possible for payment service providers to process the common symbol and the template in their IT systems without manual intervention. The common symbol should be provided by the EBA in a graphic form (i.e. printable separate logo) that is accessible, processable and printable in automated IT systems.
Template as drafted in the Annex should be suggestive (please see our answer to Q5 and Q7). Size of the columns should not be fixed. There should be an unlimited space for explaining the specifics regarding the service in question. In addition, for instance channel and customer group (student, VIP, senior etc.) are relevant regarding the actual fee. If relevant information was not provided, the SoF would be misleading and hence would not fulfil its’ purpose for the consumer. Please see our answers to Q5 and Q7.
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The Federation of Finnish Financial Services (FFI) is the common voice of the Finnish financial sector and represents the interests of its members.
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The Federation of Finnish Financial Services (Finance Finland, FFI) is the common voice of the Finnish financial sector and represents the interests of its members.
Ms. Essi Ruokanen
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