Response to consultation on Technical Standards on standardised terminology and disclosure documents under the PAD
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With narrow approach there is very complicated to agree the same definition for all countries and all banks. Narrow approach makes service lists so long and which make it difficult to read. And if terms will change in the future then this will make things more complicated for the customer for some time.
Credit cards is such product of which terms and conditions can be very different bank by bank. Credit card needs separate decision from decision making body. There are different kinds of credit cards - related to payment account and also related to some other types of accounts. So it could arise misunderstanding in customers in which case which credits cards are taken into account.
“Overdraft on a payment account” is not offered in largest banks operating in Estonia as a specific service for example. Related procedures are based on other regulations.
FID should provide for the bank possibility to explain service feature (e.g. Some card annual fee may include insurance). Otherwise banks who have additional services related with a product, will not be on the same level with other banks and customer does not get all information.
Terms "Providing debit card or credit card"(Deebetkaardiga varustamine") -this is also not common market practice. Providing means just issuing and in Estonian translation "varustamine" means like warehouse service. But the idea for the customer is all debit/credit card service - issuing, maintaining, renewal etc. We propose just "Debit card" and "Credit card".
Below we would like to provide the following terms and definitions:1. Konto haldamine - kontohaldur haldab kliendi kasutatavat arvelduskontot ehk maksekontot. 2. Maksekaardi asemel pangakaart. 3. Deebetkaardiga varustamine (selle asemel Deebetkaardi pakkumine või Deebetkaart) – kontohaldur pakub kliendi kontoga seotud pangakaarti. Iga kaarditehingu summa võetakse otse ja kogu ulatuses kliendi kontolt. 4. Arvelduskrediit – Laenusumma, mille ulatuses võib klient eelneval kokkuleppel kontohalduriga kasutada oma konto jäägist suuremat summat. Lepingus määratakse laenu maksimumsumma, sellelt arvestatavad intressid ja tasud ning laenu tähtaeg. 5. Krediidikorralduse asemel „makse“ või "maksekorraldus"- kliendi algatatud juhis kontohaldurile raha kandmiseks kliendi kontolt teisele kontole. 6. Püsikorraldus – kliendi juhis kontohaldurile kliendi kontolt regulaarselt kindla summa kandmiseks teisele kontole. 7. Otsekorraldus – saaja algatatud juhis kontohaldurile raha kandmiseks kliendi kontolt teisele (saaja) kontole. 8. Sularaha väljavõtmine - klient võtab oma kontolt sularaha välja.
How to understand - account name? PAD is aimed for basic payment account and current account. And as there is no specific term proposed by EBA then any bank will use their own term and this will not achieve the aim of FID. We propose there is no need for this row.
We propose some ideas: additional info could be added in smaller font; column for Fee is too wide.
Different countries may interpret Payments (excluding cards) differently (e.g. International payments are in or not , etc).
There is no clear understanding what should be added under Additional info.
There is a need for more examples in instructions.
If one bank adds for ex. fee for copy of statement to SOF but another bank does not as it is not needed, then for customer seems that first bank is more expensive.""
Question 1: Do you agree with the EBA’s decision to take a broad approach to defining ‘service’? Please explain your reasoning.
We agree with a broad approach as it allows to use existing market situation for sub-services.With narrow approach there is very complicated to agree the same definition for all countries and all banks. Narrow approach makes service lists so long and which make it difficult to read. And if terms will change in the future then this will make things more complicated for the customer for some time.
Question 2: Do you consider the services that the EBA has selected for standardised terms and definitions to be suitable to achieve the aims of the Directive? Please explain your reasoning.
No, those terms will not achieve the aim of Directive. We see problem specially with credit related products. If only some credit related products are stated in FID and SOF, it could confuse customers. Off course there is no reason to define all credit product terms and definitions. So we propose to remove credit card and overdraft terms from the list. Please note, that credit services are regulated by consumer credit directive and in order to avoid conflict between these two legal act it is better to regulate credit products bt consumer credit directive.Credit cards is such product of which terms and conditions can be very different bank by bank. Credit card needs separate decision from decision making body. There are different kinds of credit cards - related to payment account and also related to some other types of accounts. So it could arise misunderstanding in customers in which case which credits cards are taken into account.
“Overdraft on a payment account” is not offered in largest banks operating in Estonia as a specific service for example. Related procedures are based on other regulations.
Question 3: Do you consider the drafting decisions taken by the EBA for the standardised terms and definitions, and the resultant provisions in Recitals of the draft RTS, to be suitable for achieving the aims of the Directive of enhancing transparency and comparability? Please explain your reasoning.
It is suitable for achieving the aims but it needs to be taken into account that there is a need for some more flexibly (some more differentiation could be allowed, more space/columns allowed for additional information about specific fee components etc).FID should provide for the bank possibility to explain service feature (e.g. Some card annual fee may include insurance). Otherwise banks who have additional services related with a product, will not be on the same level with other banks and customer does not get all information.
Question 4: Do you consider the terms and definitions proposed by the EBA in the Annexes to the draft RTS, and the resultant provisions in the Recitals of the draft RTS, to be adequate for achieving the aims of the Directive of enhancing transparency and comparability? If not, please provide alternative terms and definitions and their underlying rationale.
No. There are couple of term which is used in our market differently. In Estonia there is no term credit transfer (translated: krediidikorraldus). This translation and also the term in English is not common market practice. This translation would referent to loans, not to payments. This will not be in accordance with chapter 45 in EBA Consultation paper - terms and definitions should be drafted in clear, simple, and consumer-oriented language which avoids the use of legal terminology. In Estonia is used word "Maksekorraldus" or "Makse" or "Ülekanne".Terms "Providing debit card or credit card"(Deebetkaardiga varustamine") -this is also not common market practice. Providing means just issuing and in Estonian translation "varustamine" means like warehouse service. But the idea for the customer is all debit/credit card service - issuing, maintaining, renewal etc. We propose just "Debit card" and "Credit card".
Below we would like to provide the following terms and definitions:1. Konto haldamine - kontohaldur haldab kliendi kasutatavat arvelduskontot ehk maksekontot. 2. Maksekaardi asemel pangakaart. 3. Deebetkaardiga varustamine (selle asemel Deebetkaardi pakkumine või Deebetkaart) – kontohaldur pakub kliendi kontoga seotud pangakaarti. Iga kaarditehingu summa võetakse otse ja kogu ulatuses kliendi kontolt. 4. Arvelduskrediit – Laenusumma, mille ulatuses võib klient eelneval kokkuleppel kontohalduriga kasutada oma konto jäägist suuremat summat. Lepingus määratakse laenu maksimumsumma, sellelt arvestatavad intressid ja tasud ning laenu tähtaeg. 5. Krediidikorralduse asemel „makse“ või "maksekorraldus"- kliendi algatatud juhis kontohaldurile raha kandmiseks kliendi kontolt teisele kontole. 6. Püsikorraldus – kliendi juhis kontohaldurile kliendi kontolt regulaarselt kindla summa kandmiseks teisele kontole. 7. Otsekorraldus – saaja algatatud juhis kontohaldurile raha kandmiseks kliendi kontolt teisele (saaja) kontole. 8. Sularaha väljavõtmine - klient võtab oma kontolt sularaha välja.
Question 5: Do you consider the FID template that is being proposed in the draft ITS and its Annex to be suitable to achieve the aims of the Directive? Please explain your reasoning.
No. There is a need for additional column where to add additional info about the services. For example, for account opening there are differences for residents and non residents, thy need to be mentioned somewhere for customer to understand the full service. Also for different age customers there are different prices. There is a need for some more flexibility (some more differentiation could be allowed, more space/columns allowed for additional information about some specific fee components etc).How to understand - account name? PAD is aimed for basic payment account and current account. And as there is no specific term proposed by EBA then any bank will use their own term and this will not achieve the aim of FID. We propose there is no need for this row.
We propose some ideas: additional info could be added in smaller font; column for Fee is too wide.
Question 6: Do you consider the common symbol in the FID template that is being proposed in the draft ITS and its Annex suitable to achieve the aims of the Directive? Please explain your reasoning.
We do not have special view. Possibly it should be added a text next to the symbol “Standardsed EU information sheet” since many consumers will not be aware of the symbol and may not understand why besides the bank’s normal price list they also receive the FID.Question 7: Do you consider the proposed instructions for the completion of the FID template contained in Articles 2 to 11 of the draft ITS, to be suitable to achieve the aims of the Directive? Please explain your reasoning.
Generally yes. But they are too technical and there is a need for more detailed explanations.Different countries may interpret Payments (excluding cards) differently (e.g. International payments are in or not , etc).
There is no clear understanding what should be added under Additional info.
There is a need for more examples in instructions.
Question 8: Do you consider the proposed instructions for the completion of the FID template contained in Articles 2 to 11 of the draft ITS, to be clear and easy to follow? Please explain your reasoning.
Info is clear but insufficient.Question 9: Do you consider the SoF template that is being proposed in draft ITS and its Annex to be suitable to achieve the aims of the Directive? Please explain your reasoning.
Generally yes. If in SOF could be only fees related to PAD, only most representative services, then there should be mentioned in the title that SOF is only for payment account.If one bank adds for ex. fee for copy of statement to SOF but another bank does not as it is not needed, then for customer seems that first bank is more expensive.""