Question 2 concerning the standardised terminology and definitions for the eight most representative services identified by the EBA:
The EBA identified the eight banking services most commonly used in the majority of Member States. The EBA then proposed terms and definitions to describe each service.
Concerning the eight services identified as the most representative:
UFC-Que Choisir regrets that the EBA list is less exhaustive than the French “Extrait Standard des Tarifs”1 featured by every payment service providers (PSPs) in their tariffs schedules in France. Therefore, UFC-Que Choisir considers that the French “Extrait Standard des Tarifs”, which notably includes fees (commission d’intervention) linked to irregularities of operation that require special treatment on the account, should be maintain in parallel with the standardised European list.
Concerning the standardised terms and definitions describing each service:
UFC-Que Choisir considers that some standardised definitions are not sufficiently precise, especially the following elements:
Payment cards: it would be better to define them according to their features (immediate or deferred payment) rather than according to services to which they are associated (credit, i.e. overdraft authorisation);
Credit transfer: it would be better to precise whether it is a SEPA or an international transfer.
Moreover, UFC-Que Choisir would like to bring as closest as possible the French and the EBA/ European terms and definitions for the most common services retained in the new national list.
Besides, UFC-Que Choisir would like to draw EBA’s attention on the necessity to keep the concept/term of “used account” to define fees related to the use of a bank account.
Question 5 concerning the Fee Information Document (FID):
The Directive requires PSPs to provide a pre-contractual Fee Information Document (FID) to consumers. This document should be short and clearly distinguishable (i). Beside the FID should disclose all fees related to the most representative services linked to a payment account (ii) and, where one or more services are offered as part of a package, it should reveal detailed tariffs information (iii).
Concerning the content of the FID
UFC-Que Choisir recalls that the FID must be short and clearly identifiable in order to help consumers having access to legible and reliable information and allow efficient comparison between the different providers’ offers.
UFC-Que Choisir considers that services identified in the FID offered as part of a package must be clearly designated for consumers. Therefore, any commercial terms specific to each PSP should be excluded.
UFC-Que Choisir underlines, as mentioned in the previous question, the importance to bring as closest as possible the French and the EBA/ European terms and definitions for the most common services retained that will be in the FID.
UFC-Que Choisir emphasises that unit services prices should be displayed at the top of the FID (i.e. before packages). This would inform consumers that they can opt for each of these services independently of a package and at which price. Consumer would be therefore able to assess whether packages proposed by PSPs are really more attractive for them than services “à la carte”. Recital 24 of the Directive thereby requires that “(…) Member States should ensure that when payment service providers offer packaged payment accounts consumers are provided with information on whether it is possible to purchase the payment account separately and if so, provide separate information regarding the applicable costs and fees associated with each of the other products or services included in the package that can be purchased separately”.
Concerning the aim of the FID
UFC-Que Choisir regrets that the FID delivered to each consumer is not intended to be personalised. Indeed, delivered in a sufficient period of time before the signature of the contract the FID would allow consumers to easily compare various offers from many PSPs.
Question 9 concerning the Statement of Fees (SoF):
The Directive requires PSPs to provide a Statement of Fees (SoF) to consumers. This document should be delivered to consumers, at least annually and free of charge (i). Moreover, the SoF should provide details on services invoiced and their numbers (whether or not they are part of a package) (ii) and details linked to the rate of interest charged and the credit rates granted (iii).
Concerning the content of the SoF
UFC-Que Choisir considers that the obligation to specify for each package the list of its products and services is consistence with the objective of tariff transparency foreseen by the Directive.
UFC-Que Choisir would also like to underline that services identified in the SoF must be clearly and understandably named for consumers. Therefore, any commercial designations specific to each PSP should be excluded.
UFC-Que Choisir notes that the SoF is more precise and relevant than the French “Relevé annuel de frais”1 as it exists in France. UFC-Que Choisir suggests, therefore, that the SoF replaces the existing French annual statement of fees.