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Reacting to the recently published Consumer Credit Directive, the Council of Mortgage Lenders criticizes the CCD as a flawed piece of legislation. Its objectives are confused as there is a real and unresolved tension between promoting efficient transparent markets and legislating on harmonised consumer protection, CML notes.
The Council also criticizes that the Directive has never been subjected to an impact assessment by the Commission. In contrast, independent impact assessments suggest that the CCD will fail to achieve its objectives and even have a negative effect on some national markets.
“Much of the directive appears to be driven by the need to secure political agreement rather than by analysis of consumer credit markets”, CML states. “If its shortcomings are not challenged there is a risk that the CCD will sets precedents to be followed by the Commission when considering action in other financial markets such as mortgages”.