OpenLobby.EU
Explore

4finance Group

Established in 2008, 4finance is one of Europe’s largest digital consumer lending groups with operations in 11 countries.

Lobbying Activity

Response to Consumer Credit Agreement – review of EU rules

27 Aug 2021

4finance Group’s response to the proposal for a new Consumer Credit Directive The EC was in part prompted to revisit the Consumer Credit Directive by the rapid pace of change in consumer lending since 2008 – the reappraisal is therefore welcome. However, in its present form the proposals risk appearing more a list of actions than a coherent plan to shape the future of consumer credit in Europe. We welcome the obligation of formal regulation to better protect consumers, but are concerned that other aspects of the proposals may reduce consumer protection, by prompting growth in shadow lending. In particular we are concerned that despite the advances in technology and greater scope for use of timely, relevant data in credit decision making, opportunities to take advantage of digitalisation have been side lined in favour of more prescriptive rules. The proposals overemphasise detailed rules on matters of creditworthiness and caps, without a clear vision of desired outcome. This risks over-regulation to address exceptions, rather than regulating based on what delivers the best result (both in terms of access and protection) for the greatest number of consumers. The proposals in their current form may encourage excessive intervention on matters of caps and creditworthiness. This intervention, rather than an evidence-based approach, may lead to creditworthy individuals who could benefit from access to regulated credit being forced out from the protective umbrella of regulated choices, towards the unregulated, illegal and dangerous alternatives. Across the Member States, where regulation has failed to balance strong consumer protection and a viable market for regulated consumer credit, creditworthy consumers seek access to finance elsewhere. For further details please see the attached document where we address: Mandatory interest rate caps APR as a measure for caps Creditworthiness Assessments Intermediaries Tying and bundling Supervision APR calculation for overdrafts Proportionate regulatory burden How well regulated non-bank lenders reduce systemic risks
Read full response

Response to Consumer Credit Agreement – review of EU rules

31 Aug 2020

Please find our response attached.
Read full response