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ASOCIACIÓN DE USUARIOS FINANCIEROS

ASUFIN

The Spanish Financial Users Association (ASUFIN) is a non-profit consumer association founded on 20 July 2009.

Lobbying Activity

Meeting with Maria Luís Albuquerque (Commissioner) and

26 May 2025 · • SIU, • pension system • financial literacy

Response to Consumer Credit Agreement – review of EU rules

1 Sept 2020

ASUFIN (Asociación de Usuarios Financieros), as a Spanish consumer organization specialised on financial products, welcomes the review of the Consumer Credit Directive, as we consider that there are certain issues that should be taken in consideration for the best protection of the consumers. ASUFIN agrees with all the points of the Inception Impact Assessment, considering specially important the following points: Increase the scope of the Directive to include credits under 200€, as well as other kind of credits, like instant or very short term ones. Remark the importance of the responsible credit practices to avoid the over-indebtedness. Make more effective the information given in the pre-contractual phase. ASUFIN also thinks that there should be an european harmonization on credit lines and revolving credits regulation. In Spain we just got a new law on this topic ( https://www.boe.es/diario_boe/txt.php?id=BOE-A-2020-8583), and although it is quite complete (it includes some new dutys for financial entities to provide information to consumers), we consider that there is still scope for improvement. As for example, we propose: A temporal limitation of the revolving credits to avoid a “whole life over-indebtedness” and eliminate debt spirals. The creditworthiness assessment should be aplicable in every circumstances, not allowing exemptions by using the “freedom of contract”. Sanctions for those entities that do not respect the creditworthiness assessment obligations. Our new law includes several obligations on this matter, but there are not consequences for the creditors that do not act accordingly to them. Finally, ASUFIN considers that the best policy option is a comprehensive revision of the Directive.
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