OpenLobby.EU
Explore

Verband der Sparda-Banken e.V.

VSB

The Association undertakes this task for the eleven legally and economically independent Sparda-Banks.

Lobbying Activity

Meeting with Engin Eroglu (Member of the European Parliament)

19 Sept 2025 · Housing crisis

Meeting with Moritz Körner (Member of the European Parliament)

14 Jan 2025 · Introductory Meeting

Meeting with Moritz Körner (Member of the European Parliament)

5 Mar 2024 · Banking and financial market policy

Meeting with Michael Kauch (Member of the European Parliament)

5 Mar 2024 · General Exchange

Meeting with Rasmus Andresen (Member of the European Parliament)

31 May 2023 · CMDI

Response to Evaluation of the Consumer Credit Directive

26 Jul 2018

While we intend to offer a written submission also to the announced consultation process later in the year, we hereby wish to provide the Commission with some basic ideas on the regulatory approach to consumer credit already today: In order to successfully step onto a new market the entrant must not only try to meet the preferences and tradition of the new target group but also adapt products and services to the new tax and legal regime. This makes considerable investments necessary into legal, tax and marketing expertise. Inter alia against that background, some market participants – such as for example the German Sparda-Banks – have taken the decision to see a specific region as their sole market and have incorporated this decision even within their statutes. The rationale here is the notion that we think that we can serve our clients best in the (local) markets that we know best. As a matter of fact, this model is a very valid one in the case of the Sparda-Banks that should not be called into question by regulation which has other bank models in mind. While competition is, of course, accepted and indeed welcome, we would see it as being out of balance if banks with a regional focus were forced to have, for instance, costly procedures in place which solely aim at the cross-border provision of services to unsolicited customers, although this is not within the scope of our banking model. Hence, it is necessary to apply a differentiated regulatory approach between (by choice) domestic providers and cross-border providers to help reaping the full benefits of market integration quickly and with the least market and competitive distortions. In this context, the fact must be taken into account, that each new piece of legislation will necessarily have uneven effects within the different banking markets of the Member States, depending on the vicinity of the current framework to the new legal situation. Thus, the cost to adapt will be divided unequally across Member States. It remains an open question what the optimum is in this regard – for example with view to vitality and productivity. If business models need to be adapted due to changing rules, it may be the case that de facto competitive banks cease to be a counterforce on the market. In the long run, this may damage the intensity of competition and the quality of supply and even limit customer choice. Therefore, potential welfare gains of allegedly more integrated consumer credit markets have to be weighed against welfare losses during and after the transition phase. Seen from that angle, a policy that promotes “optimal integration” is not necessarily one that aims at maximum amounts of cross border business or perfect proximity to the law of one price: Having the multitude of business models and consumer needs in mind the full costs and benefits must incorporate an assessment of how (unintended) second round effects are to be evaluated, i.e. effects of the distribution of adjustment costs, on market structures and competition and the changes in the degree of competition in domestic and EU markets. If the target is to achieve more financial market integration we need regulatory conditions through which market opportunities are opened up for consumers and providers who want to benefit from them, without harming those that on the basis of their individual business policy do not wish to do so. And we need rules that are easy to understand, transparent and secure also for the bank customers. Thus, making use of 29th regimes wherever possible seems to us to be the most promising way forward. Such an approach, compounded by the introduction of genuinely independent, objective comparison portals and a fresh look into the optimum amount and structure of information material that consumers are prepared to take into consideration when deciding on financial products - and consumer loans, in particular, - would have the full support of our banking group.
Read full response