Green Paper on Retail Financial Services in the Single Market
Date: 2007-04-30
Institutions: European Commission
Subjects: approximation of laws, consumer protection, financial institution, financial market, free movement of capital

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 30.4.2007 
COM(2007) 226 final 

GREEN PAPER 

on Retail Financial Services in the Single Market 

(presented by the Commission) 

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GREEN PAPER 

on Retail Financial Services in the Single Market 

(Text with EEA relevance) 

SUMMARY 

The Commission is currently reviewing the single market to ensure its policies are fit for the 
21st century. The interim report to the Spring European Council outlines the new approach to 
using  single  market  instruments,  and  focuses  on  enhancing  consumer  welfare1.  The 
Commission  will  present  its  final  report  in  autumn  2007,  which  will  include  concrete 
measures  to  benefit  citizens.  Retail  financial  services  represent  an  important  part  of  this 
review. 

Retail  financial  services  are  an  essential  part  of  the  everyday  lives  of  EU  citizens.  Despite 
significant progress in delivering a single market for financial services in recent years, studies 
show that retail financial services integration appears not to have yet reached its potential and 
that competition seems insufficient in some areas.  

Building on the Commission's White Paper on Financial Services 2005–20102, the results of 
the  Commission's  sector  inquiry  into  retail  banking3  and  the  interim  report  on  business 
insurance4, the Green Paper seeks to strengthen and deepen our understanding of the problems 
faced by consumers and industry in the field of retail financial services and to establish the 
scope  for  and  impediments  to  further  initiatives  in  this  area.  The  specific  results  of  this 
consultation,  including  possible  measures  to  improve  the  functioning  of  retail  financial 
services markets, will be incorporated into the final report of the Single Market Review, to be 
published in the autumn. 

The Green Paper sets out the overarching objectives of the Commission’s policy in the area of 
retail financial services, presents in more detail the actions necessary to bring the benefits of 
integrated  EU  financial  market  to  users,  and  requests  feedback  from  stakeholders  on  the 
direction being taken.  

The  Commission  believes  that  integration  in  EU  retail  financial  services  markets  can  be 
further developed by: 

•  bringing  about  concrete  benefits  for  consumers  by  ensuring  that  properly  regulated  open 
markets  and  strong  competition  deliver  products  that  meet  consumers'  needs,  offering 
choice, value and quality; 

•  enhancing consumer confidence by ensuring that consumers are properly protected where 

appropriate, and that providers are financially sound and trustworthy; 

1 
2 
3 
4 

COM(2007) 60, 22.2.2007. 
COM(2005) 629, 1.12.2005. 
COM(2007) 33, 31.1.2007 and SEC(2007) 106, 31.1.2007. 
"Interim Report on the Business Insurance Sector Inquiry", 24.1.2007. 

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•  empowering consumers to make the right decisions for their financial circumstances. This 
is  based  on  several  elements,  including  financial  literacy;  clear,  appropriate  and  timely 
information  provision;  high-quality  advice;  and  a  level  playing  field  between  products 
perceived as having similar characteristics. Empowered consumers may be more confident 
in seeking out the best deals to meet their needs, regardless of the location of the financial 
services provider. 

While initiatives at the EU level are underway or imminent in some areas such as investment 
funds, payments, insurance, mortgage credit, bank accounts and credit intermediaries, in other 
areas, such as retirement savings and financial literacy, work is at a more preliminary stage. 

The  Commission  considers  that  constant  attention  is  needed  to  ensure  that  citizens  reap  the 
benefits of a single market. In pursuing its strategy, the Commission will adopt an open and 
inclusive  approach  to  identify  and  address  problems,  consider  the  full  range  of  policy  tools 
and, where appropriate, will take targeted action. 

The  Commission  welcomes  general  comments  and  feedback  from  stakeholders  on  the 
contents of this paper and answers to the questions therein. Responses should be sent by 
16 July 2007 to markt-retail-consultation@ec.europa.eu. Responses will be placed on the 
Commission's website unless explicitly indicated otherwise. 

1. 

(1) 

(2) 

(3) 

INTRODUCTION 

The Commission is currently reviewing the single market to ensure its policies are fit 
for  the  21st  century.  The  interim  report  to  the  Spring  European  Council  outlines  the 
new approach to using single market instruments, and focuses on enhancing consumer 
welfare5.  The  Commission  will  present  its  final  report  in  autumn  2007,  which  will 
include  concrete  measures  to  benefit  citizens.  Retail  financial  services  represent  an 
important part of this review. 

Building  on  the  Commission's  White  Paper  on  Financial  Services  2005–20106,  the 
results of  the Commission's sector inquiry into retail banking7 and the interim report 
on  business  insurance8,  the  Green  Paper  seeks  to  strengthen  and  deepen  our 
understanding of the  problems  faced by consumers and industry in the field of retail 
financial services and to establish the scope for and impediments to further initiatives 
in this area. The results of this consultation will be incorporated into the Single Market 
Review, to be published in the autumn. 

The Green Paper sets out the overarching objectives of the Commission’s policy in the 
area of retail financial services, presents in more detail the actions necessary to bring 
the  benefits  of  integrated  EU  financial  market  to  users,  and  requests  feedback  from 
stakeholders on the direction being taken. 

5 
6 
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8 

Cf. footnote 1. 
Cf. footnote 2. 
COM(2007) 33, 31.1.2007 and SEC(2007) 106, 31.1.2007. 
Cf. footnote 4. 

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2. 

(4) 

(5) 

(6) 

CONTEXT 

In  this  paper,  retail  financial  services  are  understood  as  services  such  as  current 
accounts,  payments,  personal  loans,  mortgages,  savings,  pensions,  investments  and 
insurance  products,  when  they  are  provided  to  individual  customers,  including  retail 
investors. They are essential for the everyday lives of EU citizens by facilitating their 
full  participation  in  the  economy,  enabling  them  to  plan  for  the  long  term  and 
protecting 
involve  major  financial 
commitments.  Home  loans  are  the  largest  lifetime  financial  exposure  for  most  EU 
citizens,  with  outstanding  mortgage  balances  reaching  almost  50%  of  EU  GDP9. 
Investment funds in the different Member States account for between 4% and 23% of 
EU household financial assets10.  

in  unforeseen  circumstances.  They 

them 

Retail financial services are important in macro-economic terms. Retail banking (over 
half  of  total  banking  activity)  generates  2%  of  EU  GDP  annually  in  gross  income11. 
An ageing population puts added pressure on public finances, increasing the potential 
need for more private and work-based retirement provisioning and health cover. This 
helps  explain  the  growing  economic  importance  of  the  pension,  insurance  and 
investment fund sectors. At the end of 2004, investments by primary insurers reached 
EUR 6 trillion  and  EU  private  pension  funds  managed  EUR 2.5 trillion  in  assets12. 
UCITS  funds  are  capitalised  at  over  EUR 5.7 trillion,  over  50%  of  EU  GDP13.  Life 
insurance premiums alone represent 5% of EU GDP14.  

Significant  progress  has  been  made  in  delivering  a  single  market  for  retail  financial 
services.  A  framework  is  in  place  to  ensure  the  financial  soundness  and  integrity  of 
Europe's  retail  financial  services  providers  in  the  areas  of  banking,  insurance  and 
securities15.  This  framework  is  designed  to  achieve  multiple  policy  goals,  including 
prudential stability, competition and a high level of consumer and investor protection. 
In  some  areas,  such  as  investment  services  and  life  assurance,  comprehensive  rules 
have  been  put  in  place  to  protect  the  interests  of  retail  customers  and  investors16. 
Furthermore, the introduction of the euro, combined with the effects of the Financial 
Services  Action  Plan,  has  spurred  greater  competition  in  Europe's  financial  services 
markets, particularly wholesale markets.  

(7) 

Retail financial services integration appears not to have yet reached its potential and 
competition  in  some  markets  seems  insufficient,  particularly  in  areas  like  payments 
and retail banking17, which may leave EU consumers unable to take full advantage of 
the benefits of the single market. The following indicators illustrate this:  

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Hypostat 2005, European Mortgage Federation. 
SEC(2006) 1057, 26.7.2006. 
SEC(2007) 106, 31.1.2007, p. 7. 
Cf. footnote 10. 
EFAMA quarterly statistical release Q3 2006. 
Source: The European Insurance and Reinsurance Federation (CEA). 
E.g. Directives 2004/39/EC, 2006/48/EC and 2006/49/EC. 
E.g. Directives 2002/83/EC and 2004/39/EC. 
COM(2007) 33, 31.1.2007, p. 2 and p. 3. 

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•  Modest cross-border activity. With the exception of UCITS, cross-border trade 
is limited and activity through cross-border establishment or mergers is lower than 
in  most  other  sectors18.  Commission  surveys  suggest  that  only  1%  of  EU 
consumers currently buy financial services cross-border at a distance, while 26% 
of  consumers  do  so  domestically,  for  instance  over  the  phone  or  internet19.  In 
insurance,  consolidation  of  the  industry  has  taken  place  through  mergers  and 
establishment  rather  than  by  opening  branches  and  providing  cross-border 
services. The volume of cross-border business is extremely small20, with domestic 
insurance  companies  accounting  for  more  than  90%  of  total  premium  income  in 
most  markets.  50%  of  business  is  accounted  for  by  the  20  largest  European 
insurance  groups,  which  in  many  cases  have  a  wide  European  and  even  global 
presence21. 

•  Wide variations in prices. Although interest rate levels have converged to some 
extent  in  areas  such  as  home  loans,  due  largely  to  general  macroeconomic 
convergence and the introduction of the euro22, substantial differences remain for 
payment  services  and  products  such  as  consumer  credit  and  current  accounts23. 
For example, euro credit transfers are free in some Member States and cost more 
than  EUR 10  in  others24.  In  other  sectors,  such  as  motor  or  home  insurance, 
comparisons  of  the  base  price  of  an  insurance  product  are  more  difficult  as 
coverage  and  local  risk  conditions  vary  widely25.  In  2008,  the  Commission  will 
study the price variations in key retail financial services.  

•  Restricted  product  diversity  and  choice.  In  certain  Member  States  long-term 
fixed  rate  mortgage  products  and  some  newer  products,  such  as  equity  release 
mortgages,  may  be  difficult  to  obtain,  which  may  limit  consumer  demand  and 
market growth. In four Member States, more than a quarter of all savings accounts 
have tax incentives, while such products are rare elsewhere in the EU26. Problems 
with tax deductibility have proved an obstacle to the cross-border sale of some life 
insurance and pension products. 

•  Large  variations  in  market  performance.  The  profitability  of  retail  financial 
providers  varies  widely.  For  example,  retail  banking  profitability  in  the  Nordic 
countries, Spain and Ireland appears consistently above the EU average and much 
lower in Germany, Austria, the Netherlands and Belgium27. 

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SEC(2005) 927, 1.7.2005 and SEC(2006) 1057, 26.7. 2006. 
"Eurobarometer 230: Public Opinion in Europe on Financial Services", August 2005. 
According  to  data  from  Eurostat,  intra-EU25  trade  in  insurance  services  fell  by  14.6%  between  2003 
and 2005. 
Cf. footnote 14. 
SEC(2005) 927, 1.7.2005.  
COM(2007) 33, 31.1.2007, p. 3.  
SEC(2007) 106, 31.1.2007, p. 63. 
Risk profiles are different between national and even regional markets. 
SEC(2007) 106, 31.1.2007, p. 40. 
SEC(2007) 106, 31.1.2007, p. 22. 

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(8)  Without  further  efforts,  European  retail  financial  markets  are  likely  to  remain 
fragmented.  Differing  regulatory  and  consumer  protection  frameworks,  taxation 
policies and fragmented infrastructures28 create legal and economic barriers to market 
entry29.  Legal  barriers  may  prevent  or  complicate  the  offering  of  certain  products  or 
accessibility  to  market  infrastructures,  thus  limiting  competition  and  stifling 
innovation. Economic barriers such as the need to adapt products, business models and 
pricing  strategies  raise  the  costs  of  doing  business  in  another  Member  State.  These 
barriers  deter  market  entrants,  restrict  consumer  choice  and  push  up  prices  for 
consumers. High switching costs can reduce consumers' potential to change providers 
for  products  such  as  bank  accounts  and  investment  funds.  The  inability  to  access 
information,  or  incomplete  information,  may  mean  that  consumers  are  unable  to 
choose the best deal. 

(9) 

Consumer  behaviour  and  preferences  may  also  limit  market  integration.  Despite  the 
increased  mobility  of  the  population  and  the  growth  of  cross-border  retail  financial 
service  provision  (including  through  direct  channels  such  as  the  Internet)30,  most 
consumers still opt for products distributed locally through branches, subsidiaries, and 
intermediaries31.  

(10)  Notwithstanding  that  most  customers  of  retail  financial  services  are  likely  to  remain 
domestically focused and that consumers must remain free to choose a local product or 
service if that is their preference, the Commission considers that further reforms may 
be needed to make markets work better for consumers.  

3. 

BETTER REGULATION AND RETAIL FINANCIAL SERVICES 

(11) 

(12) 

Improving  the  operation  of  Europe's  retail  financial  services  markets  may  require 
targeted  and  considered  action,  building  on  what  has  been  achieved.  Some  of  the 
stakeholders consulted in recent years have indicated that more regulation in this area 
is  unlikely  to  bring  significant  benefits  for  consumers.  However,  according  to  other 
sources,  a  regulatory  approach  may  be  needed  in  some  cases.  Building  a  shared 
understanding of the policy challenges is indispensable in order to design policies that 
produce concrete benefits for consumers.  

Initiatives  should  only  be  pursued  where  there  is  evidence  of  clear  and  concrete 
benefits for citizens and a strong economic rationale. Policies must be based on solid 
economic evidence and be subjected to thorough impact assessments. The assessment 
of  appropriate  solutions  must  be  made  on  a  case-by-case  basis,  depending  on  the 
specifics of the market and problems identified. The Commission will only undertake 
new regulatory initiatives in retail financial services if the economic case is made and 
if  factors  such  as  consumer  confidence  and  cross-border  activity  can  be  improved. 
Once policies have had sufficient time to prove their efficiency, the Commission will 

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31 

E.g. payment systems, clearing and settlement systems and credit registers. 
E.g. in insurance, the requirement in some Member States to appoint a fiscal representative in order to 
ensure the collection of premium taxes in the country of the risk makes it difficult to build up business 
profitably from a low base. 
A  recent  UK  survey  suggested  that  over  50%  of  internet  users  do  their  banking  online  (16.9 million 
people). 
Cf. footnote 19. 

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evaluate their impact, in particular whether they deliver genuine and concrete benefits 
for consumers. Where measures are not working, the Commission will not hesitate to 
propose their withdrawal. 

(13) 

In pursuing its strategy on retail financial services, the Commission will adopt an open 
and  inclusive  approach  to  identify  and  address  problems,  consider  the  full  range  of 
policy  tools,  binding  or  not,  promoting  where  appropriate  market-led  initiatives  or 
optional EU legal frameworks such as the so-called "28th regimes"32. Targeted actions 
will be undertaken where necessary.  

4. 

OBJECTIVES AND ACTIONS 

(14)  This  section  outlines  the  Commission's  objectives  in  the  field  of  retail  financial 
services:  bringing  concrete  benefits  for  consumers  notably  in  terms  of  prices  and 
choice;  enhancing  consumer  confidence;  and  empowering  consumers,  and  sets  out 
how the Commission intends to achieve them. 

4.1. 

Lower prices and more choice for consumers 

(15)  The Commission is committed to removing barriers for retail financial services where 
this  will  lead  to  concrete  benefits  for  consumers  in  the  form  of  a  wider  choice  of 
products which correspond to their needs and at more competitive prices. 

Bringing down prices through increased competition 

(16)  The EU regulatory framework aims to create the conditions under which competition 
can  thrive  and  market  forces  can  push  prices  down  while  maintaining  the  quality  of 
products  provided.  The  Commission  will  take  appropriate  action,  be  it  through 
enforcement of competition law or robust infringement policies, where there appears 
to be a practice of not applying or respecting Community legislation. It may also take 
other  initiatives  (including  legislative  ones,  as  justified  following  a  full  impact 
analysis)  in  order  to  ensure  that  markets  are  fair  and  give  consumers  better  deals. 
Obstacles to the basic freedoms provided by the EC Treaty will be addressed to ensure 
that  markets  are  open  and  competitive.  The  Commission's  sector  inquiry  into  retail 
banking  suggests  that  better  market  access  for  financial  institutions  established  in 
other Member States reduces prices for consumers33. 

(17) 

It  is  important  that  consumers  wishing  to  change  providers  are  not  dissuaded  or 
prevented  in  any  manner  from  doing  so.  A  market  with  well-informed  and  mobile 
consumers forces financial institutions to compete to attract and retain them. 

(18)  Barriers to customer mobility, such as fees for terminating an account or policy, poor 
or complex information, product tying and the high administrative burden of changing 
providers, need to be addressed. 

32 

33 

28th regimes are legal frameworks of EU rules which do not replace national rules but are an optional 
alternative to them (e.g. European Company Statute). 
SEC(2007) 106, 31.1.2007, p. 32–33. 

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(19)  Lenders who are unable to access accurate credit information may charge higher prices 
or even refuse to provide credit to consumers. This makes it difficult for consumers to 
shop around for better offers, both nationally and on a cross-border basis. 

Ongoing and planned initiatives 

The  Commission  will  tackle  the  barriers  to  competition  identified  by  the  sector 
inquiry  into  retail  banking34.  In  relation  to  payment  cards,  the  Commission  will 
apply EC competition law where schemes artificially raise costs for consumers. An 
ongoing  area  of  work  refers  to  multilateral  interchange  fees,  typically  paid  by  the 
bank  of  the  merchant  to  the  bank  of  the  cardholder35.  Practices  that  weaken  inter-
network  competition  are  likely  to  be  subject  to  competition  scrutiny36.  Besides 
payment  cards,  the  Commission's  action  will  aim  at  ensuring  that  access  to  credit 
registers and to payment clearing and settlement systems is not unduly withheld. 

The Commission will work together with the national competition authorities in the 
framework of the European Competition Network in deciding how to best deal with 
practices that restrict competition and reduce consumer welfare. 

An expert group on customer mobility in relation to bank accounts was set up by 
the Commission in 2006. It will publish its recommendations in May 2007. Among 
the  options  considered  by  the  group  is  the  development  of  arrangements  for 
switching bank accounts (at national or EU level) and of various measures aimed at 
increasing  information  transparency  and  comparability.  These  options  will  be 
carefully  considered  by  the  Commission,  which  will  weigh  their  impact  before 
making final decisions. 

In  recognition  of  the  increasing  possibilities  of  employees  to  work  in  other  EU 
Member  States,  and  the  importance  of  preparing  adequately  for  retirement,  for 
example  through  work  based  pension  schemes,  the  Commission  has  recently 
proposed a Directive to improve the portability of supplementary pension rights37. 

The forthcoming White Paper on Mortgage Credit will outline initiatives to facilitate 
the transferability of consumers' credit histories and improve lenders' access to credit 
information. The Commission believes that, since this issue goes beyond mortgage 
credit, horizontal initiatives could be envisaged to improve access and transferability 
of credit data. 

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COM(2007) 33, 31.1.2007, p. 4–9. 
Cf. COMP/34.579 concerning MasterCard. 
Such  as  so-called  blending  (the  acquiring  banks'  practice  of  charging  businesses  one  global  price  for 
accepting cards of different types and/or issued by different networks) or the prohibition of surcharging, 
which avoids that merchants request additional fees for the use of the more expensive payment means. 
COM(2005) 507, 20.10.2005. 

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Increasing choice, quality and innovation 

(20) 

Innovation  creates  new  challenges  such  as  ensuring  that  regulation  of  new  products, 
providers  or  financial  advisors  is  appropriate,  that  consumers  are  able  to  understand 
and  compare  new  products,  and  that  a  level  playing  field  between  products  is 
guaranteed.  The  Commission  wishes  to  enhance  consumer  choice,  provided  that  this 
benefits  the  consumer.  Indeed,  consumers  often  express  the  concern  that  a  too  wide 
choice  of  products  may  distract  or  confuse  them,  complicating  their  selection  of  the 
product best suited to their needs. 

(21)  The  Commission  is  determined  to  ensure  that  the  removal  of  barriers  to  a  single 
market  in  retail  financial  services  improves  or  at  least  maintains  the  quality  of 
products provided, and that consumers are in a position to make an informed choice. 
For example, the Payments Services Directive seeks to improve the quality of service 
provision to consumers by increasing the speed at which payments are made38 and by 
facilitating the cross-border availability and use of certain payments products, such as 
direct  debits.  Another  way  to  ensure  the  high-quality  of  the  service  provided  to 
consumers might be accredited certification through international standards39. Indeed, 
accredited certification could provide a sound and transparent assessment of different 
aspects  of  performance,  and  serve  as  a  quality  indicator  to  consumers,  especially  in 
cases of cross-border activity. 

(22)  A  wide  range  of  banking,  insurance  and  savings  products  are  available  in  the  EU. 
However,  a  product  offered  to  consumers  in  one  market  cannot,  in  many  cases,  be 
offered  in  another  market  without  costly  adaptation  to  local  requirements.  For 
example, certain products, such as the ability to execute direct debits on a cross-border 
basis,  may  not  be  available  because  of  diverging  legal  regimes.  These  requirements 
may  reflect  local  consumer  customs  and  needs  and  be  found  in  consumer  protection 
rules,  contract  law,  differing  taxation  and  legal  systems.  Choice  may  also  be 
unnecessarily  limited  by  restrictions  on  the  providers  and  channels  through  which 
consumers  access  retail  financial  services40.  Such  restrictions  should  only  be 
maintained if objectively justified.  

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40 

In some Member States, consumers enjoy “same day” payment whereas, in others, payments can take 
two or three days, even longer in cross-border cases. 
For further information about certification, please see: 
http://ec.europa.eu/enterprise/regulation/index_en.htm. 
E.g. new payment services providers such as supermarkets, money remitters or mobile phone operators 
cannot currently offer their services throughout the single market. 

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(23)  The  insurance  Directives  allow  insurers  to  advertise  and  sell  their  full  range  of 
insurance products throughout the EU, and have abolished the prior approval of tariffs 
and  policy  conditions.  Insurance  products  are,  however,  required  to  respect  national 
rules justified by the need to protect the 'general good'41. This may limit the choice of 
products available to consumers and impose further costs on insurers42. The insurance 
industry has expressed the view that retail business is local and requires a strong local 
presence. The Commission believes that action should concentrate on the elimination 
of market protectionism and on the reduction of unnecessary regulatory costs by, for 
example, removing unjustified general good rules and bureaucratic obstacles such as 
excessive reporting requirements. With the right regulatory regime, which provides a 
high standard of consumer protection, opportunities for direct cross-border trade will 
be  exploited  naturally,  where  and  when  this  makes  sense  for  companies  and 
consumers. 

Ongoing and planned initiatives 

In  insurance,  the  Commission  will  in  2007,  together  with  the  Committee  of 
European  Insurance  and  Occupational  Pensions  Supervisors  (CEIOPS),  –  examine 
the national 'general good' rules taking into account the relevant case law principles.  

The  payments  industry,  on  a  self-regulatory  basis,  is  drawing  up  the  required 
technical  and  business  rules  to  make  the  Single  Euro  Payments  Area  (SEPA)  a 
reality by 2010 at the latest. The Commission is closely monitoring this process. In a 
Communication to be published before the end of 2007, the Commission will assess 
progress  and  consider  further  measures  to  guarantee  the  success  of  SEPA  for  the 
benefit of consumers.  

The  Commission  will  later  this  year  publish  a  White  Paper  on  Mortgage  Credit, 
containing  proposals  to  facilitate  the  creation  of  an  integrated  market  for  mortgage 
credit.  Issues  addressed  will  include  early  repayment,  information  requirements, 
annual  percentage  rate  of  charge,  advice,  property  valuation,  land  registration  and 
foreclosure  procedures.  In  2008,  the  Commission  will  review  national  regulatory 
frameworks under which equity release products are marketed, and the role of non-
banks in mortgage markets, in order to assess whether appropriate EU intervention is 
needed. 

In  order  to  develop  the  appropriate  knowledge  base  for  future  policy  initiatives, 
the  Commission  will  examine  why  consumers  generally  do  not  purchase  financial 
services across borders and how they could be encouraged to seek the best deals to 
meet their needs regardless of the location of the financial services provider. 

41 

42 

The general good concept is based on extensive and consistent case law of the Court of Justice. See for 
example the Commission's Interpretative Communication on the Freedom to provide services and the 
general good in the insurance sector, (OJ C 43 of 6 February 2000). 
Requirements  imposed  on  retail  insurance  products  in  the  interest  of  the  general  good  may  only  be 
justified if they are necessary to protect consumers, if they are proportionate and if they do not duplicate 
home country requirements. 

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Ageing  populations  and  increasing  pressure  on  public  finances  present  clear 
challenges  for  consumers  and  investors,  and  are  a  new  market  for  the  financial 
industry.  The  EU  framework  needs  to  lay  strong  foundations  for  enabling  a 
competitive,  open  and  effective  market  for  long-term  savings,  retirement  and 
pension  solutions  that  meet  consumers'  needs.  The  Commission  has  commissioned 
external  research  that  will  report  at  the  end  of  2007  on  the  current  state  and 
development of the market for retail long-term savings vehicles to help identify the 
range  of  products  currently  available,  the  main  distribution  channels  and  the 
influences  on  consumer  choices.  Building  on  this,  the  Commission  will  examine 
developments  affecting  the  marketing  of  savings  and  retirement  products  together 
with  arrangements  governing  their  sale  and  recommendation.  Due  to  the  nature  of 
long-term  savings  and  pension  plans,  particular  care  is  needed  to  ensure  that 
consumers  are  being  offered  products  that  are  really  adapted  to  their  needs  and 
marketed  appropriately.  These  are  major,  once  in  a  lifetime,  financial  decisions  for 
consumers. Therefore, consumers must be in a position to make their choices in full 
knowledge of the product, correctly assessing their circumstances and needs. 

The  Commission  considers  that  there  could  be  benefits  for  both  consumers  and 
financial  services  providers,  if  optional  simplified,  standardised  financial  services, 
such  as  basic  bank  accounts  could  be  offered.  These  would  be  less  complex  than 
other  products  and  would  meet  a  European  standard  of  consumer  protection,  for 
instance  in  respect  of  information  requirements.  They  could  therefore  be  offered 
cross-border without the need to be modified to meet local regulations. Banks would 
not be obliged to offer them, and would only do so where there was a business case. 
Consumers would have a wider choice of easier to understand products. Further work 
could be undertaken to assess the need for, feasibility and usefulness of such optional 
standardised products. 

4.2. 

Enhancing consumer confidence 

(24)  European  consumers  need  confidence  to  make  the  right  choices.  However,  surveys 
show  that  European  consumers  remain  concerned  about  the  risks  of  cross-border 
activity  and  lack  confidence  in  the  available  legal  protection43.  Further  efforts  may 
therefore  be  required  to  ensure  that  consumers  are  confident  that  they  will  enjoy  the 
same  rights,  regardless  of  the  location  of  the  financial  institution  and  of  the  selling 
mode  chosen.  Four  main  issues  arise  in  this  respect:  protecting  consumers'  interests, 
providing  legal  certainty,  ensuring  access  to  adequate  redress  and  promoting  sound 
and safe retail financial institutions.  

43 

Cf. footnote 19. 

EN 

11 

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Protecting consumers' interests 

(25)  An equivalent level of protection throughout the EU gives consumers the confidence 
to  choose  from  a  range  of  providers  wherever  they  are  in  Europe.  This  protection 
ensures a level playing field for both consumers and service providers. 

(26)  Traditionally,  EU  legislation  in  the  field  of  retail  financial  services  has  sought  to 
establish minimum rules for protecting consumers in all Member States. For example, 
the Life Assurance Directive requires a minimum cooling-off period of 14 days44. This 
approach is not without difficulties: in many cases, Member States have gone beyond 
the minimum requirements, thereby limiting the extent of the level playing field and 
creating diverging levels of protection amongst European consumers. 

(27)  The  modified  proposal  for  a  revised  Consumer  Credit  Directive45,  whose  scope  is 
narrower  than  in  the  original  2002  proposal,  seeks  to  promote  the  emergence  of  a 
genuine  single  market  in  consumer  credit  while  ensuring  a  high  level  of  consumer 
protection.  Consumers  should  be  able  to  have  access  to  a  wider  range  of  consumer 
credit  products  at  more  competitive  prices.  Providers  should  be  in  the  position  to 
market  their  consumer  credit  products  in  all  Member  States  without  having  to  adapt 
the  essential  features  to  different  national  legislations.  So  far,  it  has  proven  very 
difficult  to  find  a  consensus  between  Member  States  on  the  content  and  the  level  of 
harmonisation.  

(28)  Financial services are increasingly sold or marketed over the internet or by telephone. 
The Directive on the distance marketing of financial services46 was adopted in 2002 in 
order to boost consumer confidence in using these technologies in the area of financial 
services  cross-border  and  to  ensure  a  smooth  functioning  of  the  single  market.  Key 
elements of the Directive are pre-contractual information requirements and the right of 
withdrawal.  

(29)  The  Markets  in  Financial  Instruments  Directive  (MiFID)47  introduces  a  harmonised 
comprehensive  set  of  operating  conditions  applicable  to  both  investment  firms  and 
credit institutions that regulates the relationship between them and their clients when 
they  offer  investment  services.  This  framework  consists  in  a  set  of  conduct  of 
business,  best  execution  and  client  order  handling  rules  as  well  as  inducements  and 
conflicts of interest provisions. Specific attention is granted to retail clients for which a 
specific  regime  has  been  established,  which  entails  reinforced  fiduciary  duties  upon 
the  firm.  The  purpose  of  this  approach  is  to  protect  consumers  by  enhancing 
responsible behaviour by firms48.  

44 
45 
46 
47 

48 

See Article 35 of Directive 2002/83/EC. 
COM(2005) 483, 7.10.2005. 
Directive 2002/65/EC. 
Directive  2004/39/EC  and  its  implementing  measures,  Regulation  (EC)  No  1287/2006  and  Directive 
2006/73/EC. 
To avoid that additional rules affect the creation of a level playing field and, at the same time introduce 
barriers  to  market  entry  without  enhancing  investor  protection,  the  MiFID  introduces  a  flexibility 
clause,  allowing  Member  States  to  add  rules  at  national  level  –  but  only  in  strictly  exceptional 
circumstances – in order to enhance investor protection. 

EN 

12 

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(30)  Consumers are also indirectly protected through professional indemnity insurance that 
ensures  that,  in  the  event  of  financial  loss  owing  to  negligent  advice  or  other 
professional  misconduct  by  insurance  and  investment  intermediaries,  damages  or 
settlements may be claimed49. A recent report concluded that the requirements to have 
professional  indemnity  insurance  remain  valid  but  that  further  monitoring  will  be 
required as the legislation is not yet fully implemented in Member States50. 

Providing legal certainty for consumers 

(31)  The  law  applicable  to  contractual  obligations  is  currently  regulated  by  the  Rome 
Convention  of  1980.  On  the  basis  of  this  Convention,  a  consumer  who  concludes  a 
contract for the supply of goods or services is faced with a complex situation: the law 
applicable  to  the  contract  is,  in  principle,  the  one  chosen  by  the  parties,  which  often 
means in practice the law chosen by the provider in the standard terms and conditions. 
However, a consumer will, under certain conditions, benefit from the protection given 
by  the  mandatory  provisions  of  the  law  of  the  country  where  he  resides51.  The 
proposal  for  a  Regulation  on  the  law  applicable  to  contractual  obligations52  will 
modify  somewhat  the  rules  on  the  law  applicable  to  contractual  obligations  in 
contracts with consumers. One of the most important changes is the establishment of 
the  principle  that  the  law  of  the  country  where  the  consumer  resides  habitually  will 
apply to  the contract if the provider pursues his commercial activities in the country 
where the consumer has his habitual residence53. This will provide more legal certainty 
– and thus, confidence – for the consumer who will know that the rules he knows best 
will apply to the contract. The proposal for a Regulation is currently discussed in the 
Council and the European Parliament with a view, in particular, to finding an adequate 
balance between consumer and industry legitimate interests. 

Ensuring access to adequate redress 

(32)  To have confidence in buying financial services cross-border, consumers need to know 
that they would have easy access to redress in the event of a dispute. Consumers have 
two  main  options:  bringing  their  dispute  to  court,  or  to  an  out-of-court  alternative 
dispute resolution (ADR) scheme, such as ombudsman or consumer complaints board. 
ADRs  do not  replace the  possibility of court action, but  offer an  easier,  cheaper and 
quicker  alternative.  ADR  schemes  may  be  either  public  or  private  initiatives.  Partly 
because of this diversity, the status of the ADR decisions may vary. 

49 
50 
51 
52 
53 

See provisions included in Directives 2002/92/EC and 2006/49/EC. 
COM(2007) 178, 11.4.2007. 
Article 5 of the Convention. 
COM(2005) 650, 15.12.2005. 
Some  areas  remain  excluded  from  the  application  of  the  proposed  rule:  life  and  non-life  insurance 
Directives provide for specific laws of conflict and therefore these special rules will take precedence on 
the  general  regime.  DK,  IE  and  UK  are  not  part  of  the  Convention  and  will  not  be  covered  by  the 
Regulation (although UK and IE have an opt-in clause). 

EN 

13 

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(33)  Normally, an ADR scheme in the country of a financial services provider is competent 
to  deal  with  consumers'  complaints.  This  may  prove  complicated  for  consumers 
involved  in  cross-border  disputes,  since  they  need  to  be  aware  of  the  existence  and 
details of foreign ADR schemes. In 2001, the Commission launched a network of EU 
ADR schemes, FIN-NET54, in which members cooperate under common rules, thereby 
facilitating  the  out-of-court  resolution  of  cross-border  consumer  disputes  in  financial 
services.  Cooperation  between  FIN-NET  members  means  that  consumers  shall  only 
contact  ADR  schemes  in  their  own  country.  Member  schemes  assist  consumers  in 
transferring complaints to the competent ADR scheme in the country of the financial 
services provider.  

(34)  Despite  these  efforts,  the  handling  of  consumer  complaints  may  still  be  particularly 

problematic in a cross-border context.  

Promoting sound and safe retail financial institutions 

(35)  A  robust  prudential  framework  is  of  paramount  importance.  Indeed,  consumers  need 
to be confident in the soundness of financial institutions, wherever they are located in 
the Union. The current EU prudential framework should be kept under constant review 
and adapted to market and financial developments. The next step in this respect will be 
the  modernisation  of  the  insurance  prudential  framework,  with  the  forthcoming 
"Solvency 2" proposal.  

(36)  Specific  Directives  in  the  field  of  investment  services55  and  banking56  ensure  that 
consumers  throughout  the  EU  enjoy  a  high  standard  of  protection,  should  the 
establishment with which they have deposited or invested fail. Following a review of 
the framework for deposit guarantee schemes, the Commission will seek to ensure that 
consumers are well informed about the coverage of their deposits; that all deposits are 
covered even for newer financial products and that the length of time that it takes for 
consumer to be reimbursed is limited57. 

Ongoing and Planned Initiatives 

Negotiations in the Council on the modified proposal for a new Consumer  Credit 
Directive are being pursued with the aim of a rapid adoption.  

The objective of increasing consumers' cross-border activities in financial services at 
a distance has not yet been achieved58. The Commission has begun a review of the 
Directive  on  the  distance  marketing  of  financial  services59  and  launched  two 
studies  in  order  to  assess  the  legal  and  economic  impact  of  the  Directive.  A 
Commission  report  is  scheduled  for  2008.  It  will  examine  if  the  Directive  has 
achieved  its  goals  and,  if  not,  why  it  has  not.  If  necessary,  the  Commission  will 
propose amendments to the Directive. 

54 
55 
56 
57 
58 
59 

FIN-NET currently has 48 members from 21 EEA countries. 
Directive 97/9/EC. 
Directive 94/19/EC. 
COM(2006) 729, 27.11.2006. 
Cf. footnote 19. 
Directive 2002/65/EC. 

EN 

14 

   EN 

 
                                                 
The  Commission  will  follow  closely  the  work  announced  by  CEIOPS  for  2007  to 
examine co-operation between supervisors on issues directly influencing insurance 
policyholder protection such as the treatment of cross-border complaints. 

The Commission will monitor existing recommendations60 which establish a number 
of  minimum  guarantees  for  ADR  schemes.  The  proposal  for  a  directive  on  certain 
aspects of mediation in civil and commercial matters61, when adopted, will complete 
the  recommendations  by  ensuring  a  sound  relationship  between  the  mediation 
process and judicial proceedings. 

The Commission is aware that not all national ADR schemes are members of FIN-
NET and that not all EU Member States have ADR schemes for financial services. 
The Commission will contact competent national authorities later this year to collect 
information on the existing national ADR schemes that are not members of FIN-NET 
and identify gaps. It will then assess how the gaps in FIN-NET membership and at 
national level could be filled. 

4.3. 

Empowering consumers 

(37)  Consumers are able to make the most of the single market if they have the financial 
literacy  to  make  decisions  for  themselves,  are  well-informed,  receive  independent 
high-quality  advice  and  can  move  freely  between  providers.  By  empowering 
consumers  in  this  way,  they  may  be  more  confident  in  seeking  out  the  best  deals  to 
meet their needs regardless of the location of the financial services provider. This in 
turn can stimulate competition and make financial services markets work better.  

Developing consumers' financial literacy 

(38)  Developing  consumers'  literacy  in  financial  matters  is  becoming  increasingly 
important,  particularly  as  individuals  take  an  increasing  role  in  making  decisions 
affecting  their  financial  security  and  as  capital  markets  become  more  accessible  to 
consumers.  Numerous  international  surveys  have  demonstrated  a  low  level  of 
understanding of financial  matters on the part of consumers62. There is also a strong 
correlation  between  low  levels  of  functional  literacy  and  the  ability  to  make 
appropriate financial decisions. Consumers with poor financial literacy find it hard to 
understand and make use of the information they receive when they purchase financial 
services,  since  information  is  generally  prepared  having  average  consumers  in  mind 
rather than those with lower levels of financial literacy.  

60 

61 
62 

Recommendation  on  the  principles  applicable  to  the  bodies  responsible  for  out-of-court  settlement  of 
consumer disputes, 30.3.1998, and Recommendation on the principles for out-of-court bodies involved 
in the consensual resolution of consumer disputes, 4 April 2001. 
COM(2004) 718, 2210.2004. 
See  for  example,  "Financial  Capability  in  the  UK:  Establishing  a  Baseline",  UK  Financial  Services 
Authority,  March 2006;  research  by  the  Irish  National  Adult  Literacy  Agency,  August 2006  (see 
http://www.nala.ie/press/pressreleases/20060914161103.html); 
research  published  by 
a working  group  of  the  Autorité  des  Marchés  Financiers  (France),  June 2005  (see  http://www.amf-
france.org/documents/general/6080_1.pdf). 

results  of 

EN 

15 

   EN 

 
                                                 
Ongoing and Planned Initiatives 

While financial education is primarily a matter for Member States, the Commission 
has already funded some financial literacy initiatives, in the context of its work on 
consumer  protection  and  on  combating  social  exclusion63,  and  believes  that  more 
could  be  done  to  encourage  the  provision  of  high-quality  financial  education.  The 
role  of  the  Commission  could  be,  for  instance,  in  developing  guidelines,  collecting 
and  promoting  best  practices,  or  indicating  new  innovative  approaches.  In 
developing its policies towards financial literacy, the Commission will draw on the 
feedback  from  participants  to  its  Conference  on  financial  capability  held  on  28 
March 2007 and on the findings of a study on financial literacy schemes in the EU 
which it has commissioned and which will be available at the end of 2007. 

Providing the right information at the right time 

(39)  Selecting  an  inappropriate  product  can  have  adverse  consequences  for  retail 
consumers  and  investors  and  the  best  safeguard  against  this  is  good  disclosure  and 
sound information. Good information helps consumers to understand the key features 
of  a  financial  product,  including  the  risks,  potential  returns  and  costs.  However, 
evidence64 suggests that the information provided is often inadequate or too complex, 
making it difficult to compare prices, products and providers and to take an informed 
financial decision. Financial products are subject to different information requirements 
and  therefore  offer  different  degrees  of  protection.  The  Commission  believes  that 
information  needs  to  be  complete,  correct,  clear,  proportionate,  understandable  and 
presented in a timely manner. Information requirements also need to be consistent. 

Ongoing and Planned Initiatives 

The  Commission  has  ongoing  initiatives  to  improve  the  quality  of  information 
provided to consumers in areas such as consumer credit, mortgage credit, investment 
funds (UCITS) and payment services.  

Consumer  testing  will  be  undertaken  to  evaluate  the  relevance  and  usefulness  of 
pre-contractual information in certain areas, such as credit. 

63 

64 

For  instance,  in  2005–2006,  the  European  Commission  funded  the  development  of  the  DOLCETA 
programme,  an  online  training  tool  designed  for  use  by  adult  education  providers.  In  2006,  the 
European Commission funded a study of financial education initiatives across the EU to develop and 
exchange best practice models and new strategies to improve the access to financial services for people 
experiencing  poverty  and  social  exclusion  –  and  especially  over  indebted  people,  which  has  been 
carried out by a consortium of debt-management agencies. This work has facilitated information sharing 
between the organisations involved. 
SEC(2007) 106,  31.1.2007,  p. 67  and  "Eurobarometer  230:  Public  Opinion  in  Europe  on  Financial 
Services", August 2005. 

EN 

16 

   EN 

 
                                                 
In the area of long-term savings and investments, but also possibly in other areas, a 
sector approach to legislation has created a situation where, despite certain products 
being  perceived  as  having  similar  characteristics  by  investors,  they  are  subject  to 
different requirements, notably regarding information disclosure both at the point of 
sale and on an ongoing basis. In moving to ensure that information requirements in 
EU financial services legislation are appropriate and consistent, the Commission will 
launch a cross-sector study in 2008. This will build on the work of the three Level 3 
committees  on  conduct  of  business  (including  disclosure)  rules  across  comparable 
investment products.  

Advising consumers 

(40)  Providing  advice  is  distinct  from  providing  information.  Whilst  information  merely 
describes a product or service, advice implies a recommendation to a given consumer 
to opt for a specific product. When advice is given, it should be objective, based on the 
profile of the customer, and commensurate with the complexity of the products and the 
risks  involved.  This  is  already  required  by  MiFID  for  the  provision  of  investment 
advice  (i.e.  recommendations 
their  personal 
circumstances). For products such as home loans and retirement savings, which have a 
considerable  impact  on  the  financial  situation  of  the  consumer,  consumers  in  some 
countries rely on independent high-quality advice to make appropriate decisions.  

to  clients  must  be  suitable 

to 

(41)  The  Commission  is  giving  increased  attention  to  the  role  of  financial  intermediaries. 
The  market  infrastructure  for  sales  and  distribution  is  not  always  optimal  to  assist 
consumers  in  selecting  sound  and  suitable  financial  products.  For  instance, 
intermediation  for  pensions  currently  differs  on  a  product-by-product  basis  and 
according to "pension pillar"65 classification, although some of the services provided 
share similar characteristics.  

Ongoing and Planned Initiatives 

The  Commission  will  shortly  launch  a  study  on  credit  intermediaries  in  order  to 
analyse  the  EU  credit  intermediation  market,  to  review  the  framework  in  which 
intermediaries  operate  and  to  examine  any  possible  consumer  detriments.  On  the 
basis of this study, the Commission will examine whether it is necessary to propose 
an appropriate European legal framework.  

The Insurance Mediation Directive66 will be reviewed to make sure it is achieving 
its objectives of protecting consumers while promoting the single insurance market. 
As a first step, the Commission has asked CEIOPS to look into the way the Directive 
has been implemented. This report will be used as a basis for a possible revision of 
the Directive in 2008-2009.  

65 

66 

The pensions framework in the EU is commonly characterised by a three pillar structure which is also 
often used during debates and discussions at European level: Pillar 1: statutory social security systems; 
Pillar 2: occupational pension schemes; Pillar 3: voluntary individual pension savings. The three pillar 
typology generally reflects the different legal characteristics of the three pillars, although Community 
texts covering pensions do not refer formally to the pillars.  
Directive 2002/92/EC. 

EN 

17 

   EN 

 
                                                 
The White Paper on Mortgage Credit will address the question of ensuring high-
quality independent advice for consumers. 

5. 

CONCLUSION 

(42)  This Green Paper seeks to strengthen and  deepen our understanding of the problems 
faced by consumers and industry in the field of retail financial services, as well as to 
establish  the  scope  for  and  impediments  to  further  initiatives  in  this  area.  The 
consultation  is  open  until  16 July 2007.  Unless  indicated  otherwise,  all  responses  to 
the 
at 
http://ec.europa.eu/internal_market/finservices-retail/policy_en.htm.  

the  Commission  website 

consultation  will 

published 

on 

be 

(43)  The  Commission  will  organise  a  hearing  on  19 September 2007  to  draw  the 
conclusions  of  the  consultation  launched  by  this  Green  Paper  and  discuss  with  all 
stakeholders  which  initiatives  are  needed  to  bring  about  a  more  efficient  internal 
market for retail financial services.  

(44)  The results of this extensive consultation process will be incorporated into the Single 

Market Review report to be published in the autumn. 

(1) 

(2) 

(3) 

(4) 

Do you agree with the objectives and priorities set out in this paper?  

Are there issues that are not covered in this Green Paper, which are important 
for the integration of retail financial markets and to which the Commission's 
attention should be drawn? For example, are consumers in their everyday life 
confronted  with  requirements  or  limitations  from  either  financial  services 
providers  or  other  stakeholders  (employers,  social  security,  administrations, 
businesses,  etc.)  which  restrict  their  ability  to  use  cross  border  financial 
services (such as an obligation to have a bank account or insurance policy in 
one specific country, etc.). 

The  Commission  has  undertaken  several  initiatives  to  improve  consultation 
with  consumers  and  to  secure  their  input  into  its  policy  making.  Should 
further steps be taken and, if so, what steps? 

Is consumer choice unnecessarily limited by restrictions on the providers and 
channels  through  which  they  access  retail  financial  services.  What  are,  in 
your experience, these restrictions?  

(45)  This  paper  presents  the  actions  currently  being  undertaken  to  bring  the  benefits  of 
integrated  EU  financial  market  to  users,  and  requests  feedback  from  stakeholders  on 
the  direction  being  taken.  However,  building  on  work  to  date,  the  Commission 
believes  that  there  is  scope  for  more  action  to  ensure  that  European  retail  financial 
services markets reach their potential and to ensure that citizens reap the benefits of a 
single  market.  The  Commission  wishes  in  particular  to  receive  feedback  on  the 
following specific issues. 

EN 

18 

   EN 

 
(5) 

(6) 

Despite efforts, in particular the creation of FIN-NET, the handling of cross-
border consumer complaints in the field of financial services still remains 
problematic.  The  Commission  would  welcome  input  as  to  the  ways  to 
improve the current situation. For example, should Member States be obliged 
to  ensure  that  alternative  dispute  resolution  (ADR)  schemes  are  in  place? 
Should  providers  be  obliged  to  adhere  to  an  ADR  scheme?  Should  they  be 
contractually obliged to offer ADR mechanisms to their clients?  

The  creation  of  the  Single  Euro  Payments  Area  (SEPA)  offers  challenges 
and opportunities for businesses and consumers alike. What do stakeholders 
think of SEPA's impact on consumers? Should consumers be more involved 
in the governance and the preparation of SEPA?  

(7)  With view to the launch of its study on credit intermediaries, later this year, 
the Commission would like to know whether stakeholders believe the current 
legislative  framework  to  be  sufficient  and  if  consumers  face  any  particular 
problems in dealing with credit intermediaries, particularly on a cross-border 
basis.  

(8) 

(9) 

The Commission believes that it has an important role to play in developing a 
competitive,  open  and  effective  market  for  long-term  savings,  retirement 
and pension schemes that meet consumers' needs. Do stakeholders agree and 
how  could  the  Commission  contribute?  Could  an  optional  legal  EU-wide 
regime  ("28th  regime")  for  savings  and/or  3rd  pillar  pension  products  be 
envisaged?  

Do  you  think  that  there  could  be  benefits  for  both  banks  and  consumers,  if 
banks  would  have 
to  offer  an  optional  simplified 
standardised  product,  which  would  have  a  good  level  of  consumer 
protection, would be easy to understand, and could be offered across borders 
without the need to be modified to fit local rules? 

the  opportunity 

(10)  The  Commission  believes  that  more  could  be  done  to  improve  consumers' 
financial  literacy  and  capability.  Possible  measures  include  developing 
guidelines  or  promoting  best  practices.  The  Commission  would  welcome 
input on how this policy should be further developed at the European level. 

(11)  Do  you  think  that,  as  they  stand,  the  provisions  on  consumer  information 
contained in financial services directives are adequate and consistent with one 
another?  Were  it  not  the  case,  how  could  the  Commission  ensure  that 
information  requirements  are  set  at  the  right  level,  ensuring  proper 
information but without creating any overload? Do you think that informing 
consumers is sufficient or that advice should also be provided? If yes, should 
that be compulsory or on request?  

EN 

19 

   EN 

 
(12)  Measures  to  improve  lenders'  access  to  credit data  will  be  discussed  in  the 
context  of 
the  forthcoming  White  Paper  on  Mortgage  Credit.  The 
Commission believes that more could be done to promote the accessibility of 
credit data, in particular on a cross-border basis. Who should be able to access 
consumer credit data? How could the cross-border transferability of consumer 
credit data be improved, ensuring in particular that mobile credit data follows 
increasingly  mobile  consumers?  Could  a  memorandum  of  understanding, 
ensuring  smooth  data  circulation  between  credit  bureaus,  be  a  workable 
solution?  

(13)  Fragmentation of retail insurance markets, for example in the field of motor 
insurance, does not allow consumers to reap full benefits of EU integration in 
this area. Do you think that more should be done at EU level to address this 
fragmentation? 

(14)  Customer mobility and competition are closely associated. The Commission 
would  welcome  input  as  to  how  customer  mobility  could  be  enhanced.  In 
particular,  in  the  field  of  bank  accounts,  and  as  a  follow-up  to  the  Expert 
Group's work, would stakeholders see merits in, for example, having EU wide 
account  switching  arrangements?  Will  SEPA  have  an  impact  on  customer 
mobility?  

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