Aemip se encuentra entre las asociaciones europeas que solicita la participación en el grupo de trabajo para la revisión de la directiva de crédito de la Comisión Europea, mediante la siguiente carta:
We write to you as a group of national associations representing digital consumer lenders across four EU Member States to welcome the ongoing evaluation of the Consumer Credit Directive (CCD).
We represent over 100 digital lenders in four countries, many of whom operate across as many as a dozen countries within the EU.
Around the time of the CCD’s launch, digital lenders, often serving citizens whom established financial services providers had overlooked, began by lending small sums for short terms. In the years following the introduction of the CCD in 2008 we have seen technology, consumer demand and regulation change rapidly at the Member State level.
Digital lenders, including our members, have developed into experienced and capable institutions.
Our ability to lend responsibly while extending access to credit has developed in line with improved credit scoring and risk assessment.
So far Member States’ approaches to regulation have varied widely, ranging from carefully crafted, evidence-based measures seeking to optimise the regulatory framework to the introduction of snap regulations driven by immediate political pressures. Local interpretation of the CCD also varies, making it more difficult to enter into and bring competition to new markets. Today small sum, cross-border lending is almost impossible.
In this context and in light of the upcoming revision of the CCD, our members are keen to advocate for balanced European regulation that protects consumers, bolsters competition and recognises a viable lending market for smaller borrowers.
Our members have a wealth of experience operating across European markets. They are familiar with the local interpretations of the CCD and the interplay between local regulations and the Directive.
Given this experience, we would welcome opportunities to share our expertise with the Commission, for example by participating in relevant expert groups or other suitable fora.