The European Association of Co-operative Banks (EACB) welcomes the opportunity to respond to the EBA consultation on Technical Standards on standardised terminology and disclosure documents under the PAD.
The EACB acknowledges the challenges encountered by the EBA in assessing and identifying the most common services among 28 national lists, which differ significantly in both the number and type of services. This is compounded by the fact that the Payment Account Directive (PAD) does not clarify which activities specifically constitute a ‘service’ in the context of the Directive
It is particularly appreciated that the EBA has set out the different approaches and their respective pros and cons with the aim to ensure that all Member States understand the difficulties and benefits of various approaches
Among the various topics raised in the EACB position document, it is worth mentioning the EACB’s concerns relating to the services that co-operative banks offer as part of a package and the level of detail in the draft Implementing Technical Standards of the Fee Information Document and the Statement of Fees.