The European Association of Co-operative Banks (EACB) welcomes the opportunity to respond to the European Supervisory Authorities’ (ESAs) preliminary high-level assessment on ‘the Use of Big Data by Financial Institutions’. We appreciate the ESAs’ efforts to identify risks and benefits of the use of Big Data for consumers and financial institutions.
We recognise that the ESAs’ Discussion Paper is generally fairly accurate and complete. However – and as also stated by the ESAs – the current regulatory framework, with several horizontal data protection and consumer protection requirements and sectorial financial legislation, already addresses the topic of Big Data, although indirectly. Co-operative banks believe that the current legislative instruments are flexible enough to cover Big Data and to promote consumer protection and the safety and soundness of markets.
Co-operative banks urge that, as far as credit institutions are concerned, the focus should be on the implementation of the existing regulations and that regulatory requirements should not create new barriers or a distortion of competition. It is also important that banking supervisors do not create new, special and restrictive requirements concerning the use of customer data by financial institutions. There must be a level playing field in the use of customer data by Fintechs, banks and other market participants.