The members of the European Association of Co-operative Banks (EACB) answered to the public consultation of the European Commission on the review of the Mortgage Credit Directive (MCD).
In general, we believe that the directive has performed well and does not require an in-depth revision. Technologically neutral approach of the MCD allows the rules to adapt to new technologies and consumer expectations. Should the MCD be amended, focus should be on addressing the new market entrants, the information overload, and digitalisation.
Furthermore, it appears that the Commission is looking into the concept of green mortgages. The Co-operative banks emphasise that any possible definition for a green mortgage should be based on the EU Taxonomy criteria, whereas the MCD revision should not be the place to consider such.
We kindly invite you to look into our consultation answer for more details.