Please find the amendments below, which we submitted as our contribution to the legislative process on the European Commission´s proposal on the directive for comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features (see the proposal at: http://bit.ly/102SS7p).
The Commission proposal is a good starting point for our work, specifically the right for a basic payment account is a crucial step towards improved access to the European Common Market. Nevertheless, the proposal leaves considerable room for improvement, which we want to exploit through our amendments, aiming at the following key points:
Better participation in the Single European Market
People who are not EU residents, but who legally reside in Europe, such as homeless people, asylum seekers or non-EU foreign students are often confronted with obstacles, if they want to open a payment account. Therefore, these people should be allowed to open a basic payment account enabling them to participate in financial services and thereby to benefit from the European Common Market. The crucial precondition for a successful implementation of the Single Euro Payment Area. (SEPA) is that people have access to a bank account. Furthermore, the basic bank account should provide an appropriate range of services to allow people to satisfy their daily requirements in regards to financial services, such as withdrawal of cash and the execution of standing orders, direct debits as well as credit transfers.
Increased consumer protection and fair competition
In our opinion every owner of a payment account should benefit from increased transparency on prices and characteristics of bank account services. Comparison websites, as proposed by the European Commission can be an effective tool to achieve this aim and simultaneously foster competition. However, it is necessary to take into account the more service-oriented business models of social economy, cooperative and savings banks in this process, to promote competition, which is not merely focused on cheap prices but also on fostering the quality of these financial services.
For our amendments submitted on the Payment Accounts Directive see: http://bit.ly/1dhWab6