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This might lead to unjustified variations in the known degree of customer security across various portions of this credit rating areas.

Whilst the European Commission aims to attain a much much deeper and safer solitary marketplace for credit rating (European Commission 2017a, para. 2.6), at the moment, there’s absolutely no coherent policy that is EU when it comes to addressing consumer overindebtedness. Footnote 93 particularly, the Mortgage Credit Directive adopted post-crisis has departed through the usage of approach that is credit-oriented of credit rating Directive and introduced more protective guidelines made to avoid customer overindebtedness. In specific, this directive provides for the borrower-focused responsibility of loan providers to evaluate the consumer’s creditworthiness and imposes limits on specific cross-selling methods. You can concern, nevertheless, as to what extent the fundamental variations in the degree of customer security between your two directives are justified, given that issues of irresponsible financing occur not only in secured but additionally in unsecured credit areas, especially those related to high-cost credit.