2017年-EBA欧洲银行管理局_BSG_response_to_EC_Consultation_on_Transparency_26_fees_in_EU_Cross_Border_Transactions_30_October_2017_29页_214kb

Summary of the European Commission Public Consultation on Transparency and Fees in Cross-Border Transactions in the EU

Core Content

The European Commission launched a public consultation to gather opinions on the transparency and fees associated with cross-border transactions in the EU, particularly those involving currencies other than the euro. The consultation aimed to improve choice, transparency, and competition in retail financial services and to support the development of a more integrated internal market.

The main focus is on the cost and transparency of transactions in non-euro currencies, as well as the potential for EU-level regulation to standardize these fees. The consultation included several questions addressing the pricing models, fee structures, and the impact of regulatory measures on consumers and market participants.

Main Points and Key Information

1. Current Situation of Cross-Border Transactions

• SEPA Framework: The Single Euro Payments Area (SEPA) has significantly reduced the cost of cross-border euro transactions by introducing standardised processes and prohibiting IBAN discrimination.
• Non-Euro Transactions: These remain expensive and opaque, with fees often higher than domestic transactions in the same currency. This is attributed to higher intermediary involvement, complexity, and fixed operational costs.
• High Minimum Fees: Many non-euro transactions have minimum fees that make small transfers disproportionately costly.
• Currency Conversion: Dynamic currency conversion (DCC) is often criticized for lack of transparency and potentially unfair pricing practices.

2. Proposed Actions

• Action 1: The Commission plans to amend Regulation 924/2009 to reduce charges for cross-border transactions in all Member States, not just eurozone ones.
• Action 2: A review of DCC practices will be conducted to determine the best way to ensure consumers can choose the most competitive exchange rate.

3. Stakeholder Participation

• The consultation is open to all stakeholders, including individuals, companies, public authorities, and experts.
• Two versions of the questionnaire are available: a simplified one for non-experts and a full version for experts.
• Only responses submitted through the online questionnaire will be considered for the final report.

4. Key Questions and Findings

Question 1: Non-Euro Transactions

• Fee Transparency: Stakeholders are divided on whether fees are transparent. Some argue that information is available, while others claim it is incomplete or confusing.
• Examples of Fees: Some members reported fees ranging from 0.25% to 1% of the amount, with minimum and maximum fees also applied in some cases.
• Regulation Debate: There is a split on whether the EU should regulate these fees. Some support EU-level regulation to ensure fair pricing, while others prefer market dynamics to determine costs.

Question 2: Extending Regulation to All Currencies

• There is support for extending Regulation 924/2009 to all Member States' currencies, ensuring that cross-border transactions cost the same as domestic ones.

Question 3: Ad Valorem Pricing

• Some members believe ad valorem pricing reduces costs for low-value transactions and reflects internal costs.
• Others argue that ad valorem pricing is not justified due to fixed costs and can lead to unfair profit margins for PSPs.

Question 4: Minimum Fees

• Minimum fees are seen as a barrier to low-value transactions.
• There is debate on whether these fees should be regulated to avoid disproportionate costs and how such regulation should be structured.

Question 5: Mandatory Fee Caps

• Some members support fee caps to prevent excessive charges, while others fear it could lead to increased ad valorem rates or reduced competition.

Question 6: Market Solutions

• Market practices such as using internet or mobile banking, increased competition, and new technologies like blockchain and Swift CGI are seen as potential solutions.
• Encouragement of these practices is supported by some, with suggestions for fiscal incentives or reduced profit tax.

Question 7: Cost Determinants

• Factors like correspondent banking fees, SWIFT fees, and currency conversion fees are significant contributors to the cost of non-euro transactions.
• There is a call for uniform cost structures and transparency across all Member States.

Question 8: Further Comments

• Some stakeholders argue that the issue is not cross-border vs. domestic, but rather Euro vs. non-Euro transactions.
• They highlight the benefits of Euro Clearing and Settlement Mechanisms (CSMs) in reducing costs and increasing efficiency.

Euro Transactions in Non-Euro Countries

• Euro transactions in non-euro Member States are often more expensive than domestic euro transactions, despite the availability of similar infrastructures.
• Examples of high fees have been cited, such as 48 Euros for a 10 Euros transfer to Hungary or 50 Euros for a 79 Euros transfer to the Netherlands.
• There is a debate on whether the EU should regulate these fees or leave them to the market.

Question 9: Regulation of Euro Transactions

• Some stakeholders believe the EU has already regulated these transactions through Regulation 924/2009, but others argue that more intervention is needed to address market distortions.

Conclusion

The consultation highlights the need for greater transparency and fairness in the pricing of cross-border transactions, especially those involving non-euro currencies. While some stakeholders support EU-level regulation, others prefer market-driven solutions. The proposed actions aim to address these issues by extending the scope of existing regulations and improving the clarity of fee structures for consumers. The final decision on regulation will depend on the analysis of stakeholder responses and the assessment of market dynamics and potential impacts.