3.20 Article 32(5) of CCD2

Unique Reference Number: 
DFIN-C8-3
Status: 
Submitted
Author: 
BPFI

3.20 Article 32(5) of CCD2

No. Imposing restrictions on the payments from a consumer to a creditor or a credit intermediary prior to the conclusion of a credit agreement may result in unintentional consequences.

We would welcome greater clarity regarding the obligations under this Article as it is unclear regarding the scope of such payments i.e., are such payments intended to refer to fees and charges, repayments or deposits that may be paid to credit intermediaries e.g., in the case of leasing agreements?