DEUTSCHE BANK RESPONSE TO THE REPORT OF THE EXPERT GROUP ON CUSTOMER MOBILITY IN RELATION TO BANK ACCOUNTS

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1 Deutsche Bank Dr. Bernhard Speyer/Dr. Stefan Schäfer Deutsche Bank AG/DB Research P.O. Box Frankfurt, Germany Tel. +49 (0) Fax +49 (0) DEUTSCHE BANK RESPONSE TO THE REPORT OF THE EXPERT GROUP ON CUSTOMER MOBILITY IN RELATION TO BANK ACCOUNTS Deutsche Bank welcomes the opportunity to comment on the report of the expert group on customer mobility in relation to bank accounts. We share the expert group s view that customer mobility is one of the factors determining the intensity of competition and therefore is an important prerequisite for well-functioning retail banking markets, both at the national and EU levels. Thus, it is worthwile to analyse whether there are obstacles to switching from one bank to another and to cross-border opening of bank accounts. Yet while the Commission and some members of the expert group attach equal importance to competition in both national markets and across borders, we think that European policy makers should focus on removing obstacles to cross-border opening of bank accounts, because, according to our analysis, in the domestic context switching from one bank to another ( domestic switching ) is very easy already. 1. General comments on competitive conditions in retail banking markets: High transparency, rising competitive pressures, satisfied customers Regarding the intensity of competition in national retail banking markets, we would like to highlight some basic facts: In general, price transparency is already high. SEPA and innovation will raise competitive pressures in the payments markets further. By and large, customers are very satisfied with their banks, as many studies, some of them cited in the expert group report, prove. Therefore, we doubt that there is any need for action with regard to domestic switching. Against this background, we consider that broadening the information base on which the Commission assesses the intensity of competition would provide evidence for our above mentioned observations and would, thus, prove to be very helpful for the discussion. We therefore explicitly support recommendation 1 regarding commissioning a pan-european study to determine in detail how the search and choice process for bank accounts occurs in practice. This study could make a very valuable contribution to deepening our understanding of how banks and customers behave on the market for bank accounts. We are convinced that it will reveal the high satisfaction of European customers with their banks and with the bank switching process. Deutsche Bank response to the report of the expert group on customer mobility in relation to bank accounts, page 1 (5)

2 2. Our view on the consumer: mature citizen who freely chooses products and services The deliberations on customer mobility should be built on the assumption that consumers are mature citizens who freely choose products and services and should therefore take full responsibility for their actions. As a result, EU retail banking policy should be exclusively geared towards correcting market imperfections. It must not aim at stipulating market results, but at putting into place a well-functioning market environment. Consequently, the freedom of contract should only be compromised to the smallest extent possible. Specifically, as regards customer mobility in relation to bank accounts, this implies: The status quo of switching from one bank to another should be seen as the outcome of the free and deliberate interaction of market participants. Hence, legislative or regulatory action shoud only be taken in case of proven market imperfections. When pondering policy measures, EU authorities should not aim at increasing the number of account switches as an aim in itself. Instead, market imperfections should be removed so that customers are free to choose whether they want to switch banks or not. All measures proposed should be subjected to a thorough cost-benefit analysis before being implemented. 3. Domestic switching is easier than people might believe The expert group identifies four potential obstacles to domestic switching, all of which we do not believe to be convincing arguments for further Commission action. Information asymmetry and intransparency of prices: In our view, information asymmetry and intransparency of prices are in general low or even non-existent and therefore do not impede domestic switching. As said above, we are nevertheless sympathetic to recommendation 1 on page 23, which recommends that the Commission consider commissioning a pan-european study on the actual search and choice process for bank accounts. Regarding recommendations 2 to 9 on pages 24/25, we take up a more sceptical stance. Our position is: The currently existing broad range of products (with product features ranging from basic to complex) results from free decisions of both financial services providers and their customers acting in a competitive environment. Thus, it reflects consumer preferences and is not an impediment to competition, but its consequence. In spite of the complexity of some product offerings, price transparency is already very high due to far-reaching consumer information regulation (in Germany: Preisaushang list of prices to be displayed in each branch) and due to innovative price-comparison providers. Regarding the latter, the use of the internet is an important factor in overcoming information asymmetry, as the cost of comparing prices has decreased significantly. In case European policy makers impose additional information duties on banks, the information provided could be excessive so that consumers feel overloaded and, in the end, use less instead of more information. If consumers profess to be insufficiently informed still, this could well reflect rational ignorance, because banking cost is insignificant compared to other expenses of average households, so that search costs are not considered commensurate with potential benefits. Bundling and tying: Like the broad range of product offerings, combined product offerings result from free decisions made by households and banks. Again, complexity is not an impediment to competition, but its result. The issues of tying and bundling should therefore be left to competition between banks striving for consumer approval. Correspondingly, we are sympathetic with recommendation 4 on page 27, while we reject recommendations 1-3. Deutsche Bank response to the report of the expert group on customer mobility in relation to bank accounts, page 2 (5)

3 Closing charges: The part of the expert group report dealing with closing charges will become irrelevant, once the Payment Services Directive (PSD) takes effect, because the PSD forbids closing charges. Apart from that, we think that the pricing of products should be left to competition between banks. We therefore dismiss recommendations 1 and 3 on page 34. Yet in order to raise transparency, we consider recommendation 2 a good proposal. It recommends that charges for closing products related to current accounts be clearly indicated ex ante in the relevant agreement. A provision of this kind would enable consumers to explicitly take closing charges into account when choosing a provider for their bank account. Administrative burden: According to a Eurobarometer survey, seven out of ten EU citizens believe they can easily switch from one bank to another. Regarding those who disagree, one has to differentiate between the administrative burden preceived in advance of switching on the one hand and the experience of those customers who actually have switched. In fact, a recent Deutsche Bank customer survey reveals that two-thirds of respondents deem switching from another bank to Deutsche Bank much easier than expected beforehand or easier than expected beforehand. Another 23% perceived it as as easy as expected beforehand. only 4% of all respondents complain about a lack of support from their former bank, or about a lack of cooperation between their former and their new bank. Accordingly, 96% of all customers switching to Deutsche Bank think that when customers switch from one bank to another, both banks cooperate in order to alleviate the process. 95% of all respondents agree with the statement Opening an account at Deutsche Bank was easy and smooth. about 70% of all respondents assessed Deutsche Bank s support in changing transfer orders and informing recipients of direct debit payments as very good. For people familiar with European retail banking markets, these results are unsurprising. Due to the high intensity of competition banks that (intend to) acquire customers have a strong economic interest to offer far-reaching account switching guides and/or services to potential customers. Therefore, we support recommendation 1 on page 31: Facilitation of customer switching should indeed be left to competition between banks. Accordingly, we oppose recommendations 2 to 5. As regards recommendations 6 (automatic reply messages) and 7 (easier rerouting of payment transactions), it needs to be pointed out that banks would not be able to provide such services at reasonable cost; a thorough cost-benefit-analysis of these recommendation is therefore likely to reveal a substantial negative result. In contrast, we agree with the group regarding recommendations 8 and 9. As to remedies for the asserted difficulties in switching from one bank to another, we are especially sceptical towards account number portability, because, for historical reasons, numbering bank accounts is based on differing logical systems. Therefore, account number portability technically is virtually impossible. If at all, it is not realisable at reasonable cost. Furthermore, introducing portable account numbers would mean that the current IBAN and BIC standards which have just been agreed upon as the standards for the SEPA format would have to be replaced. The Commission itself states in the impact assessment of the PSD: the recently introduced EU-wide IBAN- BIC numbering system is not compatible with the portability of account numbers without incurring disproportionately high costs and provoking problems for efficient straightthrough processing. We therefore dismiss recommendation 10 on page 33. Deutsche Bank response to the report of the expert group on customer mobility in relation to bank accounts, page 3 (5)

4 4. Digital signature would facilitate cross-border opening of accounts significantly Legal and regulatory obstacles In contrast to domestic switching, Deutsche Bank certainly sees a need for action regarding cross-border opening of accounts. The problems related to opening a bank account abroad touch upon difficulties that are common in the process of integrating EU retail banking markets. Similar to other segments of retail banking, legal and regulatory barriers make the cross-border opening of accounts difficult for both banks and customers. Banks are obliged to apply a variety of know your customer -rules (KYC rules), among others anti money-laundering rules and tax rules, when opening an account. In case of cross-border clients, this is especially difficult, because ascertaining a customer s identity on a remote basis is complicated. We therefore endorse both of the recommendations made on page 35. Information barriers and uncertainty Similarly, extensive KYC rules make it difficult for customers to open an account abroad, because it is difficult for them to obtain information not only about the offers, but also about what documents they need to provide. After having found this out, customers have to submit their choice of product and the KYC-related information and documents to the bank at which they want to open an account. If this required face-to-face contact with the bank, they would possibly have to bear high travel costs. Therefore, setting the legal framework for a KYC-compliant digital signature scheme at the European level is an essential measure both banks and consumers would materially benefit from. Against this background, Deutsche Bank explicitly supports recommendation 5 on page 37, according to which the Commission should look into this issue in more detail. Similarly, we endorse recommendation 2. At present, credit bureaus provide crossborder credit status reports on the basis of bilateral agreements, but such agreements are not in place everywhere in the EU. In many cases foreign banks have no possibility at all to obtain information about clients creditworthiness. This is a serious obstacle to cross-border offerings of financial services as well as to pan-european business processes. As to the other recommendations made to tackle information-related barriers to crossborder opening of accounts, we reject recommendation 1 (the promotion of bank websites in more than one linguistic version), because we think it should be left to competition between banks, whether and how banks try to acquire customers residing abroad. As far as recommendations 4 (prohibition of any administrative requirements which could be considered as discrimination under EU law) and 6 (use of tax identification numbers as a direct proxy for residence under the Savings Tax Directive) are concerned, we think that such far-reaching proposals should in accordance with better regulation principles only be made if a thorough cost-benefit analysis has proven a solid net benefit of implementing them. Commercial decisions by banks In addition to legal and regulatory barriers and information barriers and uncertainty, the expert groups lists commercial decision by banks as a potential obstacle to crossborder opening of bank accounts. This gives rise to concerns. It must be realised that the competitiveness of the EU financial industry is a legitimate and important objective with a view to ensuring that the financial sector can play its role in fostering growth in the EU, and to increasing the EU s international competitiveness. Moreover, financial institutions will only engage in cross-border business, will only develop pan-european business strategies and will only offer a wide range of competitively priced products if it is commercially attractive to do so. Hence, we welcome initiatives geared towards facilitating cross-border retail banking business, provided that such initiatives are based on sound economic principles that respect the interests of banks to be profitable. The recommendations made in order to remove wrong Deutsche Bank response to the report of the expert group on customer mobility in relation to bank accounts, page 4 (5)

5 decisions by banks as an obstacle to cross-border opening of accounts do not meet this requirement. As stated above, we are convinced that whether and how banks decide to serve customers residing abroad should be left to competition between banks. Therefore, we reject recommendation 3 on page 39. There is no need to grant customers a legal right to have a basic bank account. When deciding on whether to offer bank accounts to customers residing across borders, banks have to take the expected cost-benefit-ratio of such offers into account. Linguistic diversity will prevent banks from offering cross-border services in every branch. Instead, they will employ targeted platforms, like special branches in border regions, multi-lingual online services, or, dedicated desks (e.g. German, British etc.) in tourism regions which attract a high number of second residences. As to recommendation 1 on page 38 (suggesting that consumers be provided with information at EU level about banks which offer cross-border services), we are sceptical as to whether more information really makes consumers better informed. The compromise on the consumer credit directive shows that emphasising information duties too much can lead to a excessive burden both on banks (because they have to provide it) and on customers (because they have to cope with it). If consumers are provided with too much and too detailed information, average customers will feel overpowered by a deluge of information and will refrain from using any of it. As a consequence, they would use less instead of more information. In contrast, we think that following recommendation 2 on page 38 (investigation into the causes of why banks in some Member States possibly do not offer accounts to customers from other Member States at all) might shed light on legal and regulatory barriers that prevent banks from offering accounts abroad. Also, in the field of private international law and rules on conflicts of law, the current discussion on Art. 5 of the proposal for a Rome I Regulation (law applicable to contractual obligations) and its impact on cross-border account opening need to be taken into account. Should the text of the Commission proposal be adopted (entailing that to most crossborder consumer contracts, the law of the habitual residence of the consumer would apply) and should no particular exemption be foreseen for financial services, then we fear that banks will not be inclined to offer any cross-border account opening at all. Under the proposed rule, a bank willing to serve customers from all EU member states would have to comply with 27 consumer protection rules depending on the country a customer willing to open an account resides in. In the end, banks would, in particular, probably stop offering their products to customers from smaller member states, because doing business with this customer segment would promise only limited revenue while it would involve considerable (fixed) costs. Deutsche Bank response to the report of the expert group on customer mobility in relation to bank accounts, page 5 (5)

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