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BackAK basically welcomes the initiative of the Commission to regulate credit agrements relating to residential property. It is concerned, however, about this task being done at the current time and under time pressure. Many Member States, including Austria, introduced new regulations for credit agreements relating to residential property while implementing the Consumer Credit Directive about one year ago. In Austria, all essential provisions apply equally to consumer credit agreements and residential property credit agreements with the exception of the right of withdrawal.
In any new regulations for credit agreements relating to residential property, AK thinks special attention should be paid to modelling the terms and formulations as closely as possible on the Consumer Credit Directive. AK has grave concerns about the proposed provisions on data protection. “Responsible borrowing” is one principle the proposed directive is seeking to anchor. AK believes the suggested provisions could lead to the introduction of unrea-sonable duties and penalties for consumers. <br />
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Christian Prantner
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Benedikta Rupprecht
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