The German Banking Industry Committee (GBIC) has contributed to the public consultation and the call for evidence by the European Commission. The provisions of the Mortgage Credit Directive are considered to be still essentially suitable for ensuring a high level of consumer protection in the mortgage credit sector. Where changes in the market – especially in connection with digitalization – or practical experience necessitate adjustments to the directive, such adjustments should be made in a careful and targeted manner. This process should primarily be guided by pragmatic consumer protection considerations.
