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DLA Contributes to the Consultation on the CCD3 Transposition Draft Bill

The German Federal government initiated a consultation on a draft bill transposing the revised Consumer Credit Directive. We welcome the draft in large parts but have a number of comments.

Our support of the draft bill applies, for example, to

  • the limitation of the right of withdrawal for consumers,
  • the easing of formal requirements for the conclusion of loan and loan brokerage agreements, and
  • the extension of the scope of the protective provisions to short-term loans and loans under EUR 200 and the associated obligation to carry out a creditworthiness check.

However, the draft bill also contains provisions that, in the opinion of DLA, are unclear or unduly restrict lending business in Germany – Europe’s largest market for consumer loans. Please have a read of our statement here (in German only).