Lausunto

Consultation on mortgage credit directive

In Finland, the Mortgage Credit Directive (MCD) has been applied since the beginning of 2017 and the provisions concern long-term financing. In Finance Finland’s view, it is too early to fully review the directive because its application currently seems balanced and, for example, certain points have not yet been sufficiently tested in practice.

However, should the MCD be amended, Finance Finland proposes rather limited legislative amendments that would especially focus on the simplification of the requirements of the provision of customer information. The emphasis should primarily be on avoiding information overload and improving the way customer information is provided in order to ensure the supply of mortgages also through digital channels. Legislation should provide appropriate mechanisms to ensure end-to-end fully digital mortgage credit agreements.

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