On 8 August 2023, the European Banking Authority (EBA) issued a report following a mystery shopping exercise into personal loans and payment accounts. The mystery shopping exercise supplemented the EBA’s earlier thematic report on fees and charges that was published at the end of last year.

Among other things the mystery shopping exercise found that within the confines of the sample of financial institutions covered, the conduct of some of them was inadequate and needs to improve. For example, some financial institutions did not provide the required pre-contractual information to consumers, and automatically increased the total amount of credit to include bank fees without collecting the customer’s explicit consent. More specifically, for personal loans, many financial institutions did not use the first visit of the mystery shoppers to provide pre-contractual information such as the Standardised European Consumer Credit Information that is foreseen by the EU Consumer Credit Directive. As for payment accounts, the mystery shopping exercise revealed that, during onsite visits, 63% of financial institutions included in the sample did not provide the fee information document to mystery shoppers.

The report sets out certain actions that Member State competent authorities may consider. These include:

  • Communicating with financial institutions on the lack of information provided to consumers using digital channels in some countries and on the importance of adopting a consistent approach to the provision of pre-contractual information both, onsite and online, across branches and across different distribution channels of the same institution.
  • Investigating further the conduct of some financial institutions regarding the practice to automatically increase the total amount of the credit to include bank fees without collecting explicit consent from consumers, or the provision of information related to specific requirements (opening a bank account, mandatory insurance) to get the loan.
  • Investigating further the conduct of financial institutions regarding the provision of pre-contractual information documents for personal loans in ‘good time’ and the fee information document for payment accounts.

The EBA also states that the exercise has shown that mystery shopping is a useful complementary tool for supervisory authorities to fulfil their supervisory and/or enforcement objectives, and to gather information about financial products and services and/or the conduct of financial institutions towards consumers.