The EBA has issued an Opinion directed to the EC, setting out recommendations to revise the scope and consistency of disclosure requirements in EU law to take account of the increasing use of digital marketing channels.
The Opinion follows a detailed analysis conducted by the EBA into disclosure rules. Matters addressed by the recommendations include:
- the timing of disclosure,
- the presentation format and accessibility of information,
- advertisements,
- pre-contractual information,
- rights of withdrawal,
- complaints handling and
- post-sale information.
The EBA proposes that, in advance of the development and adoption of a revised Distance Marketing of Financial Services Directive, appropriate NCAs may wish to consider adopting the proposals set out in the Opinion.