Price caps

Even though most DFS competition issues are not related to price, authorities should remain vigilant to this aspect when the service requires any type of payment on the part of the consumer and excessive charging is observed, such as in uncollateralized loans originated in digital platforms. Signs pointing at this practice can come from complaints, whistleblowing or market studies. National authorities may consider leveraging financial consumer protection elements to address unfair fees and charges, opaque and complex pricing structures, etc., including:

1. strengthened product design requirements
2. strengthened unfair terms requirements which internationally typically includes coverage of terms that imposes fees and charges excluding the upfront/core price of the product, provided it is transparent
3. as a final resort, it is sometimes necessary to specify restrictions/prohibitions on specific fees and charges that are clearly unfair (e.g. account closure fees that can prevent product switching, excessive default fees and charges etc.)