UK firms have been free to implement the MCD from 21 September ahead of the 21 March 2016 deadline, but Bertalot said Finland, Latvia, Portugal, Slovenia and Malta may need more time – with most of them aiming to be operating under the directive between four to eight weeks after the deadline.
He said: “First place therefore goes resoundingly to the UK.
“But, to be fair to the rest of the EU, UK firms had something of a head start when it came to transposing the MCD, since the Mortgage Market Review, implemented in April last year, went beyond many of the core provisions of the directive.”
Bertalot predicted the European Commission publishing a green paper on the future of retail financial services.
He added: “While member states are still, in many cases, wrestling with transposition and interpretation of the MCD, the European Commission is already moving on.
“Its retail financial services policy objective for the present mandate is further to strengthen consumer protection.
“That would continue the work already undertaken by the last commission in response to the financial crisis, to which the MCD was also considered part of the response.
“The authorities are increasingly turning away from an agenda driven by financial stability to one emphasising consumer and investor protection
“This objective will soon manifest itself – probably by the end of the year – in the form of a green paper on the future of retail financial services. Potentially, it will have a broad reach, including digitalisation, cross-border lending, debt advice and access to redress, among other issues.”
