The German Federal Financial Supervisory Authority has proposed extending the competence requirements for internal and external credit institution staff involved in mortgage consumer lending to staff engaged in general consumer lending. The draft implements amendments to the German Banking Act arising from the revised EU Consumer Credit Directive and would apply corresponding requirements to lenders covered by the Sales Financing Supervision Act. Staff working on general consumer loans would need current theoretical and practical knowledge of the applicable legal framework, creditworthiness assessments, relevant products and ancillary services, collateral valuation and advisory services. Competence would have to be demonstrated through qualifications, employment references, training records or other suitable evidence. Recognized professional qualifications would generally cover both general and mortgage consumer lending, although certified financial services advisers working on mortgage consumer loans would also need at least two years of relevant professional experience. The amended regulation would take effect on the day after promulgation, while the underlying statutory extension is due to apply from Nov. 20, 2026.
German Federal Financial Supervisory Authority launches consultation on extending staff competence rules to general consumer loans
The German Federal Financial Supervisory Authority has proposed extending existing mortgage consumer lending competence standards to internal and external staff involved in general consumer lending. Staff would need current knowledge across lending law, creditworthiness assessments, products, collateral and advice, supported by suitable evidence of competence.