Submission on Mortgage Credit Regulation in the EU

Our simple view would be that a consumer about to enter into the most significant financial transaction of his or her life should have the maximum amount of information at his or her disposal before the contract is concluded. How mortgage credit is defined is also critical here. We note that the glossary at the back of the Commission's green paper on mortgage credit in the E.U defines 'mortgage backed security' as 'Debt instruments collateralized by residential, commercial or industrial real estate mortgages'.

Thus, it would appear that any loan agreement that involves the deposit of the title deeds of real property as security for a loan is covered in the Commission's thinking, including first legal mortgages used to finance the purchase of property, refinancing, equity release and loan consolidation.