BCCI’S POSITION ON THE DRAFT BILL ON AMENDMENT AND SUPPLEMENT TO THE CREDIT INSTITUTIONS ACT (NО 154-01-7)
After a meeting with the sponsors of the Draft Bill on Amendment and Supplement to the Credit Institutions Act (Nо 154-01-7) at the National Assembly, BCCI President, Mr. Tsvetan Simeonov submitted the Chamber’s POSITION on the Bill.
We offer to you attention the full text of the POSITION PAPER, which was sent to the MPs from the Parliamentary group of Political Party GERB in the 41st National Assembly – Mr. Evgeni Stoev, Mr. Stefan Gospodinov and Mr. Dian Chervenkondev. A copy of the position paper was sent to the President of the Association of Banks in Bulgaria, Mrs. Violina Marinova.
DEAR MEMBERS OF PARLIAMENT,
The Bulgarian Chamber of Commerce and Industry (BCCI) thanks you for the opportunity to get acquainted with your idea and supports your intention to improve the regulation by amending the Credit Institutions Act. We expect these changes to ease the business by regulating the possibility for early repayment of bank loans, without penalty charges to be imposed.
It is possible to expect that the removal of the early repayment penalty will stimulate the competition between banks and will encourage them to follow the market principles when offering to the users of credit products, both companies and citizens, more favourable conditions. In this sense, the proposed changes may be useful both for the customers and the banks.
BCCI would like to propose to the sponsors of the draft bill an evaluation of the impact of the proposed changes to be carried out with regard to the other party (the banks) as well, and in particular, an evaluation of the effects of the new law on the already existing legal relations. We consider that the regulation should be applied for the future, because the banks will attack the eventual retroactive power of the regulations, due to infringement of the principle of non-retroactivity of laws and regulations, which worsen (make less favourable) the position of civil subjects.
In our opinion the removal of restriction for credit refinancing should also be regulated. This could be a positive measure for the business and would probably encourage competition.
In our opinion a wider discussion of the proposed legal changes is needed, with the participation of representatives of the Association of Banks in Bulgaria as well as representatives of other organizations and experts, and we express our readiness to take part in such discussion.