Works on amending the act on financial market supervision, the Bank law and some other acts are underway. The amendment involves a.o. regulating the consumer loan market to a greater degree than is the case with legal regulations currently in force. The direction of changes suggested by the government is good, but some of the proposed solutions require significant corrections.
Many practical complications could result for example from the definition of a loan institution included in the draft. The Ministry of Finance did not account for the fact that the income structure of a company can change very dynamically.
Developments in the last few months clearly show that establishing the limit of interest for a delay in loan payment at a level of six times the NBP lombard rate can be very dangerous. We have been dealing with deflation for over half a year and in the comings months the Monetary Policy Council may turn to quite radically measures. One cannot rule out a situation similar to many other countries where interest rates were cut to zero or even to a negative level. If that were the case, many clients could give in to the temptation of not paying their loans back, as the fines for failure to do so would be very mild.
These are only some of the shortcomings which were indicated by Employers of Poland in the Organization’s comment on the amendment presented to the Ministry of Finance. We hope that the government will consider the objections of social partners and will adapt proposed changes to the realities of business practice.