The EBA’s recent mystery shopping exercise shows the value this tool adds to the supervisory tasks of national authorities

EBA released a report detailing the outcomes of a mystery shopping exercise that focused on personal loans and payment accounts. The primary objective of this exercise was to augment the existing supervisory practices employed by NCAs with unique insights gained from mystery shopping. The aim was to address gaps and deficiencies in the oversight process that conventional methods might overlook.
The report emphasized several key points. It highlighted the intrinsic value of mystery shopping as a supplementary too to traditional supervisory actions, underlining its ability to provide distinct and nuanced insights into the behavior of financial institutions that might not be apparent through other means. The exercise was carried out to evaluate the degree of compliance with EU regulations and to gather crucial insights that could lead to improvements in consumer protection measures.
The focus of the exercise revolved around personal loans and payment accounts, including those with basic features, within a limited number of EU Member States. The exercise centered on the pre-contractual phase, scrutinizing the manner in which financial institutions disseminated information and conducted themselves during interactions with customers. The distinct legal frameworks and supervisory priorities of different countries were taken into account to tailor the exercise to their specific circumstances.
Findings from the mystery shopping exercise revealed notable outcomes in both the personal loans and payment accounts segments. For personal loans, mystery shoppers encountered variations in the provision of pre-contractual information documents during in-person visits. Some institutions promptly shared the required information, while others provided limited or no documentation. The exercise also highlighted instances where fees were integrated into the total credit amount without securing explicit consumer consent, which raised concerns about compliance with the Consumer Credit Directive.
In the case of payment accounts, mystery shoppers interacted with financial institutions through both physical visits and online channels. The exercise brought to light shortcomings in providing the Fee Information Document during on-site visits. Additionally, online interactions with Electronic Money Institutions often lacked essential information, such as the necessity of personal data when opening accounts through online chat services.
The methodology employed for the exercise comprised four distinct phases: inception, planning, data gathering, and analysis/reporting. Mystery shoppers were meticulously trained and provided with scenarios to accurately simulate interactions with financial institutions, both through physical branches and digital platforms.