We are, of course, talking about credit holidays, as the first week of their implementation brought ca. 550 consumer complaints.
Credit holidays are available to any consumer who has taken out a mortgage in PLN for their own housing needs. The suspention of repayment of instalments can last up to eight months until the end of 2023.
The President of the OCCP is monitoring how banks inform consumers about the possibility of suspending repayment, and whether they make it difficult to take advantage of the provisions of the new act. The first week that the act was in force brought complaints, which mainly concerned „problems with electronic submission of applications, banks requiring several separate applications for the suspension of each instalment, scaring consumers with the negative impact of credit holidays on their creditworthiness assessment or making it difficult to overpay a loan when instalments are suspended”.
Emerging problems
- The requirement to submit a separate application for the suspension of each instalment. Under the law, the consumer indicates in the application the period or periods for which they want to suspend repayment. They also decide whether to apply for a credit holiday for eight periods at a time or whether they will do so in separate applications. Unfortunately, many banks required a separate application for each instalment or each quarter.
- Making it difficult to apply. Some banks make it difficult to submit a paper application when the consumer has electronic banking or do not accept applications sent by post.
- Date of the submission of the application. According to the law, the suspension of an instalment shall take place „on the date of service of the application”. This means that it must also be applied if the consumer has submitted it on the day when the instalment payment falls due. Moreover, the bank should refund the money if, for example, it collected the instalment in the morning and in the evening the consumer submitted the application in electronic banking. Despite this, many banks required the application the day before the instalment due date at the latest.
- Scaring consumers with the possibility of losing creditworthiness. Some banks suggest to consumers that taking a credit holiday will make it more difficult to obtain financing in the future, including from other institutions. One bank requires confirmation during the online application that the customer has been informed that information about the suspension of repayment will be passed on to the Credit Information Bureau. In reality, such information is a neutral reference to the process of fulfilling the commitment.
- Amount of subsequent instalments. The new credit solution is free of charge. A bank cannot charge or accrue interest during this period. The borrower only pays for insurance. Unfortunately, in practice, some consumers have received repayment schedules and the interest instalments in the following months are significantly higher. There are also situations where, after the end of the holiday, the bank stipulates that only interest will be charged (with no capital repayment).
- Making it difficult to overpay the loan. The president of the OCCP urged that, if possible, the money saved should be used to overpay the loan. This solution reduces the amount of money to be repaid and allows a client to gain on interest. However, some banks make it difficult for consumers to overpay, e.g. by informing in branches that it is not possible to overpay during the loan suspension period.
