Bundled sales: position of the financial sector

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In response to a preliminary draft law, various forums published articles and positions on the “bundled sale”. As a sector federation, Febelfin considers it useful to give a brief overview of the banking sector's view on bundled sales.


The bundled sale is a nationally and European legally recognized technique that has been used for more than three decades. The lender of a home loan offers the borrower an ancillary service in all transparency, usually fire and/or outstanding balance insurance, with an insurer proposed by the lender. If the borrower accepts this proposal, the borrower receives a conditional discount on the contractual interest rate of the home loan entered into. The discount offered varies according to the lender. The benefit is “conditional”: the discount remains valid as long as the insurance remains with the proposed insurer. The borrower has the absolute freedom to compare insurance policies and then to make the most interesting and/or most advantageous choice after consideration: for example, it is always a good idea to balance the loss of interest discount with the possible reduction in insurance premium costs, calculated over the remaining term of the credit. The current technique of bundled sales is an increasingly transparent way of offering. On an annual basis, 240 000 credits are provided, a large part of which as bundled sales. Over the years, virtually no complaints have been reported to the Ombudsman Service for the financial sector or to the Ministry of Economy.

Draft new law

In the initial preliminary draft law, the legislator wanted the conditional interest rate discount to be maintained for mortgage loans if the borrower opts for another insurer after a very short period. In other words, even if the condition is no longer met, the borrower could keep the discount for the rest of the term of the home loan. There is a chance that if this legislative change comes about, the logic for granting this discount will be completely revised. Is the consumer better off in this way with these amended regulations? The banking sector strongly doubts this, as the current discount for a bundled sale is really in favor of the borrower. From a consumer interest point of view, the sector does not see any need or reason to change the current law. Even under current legislation, the consumer can already change insurer without any problems if he/she believes that this provides a better deal than the interest discount on the home loan. The real reason for the proposed change in the law is the wish of insurance brokers to have what they consider to be “greater” competition in the sale of insurance. The current advantage for the borrower is of secondary importance to them in this story. It would therefore be a pity if this legislative amendment were to reach the final mark of parliamentary approval.