The European Banking Authority (EBA) published a methodological guide to mystery shopping. For the purpose of this guide, mystery shopping is understood as an undercover research approach used by competent authorities, or the market research companies they hire, to measure the quality of customer service and to gather information about financial products and services and the conduct of financial institutions toward consumers. This exercise covers initiatives in respect of products that fall in the scope of action of the EBA consumer protection mandate—that is, mortgage credit, consumer credit, deposits, payment accounts, payment services, and electronic money.
Mystery shopping may include the use of individuals that may act as potential or actual customers and are trained and briefed to experience and measure key phases of a product’s lifecycle and compliance with particular requirements. The guide sets out seven steps how mystery shopping activities can be conceived and carried out, how national competent authorities can use the guide as a complement to other existing supervisory tools, and how to adapt such activities to the particular circumstances, goals, and mystery shopping powers conferred on national competent authorities under the national and/or EU laws, such as the EU Consumer Protection Cooperation Regulation. The guide has been developed based on the findings and good practices identified in the EBA report on mystery shopping activities of national competent authorities; the report was published in May 2021 this year. Thus, this guide is the second step to fulfilling the new EBA mandate under Article 9(1) of the EBA Founding Regulation; the mandate has been applicable since January 2020 and requires EBA to "coordinate mystery shopping activities of competent authorities, if applicable." As per the guide, the national competent authorities can consider the following steps when building a mystery shopping activity:
- Define the goals of the mystery shopping activity
- Select the products/services and their distribution channels
- Select the financial institutions to be mystery-shopped
- Select the mystery shoppers and consumer profiles
- Design scenarios for mystery shoppers
- Design the assessment questionnaire for mystery shoppers and data gathering
- Assess the findings and follow up
The guide applies irrespective of whether the activity is conducted directly by the supervisors or outsourced to an external provider. In addition, the guide applies to both online and onsite mystery shopping activities but focuses on the onsite activities. The guide is not mandatory and does not aim to harmonize the mystery shopping practices of national competent authorities or imply that all national competent authorities would need to adopt it as supervisory tool.
Keywords: Europe, EU, Banking, Mystery Shopping, Mortgage Lending, Consumer Credit Directive, Consumer Lending, Lending, Consumer Credit, EBA
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