Restricting free movement, keeping an appropriate physical distance between people and a partial economic deadlock are considered the only safe means of fighting the virus for which there is (yet) no cure. Therefore, the Croatian National Bank urges individuals to behave responsibly and respect preventive measures of protection against the coronavirus. To minimise the number of persons in a closed space, the CNB advises individuals to use available digital banking services (mobile and internet banking) and the ATM network as much as possible.
CNB GIVES RECOMMENDATIONS TO BANKS ON THE USE OF ATMs AND BRANCH OFFICES
All banks in the Republic of Croatia have responded to the Croatian National Bank's recommendation and provided a temporary waiver of fees charged to natural persons withdrawing cash by using debit cards at ATMs outside a bank's own ATM network. In the meantime, banks have terminated the temporary waiver and reintroduced the fees charged for cash withdrawals at ATM's outside a bank's own network.
The CNB's recommendation aimed at reducing the risk of infection by reducing the need for movement of people. Also, following the CNB's recommendation, all banks have started to provide access to debit cards to clients with protected accounts. In this way, the users of protected accounts may access cash via the ATM network, while in the past they had to go to a branch office of their respective bank. Furthermore, the use of debit cards via the ATM network also provides access to information on account balance to this financially vulnerable population group.
Taking due account of the difficulties encountered in adjusting to new circumstances, it is desirable that the elderly who do not use debit cards linked to accounts consider such an option in communication with their credit institution.
With regard to elderly persons who are actually unable to use ATMs and debit cards, the CNB has invited credit institutions to consider the option which would enable access to branch offices with minimum risk to the health of such persons as they belong to particularly vulnerable population groups that have been advised by the competent authorities to restrict their movement as much as possible so as to reduce their exposure to COVID-19 to the lowest possible degree.
In addition, as regards credit institutions that consider a reduction in the number of operating branch offices, the CNB expects them to approach the matter in a responsible and analytical manner, taking into consideration the health and safety of their employees and, at the same time, ensuring client access to basic banking services provided in branch offices.
RAISING THE LIMIT FOR CONTACTLESS PAYMENTS WITHOUT PIN
To reduce the possibility of infection by the coronavirus, the CNB has issued a recommendation to raise the limit for contactless payment transactions without PIN from HRK 100 to HRK 250. All banks and credit card companies responded to the recommendation and, regardless of the initial deadline set at 21 April 2020, most of them implemented the recommendation as early as 6 April 2020. The only exception is a small number of payment card issuers, which, due to the technical features of the cards, cannot apply the recommendation without replacing the cards themselves.
LOAN PAYMENT DEFERRAL (MORATORIUM)
Though it is yet uncertain how long epidemiological measures to reduce the risk of the coronavirus spread will remain in force, it is clear that economic and financial consequences for the system will be present for much longer, even after the health aspect of this threat comes to an end.
Therefore, in addition to several monetary and supervisory measures, the CNB has adjusted its regulatory framework and enabled credit institutions to offer new repayment terms for existing credit obligations to consumers faced with job loss and reduced income due to the coronavirus pandemic, and to continue to classify them as regular clients. Following the CNB’s recommendation, most banks adopted a number of measures to ease the repayment of existing obligations, including the measures to suspend forced collection of receivables, a moratorium on and/or rescheduling of household loans and the maintenance of tacitly accepted or permitted overdraft limits on current accounts at current levels, depending on their particular circumstances.
However, the Croatian National Bank does not prescribe the procedure for granting a moratorium and each credit institution needs to define this procedure itself, specify the required documentation and the method of application submission. To obtain all information on the conditions for a moratorium, and the terms and methods of forced collection of receivables during the coronavirus pandemic, consumers should contact their credit institutions and they should together, in direct communication, examine all available options to ease the current situation.
While credit institutions may freely define the terms of and time limits for payment deferral granted to their clients, they must, nevertheless, respect regulations in force in the Republic of Croatia, while maintaining the current level of consumer protection. More specifically, consumers have the right to timely information updates and clear communication with their credit institutions.
In addition, it should be ensured that, regardless of the communication channel, clients receive all necessary information on the terms of an offer as they would in ordinary circumstances.
Credit institutions are also able to take additional financial measures to ease the current situation for their clients. Therefore, following a receipt of an offer, consumers are advised to request specific calculations of possible costs they would incur in the future and then make an informed decision on whether to accept the offered measures regarding deferral of existing obligations. After considering specific calculations provided by the banks, consumers may find out that they may still be able to repay their obligations under the previously agreed terms. If amendments to the agreements are not regulated in the prescribed manner while epidemiological measures are in effect, upon expiry of the measures and procedures to contain the pandemic, credit institutions are obliged to ensure that all agreements on deferral of credit obligations are concluded in the legally prescribed form.