In the financial sector, BaFin is increasingly perceived as an institution attempting to position itself as the foremost consumer protector. While the evolving authority deals with a wide range of risks with the premise of maintaining financial stability, it sometimes gives the impression that it primarily focuses on the concerns of bank customers.

There is indeed discontent within the financial industry, and it is justified. There is talk of an occasionally intrusive oversight, which presents itself as a consumer protection authority, of regulatory zeal, and disproportionate protective behaviour. The oversight must be careful not to tilt towards consumer protection too much. It should take such criticism seriously and ensure not to overdo consumer protection, as essential as it may be.

In principle, it is commendable for BaFin to also address the concerns of beleaguered and deceived consumers. However, this does not entail a comprehensive care package for bank customers. They do not need to be hand-held and protected from every possible hardship in the world. The focus should be on risks that can endanger financial stability, such as corrections in the real estate markets or severe cyber-attacks.

It is positive that the oversight has shown more communication, transparency, and a tougher stance towards misconduct since the Wirecard debacle. It actively employs its toolbox: Misconducts, special audits, fines, higher capital requirements, and the deployment of special representatives are announced one after the other. This also applies to Deutsche Bank. The overseer stationed there is the first to watch over consumer protection, which is justified given the dimension of the disastrously executed transfer of customer data from Postbank to Deutsche Bank's IT systems.

This is also reflected in the number of complaints received by the oversight in 2023. Most of the grievances were directed against private banks, which experienced nearly a tripling of complaints. BaFin does not name names, only mentioning that a good portion of the complaints were directed at one institution. The fact that Deutsche Bank remains unnamed here also shows that the times are not yet over, when BaFin communications about penalties often left wrongdoers unnamed, citing confidentiality obligations or legal paragraphs that remained nebulous to those unfamiliar with legal matters.