"Service fee" in building society contracts ineffective

Bausparkasse withdraws its appeal!

After Debeka Bausparkasse AG withdrew its appeal to the Federal Court of Justice (BGH) against the ruling of the Koblenz Regional Court of 21.11.2019 (Ref.: 8 U 1770/18), it is now clear that the annual “service fee”, which the bank had introduced retrospectively, is invalid and may no longer be charged.

Although there has been no generally binding decision by the Federal Court of Justice on this due to the withdrawal of the appeal, customers of the building society can now make a binding assumption that the lump sum is invalid and reclaim wrongly charged fees.

At the beginning of 2017, the building society had introduced a subsequent fee, the so-called “service fee”, for the “old tariffs” BS1 and BS3. According to this, fees were charged in the amount of 24 euros once a year and 12 euros once a year. The building society cited the permanently low interest rate situation as the reason. The newer contracts, on the other hand, would already take into account the expenses supposedly incurred by the buildiThe newer contracts, on the other hand, would already take into account the expenses supposedly incurred by the Bausparkasse in the tariff structure.ng society in the tariff structure.

The plaintiff was the Consumer Advice Centre Saxony. It was of the opinion that the service fee passed on costs to the consumer that were legally or contractually to be borne by the building society. This was also the original decision of the Regional Court of Koblenz, judgement of 21.11.2019 (Ref.: 8 U 1770/18).

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Update: Ways out of real estate financing - No early repayment penalty in case of insufficient information on the calculation of the VFE; BGH (XI ZR 320/20) confirms decision of the OLG Frankfurt

In rejecting Commerzbank’s non-admission appeal (Ref.: XI ZR 320/20) against the judgment of the Higher Regional Court of Frankfurt (Ref.: 17 U 810/19), the Federal Court of Justice confirmed the protection of bank customers in the event of an exit from real estate financing without an early repayment penalty if the customer was not sufficiently informed about the calculation method of any VFE when the contract was concluded. We already reported on the previous decision in our article Auswege aus der Immobilienfinanzierung – Keine Vorfälligkeitsentschädigung bei unzureichender Information über die Berechnung der VFE. Now, the Federal Supreme Court (BGH) has also strengthened the rights of consumers and thus confirms its previously expressed legal opinion (see BGH, judgment of 28 July 2020 – XI ZR 288/19).
In its decision, the BGH agrees with the content of the OLG Frankfurt and does not consider further clarification of the matter to be necessary. While this represents a significant setback for banks, borrowers find themselves in a strengthened position.
In the previous decision, the Higher Regional Court of Frankfurt came to the conclusion that there was no legal ground for the early repayment penalty. The information on the basis of calculation had not complied with the legal requirements, therefore the bank had lost its claim to an early repayment penalty, cf. section 502 (2) no. 2 BGB. As a result, it could be reclaimed from the borrowers. We have numerous other formulations on the calculation method that are to be considered insufficient.
The ruling, which has now been confirmed by the BGH, will also have considerable significance for the clients of other banks. Although the contract forms of many banks have already been revised, they are often still vulnerable. Consumers now have the possibility, if necessary, to escape an early repayment penalty by invoking the new case law. This applies to all contracts from 22.03.2016 onwards, because from this date at the latest, the banks were in principle obliged to properly instruct their customers.
If you have any questions on the subject of early repayment fees, please contact us. We are happy to advise you!

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Reform of the Transparency Register

On 25 June 2021, the Federal Council approved the draft law on the Transparency Register and Financial Information Act (TraFinG). The aim of the law is to enable the interconnection of European transparency registers in the fight against money laundering and terrorist financing. The law is to come into force as early as 01.08.2021.
Until now, notifications to the German transparency register were only required if the information on the beneficial owners did not result from other registers, such as the commercial register. Consequently, the transparency register was initially designed as a catch-all register. However, a full interconnection of the European transparency registers requires a so-called full register, i.e. a place where all information on beneficial owners can be retrieved in a uniform data format. Through the TraFinG, the German transparency register is now to be expanded into such a full register.
In future, almost all legal entities will thus be obliged to provide the transparency register with all information on their beneficial owners. This applies irrespective of the size of the company; both listed public limited companies (and their subsidiaries) and small “one-man limited liability companies” are obliged to submit their data. Only associations are initially excluded from the notification obligation. For them, a transfer of the association’s board members, who are usually the fictitious beneficial owners of the association according to Section 3 (3) sentence 5 AMLA, from the register of associations is provided for; thus, the association does not incur any additional bureaucratic expenses. In order to take into account the far-reaching practical consequences for all other persons required to report, the legislator has provided for transitional periods. These staggered transition periods require subsequent registration by:

  • 31.03.2022 für Aktiengesellschaften (AG), Kommanditgesellschaften auf Aktien (KGaA) und Societas Europea (SE)
  • 30.06.2022 for limited liability companies (GmbH), cooperatives and partnership companies
  • 31.12.2022 for all other companies subject to transparency requirements, e.g. GmbH & Co. KG.
    In addition, the corresponding fines do not take effect with the expiry of the transitional period. Here, too, the legal entities are granted a staggered grace period until the:
  • 31.03.2023 for the AG, SE or KGaA
  • 30.06.2023 for the GmbH, cooperative, partnership
  • 31.12.2023 in all other cases.

Another innovation concerns in particular those obliged under money laundering law, such as banks. Until now, they could not rely exclusively on the information in the transparency register. Durch das TraFinG ändert sich dies nun jedoch: Geldwäscherechtlich Verpflichtete sollen die Angaben zur Identifizierung des wirtschaftlich berechtigten Vertragspartners weiterhin selbstständig erheben. However, provided that this information then coincides with the transparency register, they have sufficiently fulfilled their duty of identification.
In this respect, the TraFinG entails a considerable additional effort for the entities required to register, but those obliged under money laundering law in particular benefit from bureaucratic savings.

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BGH: Easing of the burden of proof for victims of so-called pyramid schemes

In principle, the plaintiff in a case has to present and prove all circumstances that give rise to a claim. The Federal Supreme Court (BGH) has now accommodated the injured parties of so-called pyramid schemes and decided to ease the burden of proof in its judgement of 04.02.2021, ref.: III ZR 7/20. You can read the judgement in its entirety here.

The term “pyramid scheme” refers to the satisfaction of old creditors with the money of new creditors; in this respect, the scheme does not generate any profit of its own, but finances itself through over-indebtedness. So far, the creditor had to be able to sufficiently demonstrate the existence of such a system in his statement of claim. Now the Federal Supreme Court eases the burden of proof on the creditors and states in its operative part: “The aggrieved party regularly already satisfies its burden of proof by presenting circumstances that make the (further) operation of such a pyramid scheme appear obvious. The defendant is then obliged to comment on the assertions of the party obliged to provide evidence within the framework of the duty to explain incumbent upon it under section 138 (2) of the Code of Civil Procedure.

The BGH further ruled that the existence of a pyramid scheme regularly simultaneously fulfils the requirements of intentional immoral damage according to §826 BGB as well as those of fraud in the commission of a crime according to §823 para. 2 BGB in connection with §263 StGB. The operators of a pyramid scheme regularly expected to be able to constantly attract further investors to the scheme, although this could not be controlled and sometimes depended on the current market situation. In this respect, the damaging intention of the operator was so tangible that the violation of morality could already be derived from the plant itself.

In the disputed case, a man from Bavaria used a system from Switzerland known as “Cashselect” for his life insurance. Investors should have their building savings contracts and other capital investments terminated in order to then profitably invest the surrender values in companies, predominantly from the renewable energy sector. However, the Swiss Financial Market Supervisory Authority prohibited the Swiss company from operating and the attempt to keep the company running via a German GmbH also failed. Attempts by the plaintiff to assert his claim in the amount of approximately € 60,000, first before the Regional Court of Schweinfurt and subsequently before the Higher Regional Court of Bamberg, failed due to the burden of proof. However, according to the BGH’s ruling, the plaintiff’s arguments were very conclusive and indicated a business model designed to deceive and harm customers. Further submissions on the part of the plaintiff were not appropriate here; rather, the defendant would have had to present his opposing view in a substantiated manner. A general denial that such a business model had been operated was not sufficient. The Bamberg Higher Regional Court must therefore now hear and decide the case again.
We will keep you informed about the developments!

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Reform of the law on private limited companies

The corporate partnership law, which in part dates back to the 19th century, is now to be adapted to today’s needs through a current reform project. In the meantime, the Federal Council has already commented on the government draft, so that implementation is likely as early as this autumn. However, a transitional period until the end of 2022 is planned; the law is therefore not to come into force until 01.01.2023. In the following, we inform you about the essential innovations of the government draft on the modernisation of partnership law (RegE MoPeG). The current legislative procedure on partnership law is available at: https://www.bmjv.de/SharedDocs/Gesetzgebungsverfahren/Dokumente/RegE_Personengesellschaftsrecht.pdf?__blob=publicationFile&v=3.

Innovations for the GbR

A large number of innovations of the MoPeG concern the civil law partnership. Firstly, the legal capacity of a GbR (acting externally) is enshrined in law for the first time; previously this had only been established by case law. Furthermore, §707 (1) BGB-E provides for the introduction of a company register for the GbR to be kept by the local courts.
Although registration is not to be compulsory, the acquisition of rights to be registered in public registers, such as the acquisition of real estate or trademark rights, as well as the position as a shareholder of another company, is to be linked to registration.
In addition, the GbR is to become convertible. GbRs can consequently participate in a demerger, merger or change of legal form under the Transformation Act in the future.

Innovations for the OHG

First, the gaps in the OHG’s resolution procedure law are at least partially closed. Up to now, the HGB only provided regulations on the unanimity principle for resolutions. If the articles of association stipulated other majority requirements, it was usually necessary to resort to the law of the GmbH. This is now to change through § 109 HGB-E: On the one hand, para. 1 now includes virtual meetings such as telephone or video conferences in addition to traditional face-to-face meetings. On the other hand, para. 4 standardises the requirements for the quorum of the meeting in the case of deviations from the unanimity principle (which should continue to be the basic model). Accordingly, the convened shareholders’ meeting shall constitute a quorum if the shareholders present or their representatives have the votes required for the adoption of a resolution, irrespective of their voting rights.
However, fundamental issues such as deadlines for meetings or voting prohibitions are still not regulated in this context. If the articles of association do not contain any provisions in this regard, the law governing limited liability companies will have to be applied.
Other changes relate to the determination and distribution of profits. Until now, the applicable law has been complicated and thus often impracticable. §Section 120 (1) sentence 1 HGB-E now initially assigns the competence to prepare annual financial statements to the partners with management authority. The annual financial statements are then adopted by resolution of the shareholders in accordance with §121 HGB-E. Pursuant to §120 (1) sentence 2 HGB-E, §709 (3) BGB-E, the distribution of profits and losses is to be based primarily on the share ratio. If no participation ratios are specified, the contribution rate shall be used as a basis. If neither participation nor contribution values can be determined, the head quota applies; each partner participates equally in the loss or profit. If a profit is determined, §122 HGB-E assumes the principle of full distribution. If this is not desired, corresponding regulations must be included in the articles of association.

Innovations for the KG

§162 (HGB) currently still provides for a secrecy privilege for limited partners; these are not named when the registration of the limited partnership is announced. This regulation is to be dropped in future. However, the amendment is unlikely to have any practical impact, as information on limited partners can already be obtained through excerpts from the commercial register.
Furthermore, the information rights of the limited partners are to be improved. Under the current regulations, the limited partner has only a very limited right to information. Pursuant to §166 HGB, it may demand inspection of the annual financial statements and the accounting records. However, in order to enforce his other extraordinary right to information, the limited partner requires a court order. The new §166 (1) sentence 2 HGB-E is intended to grant the limited partner a general right to information in the future. However, this right is also linked to the existence of an important reason. This is particularly the case if there is reason to assume dishonest management.
Furthermore, §176 HGB-E stipulates an increase in liability for the limited partner who has not yet been registered. Limited partners who have agreed to participate in legal transactions are liable for all liabilities of the limited partnership that were established until their registration as if they were personally liable partners. Up to now, limited partners have been able to escape this aggravation of liability if the creditors were aware of their position as limited partners. In the future, this relief from liability will no longer apply, so that it is essential to ensure that the limited partner declares his accession to the partnership subject to the condition precedent of the entry in the register.

We will keep you informed about developments in this regard!

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Ineffectiveness of "forfeiture of all claims" clause in employment contract

The Federal Labour Court (Bundesarbeitsgericht, BAG) ruled on 26 November 2020 (case no. 8 AZR 58/20) that expiry periods in an employment contract which lead to the lapse of all remaining claims under the employment contract after the expiry of a certain period of time after the end of the employment relationship are invalid.
The court had to deal with the following facts:
The employer asserted a claim for damages in the amount of 101,372.72 Euros in the context of a counterclaim on the occasion of a dismissal protection suit. The employee previously worked as a commercial employee in the company and was responsible for financial and payroll accounting. After she had posted private invoices of the limited partner – her husband – paid with company funds many times, the employer had terminated the employment relationship.
The company filed a counterclaim against the dismissal protection action brought by the employee, in which it asserted the above-mentioned claims for damages. The employee objected to the following clause of the employment contract:
“§ 13 Time limits for forfeiture: All claims arising from the employment relationship shall be asserted in writing within a preclusive period of 2 months after the due date and, in the event of rejection by the other party, shall be enforced within a preclusive period of one month.”
The lower court, the Regional Labour Court of Rhineland-Palatinate, judgment of 18.06.2019 (case no. 5 Sa 169/18), did not consider the company’s claims to be excluded under the forfeiture clause. An interpretation of the expiry clause at issue, taking into account its meaning and purpose, showed that the clause did not include the present claim for damages. The court came to this conclusion with regard to the provision of section 202 (1) of the German Civil Code (BGB), according to which liability for intent could not be facilitated in advance by a legal transaction.
The BAG has now overturned this decision. It concluded that such a forfeiture clause used in the GTC covered all claims arising from the employment relationship without exception, which resulted from section 310 (3) no. 2 BGB. More precisely, all mutual contractual and statutory claims that the parties have against each other arising from the employment relationship are basically covered, thus also claims for damages arising from intentional breach of contract and intentional tort.
However, in the present case there was a violation of section 202(1) BGB, so that the clause was invalid pursuant to section 134 BGB. Both parties can refer to this, including the employer who has made the clause himself.
In its previous case law, the BAG had not considered claims arising from intentional breach of contract and intentional tort to be covered by general terms and conditions – in this respect, this is an important change in case law that employers will have to observe in future when drafting pre-formulated contracts. Liability for wilful breach of contract and wilful tort must in future be expressly excluded from the forfeiture clauses so that the clause can apply to the other claims.

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Update - Building Land Mobilisation Act

On 07.05.2021, the Bundestag passed the partly very controversial law on the mobilisation of building land. Before the law can enter into force, it thus only requires the approval of the Bundesrat and the completion of the promulgation procedure.
The primary objective of the law is to strengthen the municipality’s scope of action with regard to the creation of housing. In future, it will be easier for building permit authorities to grant exemptions from existing development plans, e.g. to allow loft conversions or extensions. Furthermore, the Building Land Mobilisation Act provides municipalities with a new instrument: a sectoral development plan, which enables the municipality to draw up a land-use plan specifically for housing construction. The law also contains an extension of the building requirement in order to be able to build on unused plots more quickly and thus close gaps between buildings more quickly, as well as the strengthening of municipal rights of first refusal for derelict plots and so-called “problem properties”.
The most controversial point, however, is the amendment of §250 BauGB, which prohibits the conversion of rental flats into owner-occupied flats. In regions with a tight housing market, owners can no longer easily convert their flats previously used for rental purposes into owner-occupied flats; in future, this will require approval by the competent authority. The exact regions that will be affected are still being specified by the Länder through independent legal ordinances. Exceptions to the conversion ban exist, among other things, in the case of sale to family members or the sale of individual flats from an apartment building.
Already after the federal cabinet approved the draft law on 04.11.2020, immense criticism of the law was voiced. In particular, the Building Land Mobilisation Act makes it more difficult to form property, as fewer flats and houses will be available for purchase on the market. Especially in economically difficult times, when not many investment opportunities yield returns, it is irresponsible to make it more difficult to build up property for the purpose of old-age provision. In response to the strong headwind, Federal Minister of Building Seehofer even called on his own ranks to vote against the bill. After a long struggle, the Bundestag passed the law after all – including amendments to §250 BauGB.

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    No registration of a land charge in favour of a legal entity that has ceased to exist as a result of a merger

    No registration of a land charge in favour of a legal entity which has ceased to exist as a result of a merger – OLG Düsseldorf I-3 Wx 125/20

    In a recent decision(OLG Düsseldorf, decision v. 12.08.2020, ref.: 3 Wx 125/20), the OLG Düsseldorf had to deal with the question whether a land charge in favour of a legal entity that no longer exists (due to the merger process) is registrable.
    The judgment was based on the following facts:
    On 27 May 2020, the contracting parties concluded a notarised real estate purchase contract, which also contained a financing power of attorney. Furthermore, the contracting parties created a land charge in favour of the financing bank on the same day. The beneficiaries thereupon apply for the registration of the land charge and, following in rank, a resolutive conditional priority notice of conveyance. However, the creditor of the land charge had already been merged with Deutsche Bank AG as the acquiring legal entity on 10 May 2020. This conversion was also entered in the commercial register. The land registry then registered the priority notice of conveyance, but rejected the application for registration of the land charge.
    The court indisputably found that the company designated as creditor of the land charge had already ceased to exist pursuant to § 20 para. 1 no. 2 sentence 1 no. 1 UmwG as a result of the merger. However, it was unclear whether the application for registration could not be interpreted to the effect that the creditor of the land charge was now the acquiring legal entity, i.e. Deutsche Bank AG. For this, an interpretation of the land register declaration would have to lead to a doubtless and unambiguous result. However, the court denied this in the present case. The acquiring legal entity also has three other branches that can also conclude financing transactions. In this respect, it was unclear whether the contracting parties would have concluded the contract with the acquiring legal entity or one of the three branches if they had been aware of the legal situation.
    According to the court, a reinterpretation according to §140 BGB was also not appropriate, since the legal transaction was not indefinite in content, but only the designation of the creditor of the security right over real property was incorrect. Finally, the court ruled out a derivation from a universal succession directly as well as indirectly.

    If you have any further questions on this topic, we will be happy to advise you in detail.

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    Banking law - Termination of business relationship on suspicion of money laundering by the customer

    In a ruling of 29 September 2020 (Ref.: 5 U 165/19), the OLG Jena dealt with the question of whether and under which conditions an extraordinary termination option exists if the bank suspects misuse of the loan proceeds, in particular for money laundering.

    According to the court, the extraordinary termination in such a case could be based on no. 26 para. 2 of the GTC-Savings Banks (= no. 19 para. 3 GTC-Banks), or § 314 BGB. The prerequisite is a suspicion of money laundering within the meaning of section 261 of the Criminal Code, which is based on a multitude of unusual circumstances at the time of the notice of termination and which objectively could have existed. According to the court, there is no doubt that a criminal offence under section 261 of the German Criminal Code (StGB) constitutes good cause for extraordinary termination under section 314 of the German Civil Code (BGB) – this applies irrespective of the standard examples listed for good cause in the savings banks’ GTC, which do not expressly include suspicion of money laundering. Moreover, recital 33 of the Consumer Credit Directive, which according to the literature also covers money laundering, also speaks in favour of the suspicion of money laundering as a sufficient reason for termination.

    What is required is an initial suspicion, which results from concretely recognisable indications. These can be, for example, a conspicuous handling of financial transactions or a deviation from normal business conduct. The given indications are said to suggest that the origin of illegal assets is to be concealed or, for example, that access to illegal funds by the law enforcement authorities is to be avoided through transactions, so that a background corresponding to Section 261 of the Criminal Code cannot be ruled out. In this respect, there was a certain margin of appreciation when assuming the initial suspicion.

    If there is a suspicious case that has to be reported according to the GWG, a sufficient reason for termination is to be indicated in any case. The bank could not reasonably be expected to continue the business in this situation. Neither the expiry of the prohibition period pursuant to § 11 para. 1 a GWG a.F. nor a discontinuation of the preliminary proceedings according to § 170 para. 2 of the Code of Criminal Procedure precludes the extraordinary dismissal. The latter does not change the fact that the bank actually had reasonable suspicion. For this purpose, the ex-ante view was decisive, i.e. not the view “in retrospect”, but the view at the time the suspicion was founded.

    The ruling of the OLG Jena could lead to more legal certainty in the future when terminating corresponding legal transactions. We will of course continue to follow developments in the area of dismissal on suspicion of money laundering for you.

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    BGH judgement on fictitious consent in the case of amendments to GTCs

    In a judgement of 27.04.2021 (Az. XI ZR 26/20), the XI Civil Senate of the Federal Court of Justice ruled on the invalidity of general terms and conditions clauses that feign the bank client’s consent if the bank makes changes to the general terms and conditions.
    The complaint filed by the Federal Association of Consumer Centres and Consumer Associations was directed against clauses in general terms and conditions stipulating that changes must in principle be offered to the customer two months before the date on which they are to take effect. However, the express consent of the customer shall not be required for these clauses to take effect. Insofar as he does not indicate any rejection within the period between the offer and the effective date, the consent shall be deemed to have been given. The bank will make special reference to this in the offer and the customer also has a termination option.
    The plaintiff brought an action for an injunction against the use of such clauses. After unsuccessfully going through all instances, he turned to the BGH with his request to oblige the bank to refrain from using these clauses.
    The court came to the conclusion that the clauses were invalid. They do not stand up to a review of general terms and conditions pursuant to § 305 et seq. BGB.
    An interpretation of the disputed clause No. 1 (2) of the GTC shows that it concerns all amendments to the contracts concluded between the bank and the client. This may also include, for example, securities transactions and savings transactions. Without there being any restriction in this respect, every contractual amendment agreement is therefore affected by the effect of approval. The BGH sees this as a significant deviation from the basic idea of § 305 para. 2, § 311 para. 1, §§ 145 et seq. BGB, according to which silence in legal transactions is generally not to be regarded as a declaration of intent. Accordingly, the GTC offer cannot be effectively accepted without the customer actually giving his consent. This was to be seen as an unreasonable disadvantage to the customer pursuant to section 307 (1) sentence 1, (2) no. 1 of the German Civil Code (BGB), which is presumed in the case of a substantial deviation from the basic ideas of the law. In the case of fictitious consent, the bank has the power to redraft the contract on its own authority. Even the possible exercise control with regard to already agreed amendments did not change the existence of the unreasonable disadvantage. Rather, an amendment agreement was required for an amendment of the GTC, especially if such fundamental and far-reaching provisions for the contractual relationship of the parties were involved, as in the case decided in this case.
    With regard to another clause, no. 12 (5) of the disputed GTC, the court also came to the conclusion that the clause was invalid. This regulates charges for main services. Because of the customer’s fictitious consent, the main performance obligations owed by the bank can be changed by means of GTCs – and without restrictions. This leads to the bank being able to influence the contractual provisions to its advantage in a significant way, which can lead to a devaluation of the client’s position. This was an unreasonable disadvantage contrary to the principles of good faith. In order to be effective, an amendment agreement meeting the legal requirements would also be required. The fiction of consent, on the other hand, was not sufficient.
    This decision will have far-reaching consequences for practice. On the one hand, this makes it necessary to adapt comparable clauses in legal transactions. Furthermore, certain amendments to the GTC may also be retroactively invalid. With respect to consumers, amendments to general terms and conditions or special terms and conditions based on a mere fiction of consent by the customer may not have become effective. This would have the consequence that the originally agreed conditions would continue to apply, which may well lead to a need for legal action.
    If you have any questions about changes to the GTC, we will of course be happy to advise you. We continue to follow developments on this issue and will keep you informed.

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