Consumer credit providers and peer-to-peer loan brokers
Consumer credit providers and peer-to-peer loan brokers - instructions
If an entity intends to provide consumer credits or broker peer-to-peer loans, it must submit a notification to the Financial Supervisory Authority (FIN-FSA) for entry in the register of credit providers and crowdfunding intermediaries.
The notification must include the information mentioned in section 4 of the Act on the Registration of Certain Credit Providers and Credit Intermediaries (186/2023) (in Finnish). Section 11 of the Act contains additional provisions on the statements to be submitted if the entity submitting the notification has applied for the right to receive client funds. The content of the notification, together with the statements attached to it, must be submitted either as a Finnish- or Swedish-language application. In the case of possible additional statements, attachments in other languages may be approved, where necessary. Submission of attachments prepared in a language other than Finnish or Swedish must be agreed with the FIN-FSA in advance.
Credit providers and peer-to-peer loan brokers must notify the FIN-FSA immediately of changes to the information entered in the register. In addition, credit providers and peer-to-peer loan brokers must notify the FIN-FSA of the termination of their activities.
More detailed regulations and guidelines can be found in the FIN-FSA’s Regulations and guidelines 3/2023 (in Finnish).
Application forms
The FIN-FSA has published a notification form (word, in Finnish), which is recommended for use when applying for registration, and an attachment form (word, in Finnish), which is recommended for use when preparing the fitness and propriety assessment. Annex A (word, in Finnish) is required if the business activities include receiving customer funds. The forms can also be used to report changes in the information entered in the register.
The notification with its attachments is submitted to the FIN-FSA Registry
- by post to the address Finanssivalvonta, Kirjaamo, PL 103, 00101 Helsinki
- by e-mail to the address kirjaamo(at)finanssivalvonta.fi (secure email instructions).
The Registry will assign a register number to the case, which must also be used when submitting any further statements.
Questions about the notification procedure can be sent to RLL-rekisteroinnit(at)finanssivalvonta.fi.
Registration of consumer credit providers and peer-to-peer loan brokers
If an entity intends to provide consumer credits or broker peer-to-peer loans, it must submit a notification to the Financial Supervisory Authority (FIN-FSA) for entry in the register.
Requirements for the content of the registration notification
The registration notification must include:
- The information of the party making the notification
- Information about the nature of the activities
- A description of the nature and scope of the activities
- A statement on the fitness and propriety of the party making the notification and on their knowledge of credit activities
- Information on whether the party making the notification provides consumer credit advisory services
- Information on the keeping and handling of client funds.
The notification must include the information mentioned in section 4 of the Act on the Registration of Certain Creditor Providers and Credit Intermediaries (186/2023). Section 11 of the Act contains provisions on the statements to be submitted if the party making the notification has applied for the right to receive client funds.
The notification and its attachments must be submitted in either Finnish or Swedish. On a case-by-case basis, attachments prepared in an language other than Finnish or Swedish may be accepted.
Credit providers and peer-to-peer loan brokers must notify the FIN-FSA immediately of changes to the information entered in the register. In addition, credit providers and peer-to-peer loan brokers must notify the FIN-FSA of the termination of their activities.
More detailed regulations and guidelines can be found in the FIN-FSA’s Regulations and guidelines 3/2023 (in Finnish).
Statement on the notifying party’s knowledge of credit activities
The professional requirements applicable to consumer credit providers and peer-to-peer loan brokers and their senior management are laid down in the Government decree. The FIN-FSA shall also apply the requirements laid down in the Government decree when assessing whether the notifier or its senior management possesses sufficient knowledge of credit activities.
The party making the notification must demonstrate that it or, where it is a legal person, its senior management has the required competence and knowledge in accordance with the Government decree on the professional requirements of lenders and credit intermediaries in certain consumer credits. Senior management refers to the notifying party’s CEO, deputy CEO, members and deputy members of the board of directors, members and deputy members of a body comparable to the board of directors, responsible partners or other persons belonging to senior management. Other persons belonging to senior management are typically considered to be, for example, members of the management team and the heads of individual business areas.
The expertise requirement applies to senior management as a collective. Therefore, not all members of senior management are necessarily required to have knowledge of credit activities; it is sufficient that senior management collectively have the necessary knowledge and competence.
Relevant knowledge must include at least knowledge of:
- consumer credits falling within the scope of chapter 7 of the Consumer Protection Act and, if necessary, additional services related to them
- the consumer protection legislation relating to these credits and other legislation where applicable
- the consumer’s creditworthiness assessment process; and
- the credit market in Finland
In addition, the party making the notification must have, with regard to the nature and scope of its activities, appropriate knowledge of and competence in 1) the preparation, offering and granting of credit agreements, 2) credit intermediation, 3) the provision of advisory services and 4) the related consumer rights.
The required competence and knowledge must be demonstrated by an appropriate degree or other academic qualification and work experience. The necessary documents may include, for example, CVs, diplomas and work certificates as well as certificates of participation in significant educational programmes or professional courses. The required knowledge and competence must be kept up to date.
Notification forms
The FIN-FSA has published a notification form (Word, in Finnish), which is recommended for use when applying for registration, and an attachment form (Word, in Finnish), which is recommended for use when preparing the fitness and propriety assessment. Annex A (Word, in Finnish) is required if the business activities include receiving customer funds. The forms can also be used to report changes in the information entered in the register.
Submission of a register notification
The notification with its attachments is submitted to the FIN-FSA Registry either
- by post to the address Finanssivalvonta, Kirjaamo, PL 103, 00101 Helsinki
- by email to the address kirjaamo(at)finanssivalvonta.fi (secure email instructions).
The Registry will assign a register number to the case, which must also be used when submitting any further statements.
Progress of the registration procedure in the FIN-FSA
After receiving the register notification, the FIN-FSA assesses whether the entity fulfils the statutory requirements, and issues a decision on the case. If the application is incomplete, the FIN-FSA will ask for further clarification before deciding on the matter. The quality and completeness of the notification will influence significantly the total processing time.
Practice of activities may be prohibited by virtue of a conditional fine if the registration obligation is not complied with.
Registration and supervision fee
A registration fee is charged for registration in accordance with the FIN-FSA’s price list.
Entities in the FIN-FSA register are charged a supervision fee in accordance with the Act on the Supervision Fees of the Financial Supervisory Authority (1209/2023). For a registered consumer credit provider or peer-to-peer loan broker, the annual basic fee is EUR 15,000.
Register of credit providers and peer-to-peer loan brokers
The FIN-FSA maintains a register of credit providers and peer-to-peer loan brokers in accordance with section 4 of the Act on the Registration of Certain Credit Providers and Credit Intermediaries (186/2023).
Contact information
Questions about the notification procedure can be sent to the address kuluttajaluottorekisteroinnit(at)finanssivalvonta.fi.