Frequently asked questions regarding consumer credit intermediaries

According to the Government Proposal (HE 120/2025 vp., pp. 94–95), preparatory steps relating to a credit agreement or other administrative activities preceding the conclusion of the agreement are also regarded as assisting the consumer in concluding a credit agreement and therefore constitute credit intermediation. Examples of such preparatory or administrative activities mentioned in the proposal include situations where a trader transmits a consumer’s information to a creditor or another credit intermediary for the purpose of applying for credit, offers the possibility to submit a credit application on its own website and forwards the consumer’s credit application to a creditor, or requests credit offers from creditors on behalf of the consumer.

The Finnish Financial Supervisory Authority considers that, as a general rule, the technical manner in which the information is collected and transmitted onward is not relevant for the purposes of determining whether the definition is met.

According to the Government Proposal (HE 120/2025 vp., p. 94), the presentation or offering of credit agreements to consumers within the meaning of the definition of credit intermediation includes, for example, presenting creditors’ credit offers to consumers or directing the consumer towards concluding a credit agreement. By contrast, where a trader merely directly or indirectly introduces the consumer to a creditor, this alone is not considered to constitute credit intermediation within the meaning of the definition.

The Finnish Financial Supervisory Authority considers that banner advertising in which the consumer is merely introduced to a creditor or a credit intermediary does not constitute credit intermediation. However, marketing is assessed as a whole, and more extensive presentation of credit offers or directing the consumer may nevertheless result in the definition of credit intermediation being fulfilled.