Banks

Consumer credit providers and peer-to-peer loan brokers

Registering as a consumer credit provider and peer-to-peer loan broker

The Act on the Registration of Certain Credit Providers and Credit Intermediaries, by which supervisory responsibility was transferred to the Financial Supervisory Authority (FIN-FSA), entered into force on 1 July 2023.

The Act applies to traders who provide consumer credits within the scope of chapter 7 or chapter 7a of the Consumer Protection Act. The Act also applies to traders who broker loans to consumers, where the loan is provided by a lender other than one referred to in chapter 7 or chapter 7a of the Consumer Protection Act (peer-to-peer loan).

In addition, the new Act applies to traders who provide loans to housing corporations or other housing associations (housing association loan).

Application forms

Only registered entities are permitted to provide consumer credits and housing association loans and to broker peer-to-peer loans.

The FIN-FSA has prepared forms to facilitate the submission and processing of applications for entities applying for registration. Entities already registered with the Regional State Administrative Agency for Southern Finland do not need to re-apply for authorisation after the change of supervisor; their registrations will be transferred as they are.

Key requirements for the content of the register notification

The registration notification must include:

  • Information of the party making the notification
  • Information about the nature of the activities
  • Description of the practised activities
  • A statement on the fitness and propriety of the party making the notification and on their knowledge of credit activities
  • Information on the keeping and handling of client funds.

Under the law, the entity must also notify the FIN-FSA immediately of changes to the information entered in the register and of the termination of activities.

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 case. The quality and completeness of the notification will influence significantly the total processing time.

Practice of the activity may be prohibited under penalty of a conditional fine if the obligation register is not complied with.

A registration fee is charged for registration.

Regulations and guidelines 3/2023

Regulations and guidelines 3/2023 bring together the FIN-FSA’s regulations, guidelines, recommendations and interpretations on the information to be included in the register notification for credit providers and peer-to-peer loan brokers. Their purpose is to provide guidance on market entry and to streamline the registration process.

Regulations and guidelines 3/2023 highlight the factors to which the FIN-FSA, when interpreting the requirements laid down in the law, pays particular attention when it assesses whether the party submitting the registration notification meets the requirements set for certain consumer credit providers or peer-to-peer loan brokers. The requirements for registration must be fulfilled throughout the period of activity.

Registers and lists

Information on the supervised entities of the FIN-FSA is collected in the list of supervised entities. The list contains information on, for example, the authorisation or other justification for activities.

Subareas of supervision

In addition to supervising the information in the register notification, the FIN-FSA also supervises other subareas. These include the management of insolvency risks in consumer credit, the maximum LTC ratio, compliance with obligations to prevent money laundering and terrorist financing, and the conduct of entities in their relationship with customers.

Contact information

RLL-rekisteroinnit(at)finanssivalvonta.fi

Registering as a consumer credit provider and peer-to-peer loan broker

The Act on the Registration of Certain Credit Providers and Credit Intermediaries applies to entities who provide consumer credit within the scope of chapter 7 or chapter 7a of the Consumer Protection Act. The Act also applies to entities who broker loans to consumers, where the loan is provided by a lender other than one referred to in chapter 7 or chapter 7a of the Consumer Protection Act (peer-to-peer loan). In addition, the Act applies to entities who provide credit to housing corporations or other housing associations (housing association loan).

The Act also applies to the provision of advisory services related to credits within the scope of application, the right to which is only available to entities registered as consumer credit providers in accordance with the Act and certain other groups of entities identified by the Act. Advisory service means the provision of a personal recommendation to a consumer with regard to a credit agreement falling within the scope of chapter 7 of the Consumer Protection Act.1

Exemptions from the obligation to register

The obligation to register under the Act does not apply to

  • Finnish or EEA credit institutions or branches of a third country credit institution
  • micro-enterprises and SMEs that provide consumer credit as a side business only to finance the purchase of the consumer goods they sell, where their credit is interest-free and free of charges
  • payment institutions when the payment institution provides credit related to a payment service
  • pawnbrokers
  • a state, municipality or other public entity.

Notification forms and additional information about registration

Only registered entities are permitted to provide consumer credits and housing association loans and to broker peer-to-peer loans.

More information on the notification procedure can be found here: Authorisations, registrations and notifications

Regulations and guidelines 3/2023

Regulations and guidelines 3/2023 bring together the FIN-FSA’s regulations, guidelines, recommendations and interpretations on the information to be included in the register notification for creditor providers and peer-to-peer loan brokers. Their purpose is to provide guidance on market entry and to streamline the registration process.

Regulations and guidelines 3/2023 highlight the factors to which the FIN-FSA, when interpreting the requirements laid down in the law, pays particular attention when it assesses whether the party submitting the registration notification meets the requirements set for certain consumer credit providers or peer-to-peer loan brokers. The requirements for registration must be fulfilled throughout the period of activity.

Service provision by a Finnish entity abroad and service provision by a foreign entity in Finland

Registration as a consumer credit provider or peer-to-peer loan broker does not grant the right to engage in consumer credit provision or peer-to-peer loan broking abroad; the right depends on the applicable legislation of the country in question.

Registration as a consumer credit provider or peer-to-peer loan broker outside Finland does not grant the right to engage in consumer credit provision or peer-to-peer loan broking in Finland.

Subareas of supervision

In addition to supervising the information in the register notification, the FIN-FSA also supervises other subareas. These include the management of insolvency risks in consumer credit, the maximum LTC ratio, compliance with obligations to prevent money laundering and terrorist financing, and the conduct of entities in their relationship with customers.

In addition, consumer credit providers are obliged to report information on consumer credits and comparable credits to the Positive Credit Register. The Positive Credit Register is regulated by the Positive Credit Register Act, section 16 of which provides for the reporting obligation. The register stores information on credit provided to natural persons.

Contact information

kuluttajaluottorekisteroinnit(at)finanssivalvonta.fi

 

1 If a creditor offers advisory services falling within the scope of chapter 7 of the Consumer Protection Act, it must notify the Financial Supervisory Authority thereof within six months of the amendment to the Act that enters into force on 20 November 2026. The notification should be made in free form to the address kirjaamo@finanssivalvonta.fi.