Response to consultation on draft RTS on credit scoring and loan pricing disclosure, credit risk assessment and risk management requirements for Crowdfunding Service Providers

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Q1: Do you have any comments on the elements to be disclosed to investors in relation to credit scoring, as proposed in Articles 1-5?

We believe that the elements to be disclosed to investors in relation to credit scoring identified by EBA are articulated enough.

Q2: Do you have any comments on the elements to be disclosed to investors as part of the loan pricing framework, as proposed in Articles 6-11?

The goal is for the investor to clearly understand the risks of crowdfunding, as outlined by EBA. As provided for insurance and financial products, we believe that it would be appropriate to provide an information document containing the essential elements.

Q3: Do you consider that the elements for the price of the loan to be fair and appropriate as proposed in Article 11 are sufficient?

The crowdfunding service is expensive enough, due to the structure and regulations envisioned by the RTS proposal. We consider that the elements as proposed in Article 11 are sufficient, since further fragmentation of the elements would result in additional costs.

Q4: Do you have any comments with the information and factors to be considered by crowdfunding service providers in relation to credit risk assessment as proposed in Articles 12-18? Are there other elements that should be taken into account?

We believe that the elements considered in the RTS should only be provided for big project, by identifying appropriate size thresholds. Otherwise, there is a risk that this source of funding will exclude small and medium-sized entities with innovative ideas that seek alternative channels to traditional sources of funding. In fact, the factors envisaged are expensive and would only allow access to large amounts of capital, in spite of small and medium-sized companies which the Crowdfunding Regulation intends to encourage.

Q7: Do you have any comments on the elements to be included in the policies and procedures related to the risk management framework and to credit risk assessment as proposed in Articles 23-28?

As indicated in the response to question 4, the information and factors provided by EBA are really complex and appropriate only for large volumes of business, but not for start-up. There should be simplified provisions for projects below certain thresholds.

Name of the organization

ANASF