NEO FINANCE, AB
RULES ON ASSESSMENT OF CREDITWORTHINESS OF CONSUMER CREDIT BORROWERS
1. GENERAL PROVISIONS
1.1. NEO Finance, AB rules on assessment of creditworthiness of consumer credit borrowers (hereianfter – the Rules) regulate the actions of NEO Finance, AB (hereianfter – the Company) employees acting on behalf of the Company, conducting Client creditworthiness assessments in order to determine whether a consumer credit can be granted to a specific Client, as well as establishing under what Conditions consumer credit may be granted to a specific Client.
1.2. These Rules are prepared and interpreted in accordance with the Republic of Lithuania Consumer Credit Law (Official Gazette, 2011, No. 1-1), the Bank of Lithuania Board Resolution No. 03-62 of March 19, 2013, approving the Creditworthiness Assessment and Responsible Lending Provisions for Consumer Credit Borrowers (edition of the Bank of Lithuania Board Resolution No. 03-45 of March 26, 2024) (hereinafter – the Provisions), the EBA Guidelines on loan origination and monitoring dated May 29, 2020, other applicable legal acts in the Republic of Lithuania, and documents regulating the Company’s work procedures.
1.3. Issues of Client creditworthiness assessment not covered in these Rules shall be determined directly based on the legal acts indicated in paragraph 1.2 of these Rules.
1.4. All Company employees performing the creditworthiness assessment procedure applied by the Company towards Clients must comply with these Rules.
1.5. The terms used in singular in these Rules may be understood as used in plural if required by the factual situation, and vice versa.
2. TERMS AND ABBREVIATIONS
2.1. Company – means NEO Finance, AB, a joint-stock company established under the laws of the Republic of Lithuania, whose registered office is at Ukmergės St. 126, Vilnius, Republic of Lithuania, legal entity code 303225546, data about which is collected and stored by the State Enterprise “Centre of Registers” in the Register of Legal Entities. The Company is entered in the public list of consumer credit providers managed by the Bank of Lithuania and the public list of peer-to-peer lending platform operators managed by the Bank of Lithuania.
2.2. CCL – Consumer Credit Law of the Republic of Lithuania.
2.3. Operator – peer-to-peer lending platform operator, as defined in CCL. For the purposes of these Rules, Operator means the Company acting as Operator.
2.4. Platform – the internet platform managed by the Company, accessible at https://www.paskoluklubas.lt/en
2.5. Consumer credit – as defined by the Consumer Credit Law.
2.6. Loan provider – a person actually providing Consumer credit mediated by the Company as Operator, as defined in CCL.
2.7. Client – a natural person at least 18 years old, who submitted an application for Consumer credit on the Platform and is a potential Consumer credit recipient.
2.8. Consumer credit recipient – a natural person who submitted an application for Consumer credit on the Platform and with whom a consumer credit agreement was concluded. A consumer credit agreement cannot be concluded with a person incapacitated in a certain area, partially incapacitated in a certain area, and in other cases established by the Consumer Credit Law (CCL).
2.9. NASIS - information system in which the list of persons for whom applications have been submitted to prohibit them from concluding consumer credit agreements is indicated. The information system’s administrator and processor, as well as the personal data controller and processor of the information system, is the Bank of Lithuania.
2.10. PR – Population register. The register controller is the state enterprise Centre of Registers (hereinafter – Centre of Registers), which is also the personal data processor.
2.11. PRDB – database administered by the Bank of Lithuania, into which data on loan recipients and loans granted to them are submitted.
2.12. BVKK – total cost of consumer credit, as defined by the Consumer Credit Law.
2.13. BVKKMN – total cost of consumer credit expressed as an annual percentage rate.
2.14. DSTI – ratio of average installment amount to income.
2.15. Personal consumer credit – granted considering only the personal income of the Client and the Client’s and family’s joint obligations, when the Client seeks to conclude or concludes a consumer credit agreement for personal needs. The Client is personally responsible for obligations arising from personal consumer credit.
2.16. Installment – periodic monthly payment which the Consumer credit recipient must pay under the concluded consumer credit agreement. The installment consists of the repaid part of Consumer credit and fees payable for the use of Consumer credit under the specific consumer credit agreement. The installment is determined assuming that the Consumer credit recipient will properly and timely fulfill their obligations under the consumer credit agreement, and does not include interest, penalties, and other costs for the overdue period.
2.17. Terms – the specific Consumer credit amount, repayment period, Installment, and other special conditions of the consumer credit agreement, which qualitatively define the financial obligations undertaken by the Consumer credit recipient under the consumer credit agreement.
2.18. Family – married persons (spouses).
2.19. Set of Consumer credit recipients or Co-borrowers (Co-borrower) – cases when the same consumer credit agreement with the Company is concluded by two or more Clients, who are jointly and severally liable under the agreement and whose income, expenses, and obligations to financial institutions may be evaluated together. Co-borrowers may be persons related by formal (e.g., family) mutual relationships, as well as persons not related by formal mutual relationships (e.g., partners, cohabitants).
2.20. Obligations – the monthly payment amount of financial obligations to financial institutions held by the Client, his spouse, and joint family members (co-debtors). In the case of a personal consumer loan, the Client’s obligations are the sum of the payments of personal and joint family financial obligations to financial institutions held by the Client. The payment amount is calculated separately by calculating the amount of each financial institution obligation, obtained by dividing the remaining loan repayment and loan cost amount of the respective obligation by the remaining loan term in months, and summing the obtained amounts, except for:
2.20.1. loans without partial repayments (unlimited loan agreement, account credit agreement, other loan agreement granting the borrower the right to use credit not exceeding the established credit limit, etc.), the obligation amount is calculated by summing the following amounts:
2.20.2. the unused credit and loan cost amount divided by the entire loan term in months, but not more than 36 months (including unlimited loan agreements);
2.20.3. the used credit and loan cost amount divided by the remaining loan term in months, but not more than 36 months (including unlimited loan agreements).
2.21. Evidence – information confirmed by documents based on which conclusions about the real financial condition of the Client can be drawn, including but not limited to: Client’s bank account statements, information provided in the SODRA database about the Client’s employer, received salary, and work experience, information about the Client’s contracts with other financial institutions provided by UAB "Creditinfo Lietuva" or another database, annual income declarations submitted by the Client to the State Tax Inspectorate, other possible evidence. If the purpose of granting the consumer loan is to cover specific financial obligations of the Client to financial institutions (refinancing), the data about the Client’s obligations can be confirmed by the Client submitting contracts justifying these obligations or a received certificate from PRDB or by providing information during a phone conversation or by email.
2.22. Negative ratio:
2.22.1. A situation where the monthly amount of obligations held by the Client, his spouse, and joint family is greater than 40 percent of the sustainable monthly income received by the Client and his family (co-debtors). When the purpose of granting the consumer loan is to cover specific financial obligations of the Client to financial institutions (refinancing), and the total monthly payment amount and average APR (BVKKMN) of the refinanced obligations are higher than those of the consumer loan granted specifically to cover these obligations, and the Company has evidence that the Client’s DSTI, considering current/refinanced obligations, is higher than the future one after refinancing, the negative ratio is a situation where the monthly amount of obligations held by the Client, his spouse, and joint family is greater than 50 percent of the sustainable monthly income received by the Client and his family (co-debtors).
2.22.2. In the case of a personal consumer loan, when the Client has submitted evidence that for proper creditworthiness assessment, information about only him is sufficient (relevant court decision, prenuptial or postnuptial agreement), the negative ratio is a situation where the monthly amount of obligations of the Client and joint family is greater than 40 percent of the sustainable monthly income received by the Client. When the purpose of granting the consumer loan is to cover specific financial obligations of the Client to financial institutions (refinancing), and the total monthly payment amount and average APR (BVKKMN) of the refinanced obligations are higher than those of the consumer loan granted specifically to cover these obligations, and the Company has evidence that the Client’s DSTI, considering current/refinanced obligations, is higher than the future one after refinancing, the negative ratio is a situation where the monthly amount of obligations of the Client and joint family is greater than 50 percent of the sustainable monthly income received by the Client.
2.22.3. In the case of a personal consumer loan, when the Client has not submitted the above evidence, the negative ratio is a situation where the average payment amount of the Client according to all the Client’s and joint family obligations exceeds 40 percent of the Client’s sustainable income.
2.23. Positive ratio:
2.23.1. The monthly amount of obligations held by the Client, his spouse, and joint family members is not greater than 40 percent of the sustainable monthly income received by the Client and his family (co-debtors). When the purpose of granting the consumer loan is to cover specific financial obligations of the Client to financial institutions (refinancing), and the total monthly payment amount and average APR (BVKKMN) of the refinanced obligations are higher than those of the consumer loan granted specifically to cover these obligations, and the Company has evidence that the Client’s DSTI, considering current/refinanced obligations, is higher than the future one after refinancing, the positive ratio is a situation where the monthly amount of obligations held by the Client, his spouse, and joint family is not greater than 50 percent of the sustainable monthly income received by the Client and his family (co-debtors).
2.23.2. In the case of a personal consumer loan, when the Client has submitted evidence that for proper creditworthiness assessment, information about only him is sufficient (relevant court decision, prenuptial or postnuptial agreement), the positive ratio is a situation where the monthly amount of obligations of the Client and joint family is not greater than 40 percent of the sustainable monthly income received by the Client. When the purpose of granting the consumer loan is to cover specific financial obligations of the Client to financial institutions (refinancing), and the total monthly payment amount and average APR (BVKKMN) of the refinanced obligations are higher than those of the consumer loan granted specifically to cover these obligations, and the Company has evidence that the Client’s DSTI, considering current/refinanced obligations, is higher than the future one after refinancing, the positive ratio is a situation where the monthly amount of obligations of the Client, his spouse, and joint family is not greater than 50 percent of the sustainable monthly income received by the Client and his family (co-debtors).
2.23.3. In the case of a personal consumer loan, when the Client has not submitted the above evidence, the positive ratio is a situation where the average payment amount of the Client according to all the Client’s and joint family obligations does not exceed 40 percent of the Client’s sustainable income.
2.24. Sustainable income – such income of the consumer loan borrower which can be reasonably expected during the consumer loan period. The conclusion about the Client’s sustainable income is made taking into account the average of not less than four months of the Client’s sustainable income history and evaluated whether the sustainable income expected during the loan repayment period is sufficient to meet all obligations to financial institutions.
2.24.1. Four-month sustainable income from wages (work experience) is considered when:
2.24.1.1. The Client has been working in the same workplace for the last four months;
2.24.1.2. If the workplace was changed during the last four months and the Client worked less than one year at the previous workplace, and the new job started the next working day or a break of no more than one working day can be justified by objective evidence, and the new employment contract has no probationary period or the probationary period has ended;
2.24.1.3. If the workplace was changed during the last four months and the Client worked more than one year at the previous workplace, and the new job started the next working day or a break of no more than five working days can be justified by objective evidence, and the new employment contract has no probationary period or the probationary period has ended.
2.24.2. Four-month sustainable income is also considered if during this period the Client was on unpaid leave, except when the unpaid leave was in the last month of the evaluation period.
2.24.3. Sustainable income is also considered when income is received from regular benefits (pensions) for not less than 4 months:
2.24.3.1. If the benefit is temporary, the loan term may not be longer than the benefit payment period;
2.24.3.2. If the benefit is permanent, the loan term is unlimited;
2.24.3.3. If child care benefits vary during the child care period, the sustainable monthly income is calculated based on the lowest monthly benefit;
2.24.3.4. If three-year child care leave is chosen, the loan term cannot exceed the end of the second year’s benefit payment;
2.24.5. Income received from property rental or per diem payments may only be considered as additional income.
2.25. Sustainable monthly income amount – shall be calculated as the simple average by dividing the total income amount for the assessed months by the number of months taken into account during the assessment.
2.25.1. In cases when the Client changed workplaces during the assessment period, the sustainable monthly income amount shall be calculated as follows:
2.25.1.1. If the Client’s income increased at the new job, the income shall be calculated as the simple average based on the last four months;
2.25.1.2. If the Client’s income decreased at the new job, the income shall be calculated using the average of the lower income received at the new workplace.
2.26. Creditworthiness rating – the result of the Client’s creditworthiness evaluation based on the Client’s submitted data and data obtained from databases, as well as social and statistical analyses performed according to the Company’s methodologies.
2.27. Maximum amount of existing obligations – the total amount of consumer loans held by the Client at the Company, excluding interest and all other fees, depends on the Client’s Creditworthiness rating: for A+ and A ratings, the total amount may not exceed 35,000 EUR (thirty-five thousand euros); for B rating, the amount may not exceed 30,000 EUR (thirty thousand euros); for C rating, the amount may not exceed 20,000 EUR (twenty thousand euros); for C- rating, the amount may not exceed 12,000 EUR (twelve thousand euros).
2.28. Maximum number of consumer loans – a Client with a C or C- Creditworthiness rating may receive a consumer loan from the Company only if at least two monthly payments on previously held consumer loans from the Company have been made.
2.29. SODRA – State Social Insurance Fund Board under the Ministry of Social Security and Labour of the Republic of Lithuania.
3. CONTENT OF THE RESPONSIBLE LENDING PRINCIPLE
3.1. When assessing the Client’s (or their spouse’s/co-borrower’s) creditworthiness, the Company’s employee must adhere to the principle of responsible lending. It is considered that the principle of responsible lending is properly followed if all the aspects listed below are implemented:
3.1.1. Each time before deciding to grant a consumer loan to the Client (or, in other cases, to their spouse/co-borrower), the Company’s employee must evaluate the Client’s (or their spouse’s/co-borrower’s) creditworthiness based on sufficient information, also checking the Client in the Credit Register (CR) and NASIS registers. In addition, the Company has the right to verify other databases/public information sources if it is deemed necessary to properly assess creditworthiness;
3.1.2. The purpose of assessing the Client’s creditworthiness is to evaluate the Client’s ability to undertake a specific financial obligation which, together with existing financial obligations, the Client would be able to fulfill;
3.1.3. The Company’s employee must consider all objectively foreseeable significant factors, based on information provided by the Client and available to the Company, which may affect the Client’s ability to pay, especially factors such as the Client’s Sustainable Income, credit history, and potential changes (increase or decrease) in income;
3.1.4. Lending is based on (taking into account historical data, economic cyclicality) the limitation of the ratio between the average payment amount of all the Client’s obligations under consumer credit and other contracts with financial institutions and the Client’s income (debt-to-income);
3.1.5. The Client’s creditworthiness assessment, based on the information available at that time, must be founded on the assumption that the Client will be able to fulfill the assumed financial obligations throughout the term of the Consumer Credit Agreement;
3.1.6. If during the creditworthiness assessment it is established that based on the information available at that time the Client is unable to fulfill the financial obligations throughout the validity period of the Consumer Credit Agreement, the consumer loan must not be granted to the Client.
3.2. The Company’s Consumer Credit granting policy is based on the assumption that the Consumer Credit will be repaid from the cash flows (income) generated by the Client’s earnings, rather than through forced repayment by means of debt collection (pre-litigation / litigation) procedures.
3.3. Before making a decision to increase the current total Consumer Credit amount (i.e., before lending additional funds to the Client), or to refinance the Consumer Credit, or to defer the performance of obligations under the consumer credit agreement (credit restructuring), the Company, relying on sufficient information and evidence, must also assess the creditworthiness of the Client (his/her spouse / co-borrower).
3.4. The Company must inform the Client about his/her obligation to provide accurate and complete information necessary for the assessment of the Client’s (his/her spouse’s / co-borrower’s) creditworthiness.
4. INFORMATION COLLECTED DURING THE CREDITWORTHINESS ASSESSMENT
4.1. When assessing the Client’s creditworthiness, the following information must be collected from the Client:
4.1.1. If a personal consumer credit is chosen – the average sustainable income of the Client, or alternatively of the Client and his/her spouse (co-borrower), over the past 4 months;
4.1.2. If a personal consumer credit is chosen – the sources of sustainable income of the Client, or alternatively of the Client and his/her spouse (co-borrower), along with documents substantiating the receipt of sustainable income:
a) if income is earned under an employment contract – information from the SODRA database or a bank statement, or a certificate from the employer (signed by a responsible person and stamped if the employer has a stamp) confirming the salary paid;
b) if income is earned from property rental – the lease agreement and bank statement. If the Client (or alternatively his/her spouse / co-borrower) has declared income, the income declaration for the previous calendar year;
c) if income is earned from individual activity – information from the SODRA database, income tax declaration for the previous calendar year, documents confirming income and expenses for the current and previous years (bank statements confirming cash flows, income and expense journals), certificate of individual activity and documents proving continuity of activity (contracts, orders);
d) if the Client or his/her spouse (co-borrower) receives income from activity under a business certificate – business certificate, income tax declaration for the previous calendar year, documents proving continuity of activity (contracts, orders), documents confirming income and expenses for the current and previous years (bank statements confirming cash flows, income and expense journals);
e) if the Client or his/her spouse (co-borrower) receives income in the form of regular payments – information from the SODRA database or bank statement and copies of documents substantiating receipt of regular payments;
f) if the Client or his/her spouse (co-borrower) receives income from a Small Partnership activity – the assessed information about the Client’s monthly declared income as recorded in the SODRA database;
g) if the Client or his/her spouse (co-borrower) receives income from daily allowances – bank statement;
h) other income sources not listed above and the documents substantiating them.
4.1.3. The amount of liabilities shall be collected separately by group:
4.1.3.1. Liabilities under consumer credit agreements, excluding liabilities under linked consumer credit agreements and credit card agreements;
4.1.3.2. Liabilities under housing credit agreements;
4.1.3.3. Liabilities under leasing agreements (i.e., linked consumer credit agreements);
4.1.3.4. Liabilities under credit card and credit line agreements;
4.1.3.5. Other financial liabilities to financial institutions not specified above.
4.1.4. The Client’s credit history for at least the past 6 months and information on whether the Client is or has been in default on financial obligations, as provided by UAB “Creditinfo Lietuva”;
4.1.5. The Client’s confirmation as to whether their or their family’s (co-debtor’s) income or expenses will change during the entire term of the Consumer Credit Agreement. If a personal consumer credit is selected, the Client confirms whether their personal income or expenses will change during the entire term of the consumer credit agreement. If the Client confirms that their or their family’s (co-debtor’s) income or liabilities will change during the term of the consumer credit agreement, or in the case of personal consumer credit, the Client confirms that their personal income or liabilities will change during the term of the consumer credit agreement, information must be collected on what kind of change is expected and how it will affect the Client’s (or their spouse’s / co-debtor’s) ability to fulfill obligations under the consumer credit agreement;
4.1.6. A Client whose income may fluctuate significantly (e.g., income from dividends, shares, investment activities, etc.) or whose income sustainability is in doubt shall be assessed more conservatively.
4.2. If the Client fails to submit all or part of the required information, the Consumer Credit shall not be granted to the Client (or their spouse / co-debtor). The Company must retain the information (assessed and collected) during the creditworthiness assessment process for 3 years from the date the obligations under the Consumer Credit Agreement are fulfilled, unless other legal acts set a longer retention period for this information, data, and documents, in order for the consumer credit provider to be able, if necessary, to prove that the consumer credit recipient's creditworthiness was properly assessed.
5. EVALUATION OF COLLECTED INFORMATION
5.1. All information collected during the creditworthiness assessment must be supported by Evidence. If the Client and the Company cannot substantiate the information provided about Sustainable income with Evidence, such information shall not be taken into account. If the Client and the Company cannot substantiate the information provided about Liabilities, but the Client discloses the existence of such Liabilities to the Company, such information shall be taken into account. When reviewing a request to grant consumer credit, the Company shall thoroughly assess the collected information about the Client's (or, where applicable, their spouse’s / co-debtor’s) personal circumstances and financial situation and, if deemed necessary, shall request additional data or documents.
5.2. Only Sustainable income and Liabilities of the Client and their family (co-debtor) that exist at the time of the creditworthiness assessment are evaluated. In the case of personal consumer credit, only the Sustainable personal income and Liabilities of the Client that exist at the time of the creditworthiness assessment are evaluated.
5.3. When assessing the income of the consumer credit recipient, the credit provider takes into account the actual income received by the consumer credit recipient at the time of the creditworthiness assessment, existing financial liabilities (including their remaining term, interest rates, outstanding amounts, and repayment history), as well as projected future income—provided that the income reduction is supported by objective data and any expected increase in income is supported by appropriate Evidence.
5.4. If the Client submits an income tax return for the previous calendar year, but does not attach any additional documents proving that the declared income was received over a period shorter than the full calendar year, it shall be presumed that the declared income was earned over the entire previous calendar year, and the declared amount is divided by 12 (twelve) months to calculate the Client's average monthly income for the declared year. If the Client submits evidence on the basis of which it can be determined that the declared income was received over a shorter period than the full previous calendar year, the declared income shall be divided by the number of months during which the declared income was actually received.
5.5. When evaluating the collected and Evidence-based data on the Client’s Sustainable income and existing Liabilities, the ratio between the Client’s and their family’s sustainable monthly income and their total Liabilities is calculated. In the case of personal consumer credit, the ratio is calculated between the Client’s sustainable personal monthly income and their Liabilities.
5.6. If the Client and the Company agree that the purpose of granting the Consumer Credit is to cover specific financial obligations the Client has towards financial institutions, and the Company ensures that the Consumer Credit funds will be used exclusively for the repayment (refinancing) of these specific obligations, then, when calculating the total amount of Liabilities, such specific obligations are not included.
5.7. If the ratio defined in Clause 5.5 of the Rules is Negative, the Consumer Credit is not granted to the Client.
5.8. If the ratio defined in Clause 5.5 of the Rules is Positive, the procedure set out in Chapter 7 of these Rules shall be followed.
5.9. When assessing the Client’s obligations, consideration is given not only to the ratio between existing obligations and Sustainable income, but also to ensure that the minimum amount of income left for living expenses after the credit is granted is not less than the Minimum Consumption Needs Amount (MCNA) as published by the Ministry of Social Security and Labour of the Republic of Lithuania. This amount may vary depending on:
5.9.1. the average salary in the municipality where the Consumer Credit recipient resides, as published on the official statistics portal for the previous calendar quarter, in comparison to the national average salary. That is, the minimum remaining income threshold is determined by multiplying the MCNA by a coefficient that reflects the ratio between the average salary in the Client’s municipality and the national average salary;
5.9.2. the purpose of the loan (e.g., in cases of refinancing).
5.10. Fixed-term employment contracts are treated as permanent (open-ended) in the following cases:
5.10.1. If the employment or service contract is concluded with a statutory officer (civil servant with special status), and the probationary period has ended or no probationary period was set, then such employment contracts are considered to be permanent;
5.10.2. In other cases (e.g., medical residents, heads of educational institutions, or representatives of other professions), the Company has the right, upon collecting additional evidence, to decide to treat the contract as permanent. This decision is made after conducting a thorough and comprehensive assessment of the credit recipient’s financial situation and individual circumstances (characteristics), provided that there is no sufficient reason to believe that the Client’s income continuity might be interrupted after the expiration of the current fixed-term contract or term of office.
6. ADDITIONAL RULES APPLIED WHEN ASSESSING THE CREDITWORTHINESS OF CO-BORROWERS
6.1 All the requirements of the Rules apply equally to both the principal borrower and the Co‑borrower (i.e., the same documents and information are required and assessed as for the principal borrower). The provisions of this section additionally apply when assessing the creditworthiness of natural persons who are not married to each other but intend to become Co‑borrowers (jointly responsible for the fulfillment of the consumer credit agreement). This means that a Co‑borrower is an equal participant in the Consumer Credit Agreement, and therefore their financial situation (creditworthiness) is assessed with the same thoroughness and detail as that of the principal borrower.
6.2. The obligation of Co‑borrowers is joint and several; legally, any Co‑borrower assumes full responsibility. However, a joint and several obligation does not, by itself, require the Company to assess each Co‑borrower as if they were taking out the entire credit alone—doing so would be considered excessive and practically restrictive of the Co‑borrowers' needs and capabilities. In other words, the law does not require that each Co‑borrower be capable of covering the entire loan by themselves. The creditworthiness assessment is a probabilistic evaluation predicated on the assumption that all Co‑borrowers will fulfill (be able to fulfill) their obligation as agreed.
6.3. If the consumer credit recipients are two or more persons (Co‑borrowers), their income, expenses, and financial institution obligations may be assessed jointly. This means the Company may calculate a joint DSTI ratio by mathematically summing the Co‑borrowers' sustainable incomes and their financial institution liabilities.
6.4. Although the Company reserves discretion to assess the Co‑borrowers' data jointly, such assessment must not violate the fundamental responsible lending requirements set out in Article 8, Paragraph 4 of the Consumer Credit Law (CCL) and in Section II of the Rules.
6.5. When assessing the creditworthiness of Co‑borrowers and deciding to grant them a consumer credit, the Company must ensure that approval does not rely solely on the financial status of just one Co‑borrower. To ensure that a Co‑borrower is not being used solely for formality to obtain a favorable credit decision, the Company assesses all significant circumstances and risks. Before granting credit to unmarried Co‑borrowers, the Company confirms the Co‑borrowers’ willingness to enter into such a transaction and assume joint and several obligations with respect to the Company. The Company also collects information about the Co‑borrowers' declared residence and their relationship (cohabitation, partnership, shared household). In cases where one Co‑borrower’s financial situation is complex, the Company additionally requires Co‑borrowers to submit documentation such as: a rental agreement, shared utility bills, proof of joint child custody or a birth certificate, a joint bank account statement, or other evidence (confirmation) of their existing relationship.
7. DECISION ON GRANTING CONSUMER CREDIT
7.1. Consumer credit is granted to the Client only if the ratio between the Client’s liabilities, including the specific installment amount of the granted Consumer Credit, and the Client’s sustainable income corresponds to the positive ratio specified in Clause 2.23 of the Rules.
7.2. Consumer credit is not granted to the Client if at least one of the following conditions is met:
7.2.1. The ratio between the Client’s liabilities, including the specific installment amount of the granted Consumer Credit, and the Client’s sustainable income corresponds to the negative ratio specified in Clause 2.22 of the Rules;
7.2.2. The Client would exceed the Maximum amount of existing liabilities specified in Clause 2.27 of the Rules;
7.2.3. The Client would exceed the Maximum number of consumer credits specified in Clause 2.28 of the Rules;
7.2.4. The Client’s minimum remaining income for subsistence after granting the credit would be lower than the amount specified in Clause 5.9 of the Rules.
7.3. If the Company decides to grant the Consumer Credit to the Client, the Client is informed via SMS and/or email about the prepared Consumer Credit offer and the validity period of the offer. The Company may also inform the Client about the decision during a phone call.
7.4. If the Client does not confirm the provided Consumer Credit offer within the validity period specified in the offer, the offer becomes invalid.
7.5. The credit amount is disbursed to the Client only after the Consumer Credit Agreement is concluded.
7.6. The Client is informed about the decision not to grant Consumer Credit via the Platform and/or by email and/or SMS. The Company may also inform the Client about the decision during a phone call.
7.7. The maximum Consumer Credit amount that can be granted via the Platform is determined by an order of the Company’s Head of Administration.
7.8. The possibility to increase the Consumer Credit amount is not provided to the Consumer Credit recipient.
8. FINAL PROVISIONS
8.1. These Rules come into force on the date of their approval and remain valid until they are repealed or amended by an order of the Company's Head of Administration.
8.2. Any amendment or invalidity of a provision of these Rules due to changes in or the cessation of mandatory legal regulations does not affect the validity of the remaining provisions of the Rules. In such cases, the applicable legal acts shall apply in place of the invalidated provisions.
8.3. These Rules must be reviewed at least once per calendar year, as well as upon any changes to mandatory legal requirements.