The aspiration to the profession of credit intermediary in Bulgaria raises many questions among candidates who are looking for professional support to successfully start their activity. One of the most frequently asked questions is: “How to become a credit intermediary in Bulgaria?”, which implies the need to familiarize yourself with the process of registering a credit intermediary in the BNB. There is also interest in the requirements for licensing and entry in the Register of Credit Intermediaries, as well as the conditions that must be fulfilled according to the BNB Ordinance No. 19 on Credit Intermediaries. Elan Consulting, as an established consulting firm, provides comprehensive support in this process, including the clarification of specific questions such as: “What documents are needed for registration of a credit intermediary?” and “What are the obligations of a credit intermediary once it is entered in the register?”.
Along with this, there is considerable interest in the topic of remuneration and commissions associated with this profession. Customers often ask: “What is the commission of a credit consultant?” and “What is the salary of a credit consultant in Bulgaria?”. In addition, many seek opinions and recommendations regarding “Working as a Credit Consultant”, which implies the need to understand the daily tasks and responsibilities that accompany this role. Elan Consulting can offer professional support not only in the process of registration and licensing, but also in the provision of expert advice regarding the determination of appropriate commissions and remuneration structures.
The professional approach of Elan Consulting, with many years of experience in the field of accounting services of credit intermediaries, is available to all who are interested in “How to become a credit intermediary” not only in large cities such as Sofia, Plovdiv, Varna and Burgas, but also in smaller settlements such as Pomorie, Karnobat, Sunny Beach, Aytos, Nessebar, Sozopol, Primorsko and others. In addition to the legal aspects related to BNB registration, our consultants provide expert advice and assistance in the creation and management of credit intermediaries - both under the legal form of limited liability companies (LLCs) and as individuals and sole traders, paying attention to all regulatory and operational aspects to ensure the successful development of your business within this dynamic sphere.
The profession of credit intermediary is an activity in which a natural or legal person acts as an intermediary between borrowers and creditors in order to assist borrowers in obtaining credit, whether mortgage, consumer or any other type of credit. The credit intermediary provides advice, analyzes the financial situation of the client, offers the most suitable credit products and can mediate in the conclusion of credit agreements. The activity of the credit intermediary is strictly regulated in the Consumer Real Estate Loans Act and Ordinance No. 19 of the Bulgarian National Bank (BNB) on credit intermediaries.
According to the provisions of the Consumer Real Estate Loans Act, in Art. 51, a credit intermediary can only be a person who is registered in the register of BNB. This register includes information about all persons who have received a license to carry out such activity, and it is mandatory that the credit intermediary meets a number of conditions. In particular, Article 52 (1) states that the credit intermediary must have appropriate education and professional experience to ensure that he will be able to competently perform his duties. In addition, he must have “Professional Liability” insurance, which covers his liability to third parties, as specified in art. 52, (2).
The obligations of the credit intermediary include providing clear and understandable information to customers on the terms of the loans offered, while being obliged to act in good faith and in the interests of the client. Article 54 (1) of the Act stipulates that the credit intermediary is not entitled to receive remuneration or other material benefits from creditors unless this is clearly agreed and approved by the consumer of the credit service. This provision is intended to ensure the independence of the credit intermediary and to prevent possible conflicts of interest.
With regard to regulation, Regulation No. 19 of the BNB on credit intermediaries defines additional requirements and procedures that the credit intermediary must comply with. For example, Article 7 states that the credit intermediary must keep detailed accounts of its activities and provide regular reports to BNB. In addition, the regulation requires credit intermediaries to undergo regular audits to ensure that their activities comply with legal requirements.
The definition of “credit intermediary” can be found in the Supplementary Provisions of the Consumer Real Estate Loans Act, where §1, item 6 specifies that this is any person who is not a creditor and who, for remuneration, mediates in the conclusion of credit agreements or provides advice in connection with loans.
Credit intermediaries in Bulgaria are subject to strict supervision and must meet a number of requirements, including financial, professional and ethical standards, to ensure that their services benefit consumers and that they operate within the law. Along with this, they must comply with all obligations related to the accountability and transparency of their activities, which is regulated in detail in the relevant laws and regulations.
Credit intermediaries in Bulgaria have both rights and obligations, which are clearly regulated in the legislation. The main right of a credit intermediary is to provide intermediary services between borrowers and creditors. This right includes the possibility to advise clients on the most appropriate credit products, to mediate in negotiations with creditors and to assist in the conclusion of credit agreements. According to the Consumer Real Estate Loans Act, the credit intermediary has the right to remuneration for the services provided, which must be agreed with the client in advance and clearly stated in the contract.
On the other hand, credit intermediaries have a number of obligations that are aimed at protecting the interests of customers and ensuring transparency in their activities. One of the main commitments of the credit intermediary is to provide clear, accurate and complete information to consumers about the credit products they offer them. This obligation is regulated in Art. 55, (1) of the Consumer Real Estate Loans Act, which states that the information must be provided in a manner that is understandable to the client and include all the essential conditions of the loans offered, including possible risks and fees.
The credit intermediary is obliged to act in good faith and in the best interests of the client. This means that he cannot receive commissions or other benefits from creditors unless this is previously agreed and approved by the client. The legislation expressly prohibits the credit intermediary from misleading customers or concealing important information that could lead to an incorrect decision on the part of the client. Article 56 emphasizes that the credit intermediary must comply with all contractual obligations and inform the client of any changes that may occur in the process of negotiating and concluding the loan.
The obligations of credit intermediaries include regular reporting to the Bulgarian National Bank. Regulation No. 19 of the BNB on credit intermediaries stipulates that they must keep detailed accounts of their activities, as well as provide regular reports to BNB, including information on contracts concluded and commissions received. This obligation is aimed at ensuring the transparency and reliability of the activities of credit intermediaries.
In addition, the credit intermediary must have professional liability insurance to cover possible damage caused to customers due to negligence or improper performance of his obligations. This requirement is specified in Art. 52, (2) and is a key element for ensuring the protection of consumers' interests.
Credit intermediaries in Bulgaria receive remuneration in the form of a commission for the services provided in mediation between borrowers and creditors. The amount of this commission usually varies in the range from 1% to 3% of the total loan amount, the exact percentage depends on the terms of the contract between the credit intermediary and its client. According to the provisions of the Consumer Real Estate Loans Act, the commission must be clearly agreed and specified in the contract before the service is provided. In this context, the credit intermediary is obliged to inform the client about the exact amount of the commission, as well as about any other costs that may arise in the mediation process.
The law provides that the commission of the credit intermediary must be fair and proportional to the services provided. Article 54 (1) of the Consumer Real Estate Loans Act emphasizes that the credit intermediary may not receive any other remuneration or benefits from creditors unless this is clearly agreed and approved by the client. This provision is intended to ensure transparency in the relationship between the credit intermediary and its clients and to prevent possible conflicts of interest.
Assuming that the commission is in the range from 1% to 3%, we can consider the following example of calculating the profit from this activity. If the credit intermediary mediates in the granting of a loan in the amount of BGN 100,000, its commission may be between BGN 1,000 (at 1% commission) and BGN 3,000 (at 3% commission). That is, the profit of the credit intermediary depends on both the amount of the loan and the agreed commission rate.
It is important to note that in addition to the main commission, the credit intermediary may have other expenses related to the activity, such as Professional Liability Insurance, which is mandatory under Art. 52, (2). These costs must be taken into account when calculating the total profit from the activity.
In order to ensure that the commission is justified and proportionate to the services provided, credit intermediaries should keep transparent accounts of their income and expenses. In this sense, BNB Regulation No. 19 on credit intermediaries requires regular reporting and reporting to the regulatory authority, which further strengthens control over this activity and ensures the protection of clients' interests.
The credit intermediary in Bulgaria can offer a variety of services aimed at assisting individuals and legal entities in obtaining loans. These services include consulting, mediation in the negotiation of credit terms, as well as assistance in the conclusion of credit agreements. The main goal of a credit intermediary is to facilitate customers in the process of obtaining a loan and provide optimal conditions for them.
The first and most important service that a credit intermediary can provide is to advise the client on the different types of loans that are available on the market. This includes an explanation of terms, interest rates, repayment terms and all other important aspects related to loans. The credit intermediary must provide the client with clear and understandable information about the credit products offered so that the client can make an informed decision. According to Art. 48, para. 1, item 3 of the Consumer Real Estate Loans Act, the credit intermediary is obliged to inform the client of all expenses that will be associated with the loan, including commissions, fees and other expenses.
Another important service is mediation when negotiating the terms of credit agreements between the borrower and the creditor. The credit intermediary may assist the client in negotiating with the lender to obtain better terms, such as lower interest, longer repayment periods or more favourable collateral conditions. In this process, the credit intermediary must act in the interest of the client and strive to provide the best possible conditions, in accordance with Art. 48, para. 2, item 2 of the ZKNIP.
The credit intermediary may also provide a service to assist in concluding a credit agreement. This includes preparing the necessary documents, filling out applications and contracts, as well as providing assistance in finalizing the transaction. The credit intermediary plays the role of a connecting link between the borrower and the creditor, ensuring the smooth running of the process and compliance with all legal requirements.
In addition, the credit intermediary can also offer credit management services after its granting. This may include monitoring the repayment of the loan, providing information on outstanding payments, as well as advice on refinancing or restructuring the loan if necessary. These services are relevant to maintain the financial stability of the client and to avoid potential problems in servicing the loan.
It is important to note that a credit intermediary does not have the right to provide credit products on its own behalf or to act as a creditor, unless it has received the appropriate authorization to do so. Its role is to facilitate the interaction between the borrower and the creditor by providing professional advice and mediation.
Registration as a credit intermediary in Bulgaria requires compliance with strict requirements regulated by the Consumer Real Estate Loans Act (ZKNIP) and Ordinance No. 19 of the Bulgarian National Bank (BNB). The process begins with the submission of a written application to BNB, which must include the necessary documents and information, in accordance with the requirements of the law and the regulation.
First of all, the applicant must provide detailed information about himself, including name, personal identification number and permanent address for natural persons, or name, EIC, registered office and address of management for legal entities. This is necessary in order to correctly identify the applicant and determine whether he meets the requirements for registration. If the applicant is a legal entity, data on the persons who manage and represent the company must also be provided.
Other documents must be attached to the application, including copies of concluded contracts with creditors, if the intermediary is bound by them. This requirement is important for BNB to ensure that the intermediary complies with all regulatory requirements and that the contracts are legal and valid.
In order to be registered as a credit intermediary, a person must prove that he also has the necessary qualifications and professional experience. The law requires the applicant to have a completed higher education, which is a mandatory requirement and must be proved by a notarized copy of the diploma. This requirement is specified in Art. 2, para. 5, item 2 of the Bulgarian National Bank Ordinance No. 19. In addition to education, the applicant must also have professional experience in the field of credit intermediation or similar activity, sufficient for the performance of the duties of a credit intermediary.
The professional experience and qualifications of the person must be described in detail in a questionnaire-declaration, which is filled out by the applicant and submitted together with the rest of the documents. This declaration is necessary in order to assess the reputation and competence of the applicant, including all relevant knowledge and skills in the areas specified in Article 48, paragraphs 2 and 3 of the ZKNIP. In the event that the applicant has additional qualifications or certificates, they must also be presented with notarization, as specified in Art. 2, para. 5, item 5 of Ordinance No. 19.
A person applying for registration as a credit intermediary must also declare that he has no criminal records or other circumstances that could cast doubt on his reputation and ability to perform his duties in good faith. This declaration is required to assure BNB that the applicant is reliable and able to manage the risks associated with credit intermediation.
It is important to note that for legal entities applying for registration, all persons who manage and represent the company must also meet the above requirements for qualifications and experience. This also includes the provision of the relevant documents for each of them, as specified in Article 2, paragraph 5 of Ordinance No. 19.
One of the key requirements is the existence of a valid professional liability insurance, which must cover the activities of the intermediary both in Bulgaria and in other EU Member States, if the intermediary intends to operate in their field. The insurance must be paid in full, and the documents certifying this must be attached to the application.
In addition, applicants are required to provide copies of an identity document, a notarized copy of a diploma of completed higher education, and for applicants who are not Bulgarian citizens, a certificate of absence of criminal record is also required. These documents are necessary in order to verify that the applicant meets all the qualification requirements established by law.
Also, the applicant must declare that he has not been declared bankrupt and that there are no outstanding obligations to creditors or consumers. This declaration serves to ensure confidence and stability in the activities of the credit intermediary, while protecting the interests of customers.
Once all documents have been submitted and examined by BNB, if all conditions are met, BNB will enter the applicant in the register of credit intermediaries. In the event of incompleteness or errors in the documents, BNB may suspend consideration of the application until the deficiencies are rectified. After all, successful registration depends on the completeness and correctness of the submitted documents, as well as compliance with all legal requirements.
The procedure for obtaining a license for a credit intermediary in Bulgaria is regulated in the Consumer Real Estate Loans Act (ZKNIP) and Ordinance No. 19 of the Bulgarian National Bank (BNB). This procedure includes several key steps that must be strictly followed to ensure successful registration and licensing as a credit intermediary.
The procedure begins with the submission of an application to the BNB, which must be accompanied by a certain set of documents. The application must include information about the natural person (name, personal identification number and permanent address) or about the legal entity (name, TIN, registered office and address of management). If the applicant is a legal entity, the application must also indicate the persons who manage and represent the company, and they are also required to provide the relevant documents.
One of the main requirements for obtaining a license is the presence of professional liability insurance. This insurance must cover the liability of the credit intermediary for damage caused to third parties in the course of its activities. A document certifying the conclusion and full payment of this insurance must be attached to the application. According to Article 2, paragraph 4, item 1 of Ordinance No. 19, the insurance must be valid both on the territory of Bulgaria and in other EU Member States if the intermediary plans to carry out activities there.
Another important aspect of the procedure is the proof of the qualifications and professional experience of the applicant. For individuals and persons who manage and represent the legal entity, it is necessary to provide documents such as a notarized copy of a diploma of higher education and a questionnaire-declaration that certifies their professional competence and reputation, in accordance with Art. 2, para. 5 of Ordinance No. 19. In addition to these documents, the applicant must also provide a criminal record certificate or a similar document if he is a foreign citizen.
After all documents have been collected and filled in, the application for registration and licensing is submitted in paper and electronic form through the automated system of BNB. The system requires a qualified electronic signature (KEP) to submit the documents electronically, as specified in the BNB guidelines.
After submitting the application, BNB examines the submitted documents and checks their compliance with the legal requirements. If all requirements are met and the documents are in order, BNB enters the applicant in the register of credit intermediaries and issues a license to operate as a credit intermediary. In case of incompleteness or errors in the documents, BNB shall notify the applicant and the procedure may be temporarily suspended until their elimination, pursuant to Article 3, paragraph 2 of Ordinance No. 19.
The term for consideration of the application and the attached documents is one month from the date of their entry!
The process ends with the issuance of an order for entry in the register of credit intermediaries or a refusal to enter. In the event of refusal, the deputy governor of BNB, managing the Bank Supervision department, or a person authorized by him, issues a refusal order stating the reasons for which the application was rejected. Entry in the register becomes a fact when all requirements are met and the documents are approved.
Registration of a credit intermediary in Bulgaria requires the provision of various documents proving both the identity and legal capacity of the applicant, as well as his qualifications and professional experience. These documents must be submitted to the Bulgarian National Bank (BNB) and comply with the requirements set out in the Consumer Real Estate Loans Act (ZKNIP) and BNB Ordinance No. 19.
The first step is to submit an application for registration, which includes basic information about the applicant. For natural persons, name, personal identification number and permanent address are required, and for legal persons — name, TIN, registered office and address of management. If the applicant is a legal entity, the persons who manage and represent it must also be indicated.
In order for the application to be valid, the following documents must be attached:
After submitting all the necessary documents, BNB examines the application and, if all the conditions are met, enters the applicant in the register of credit intermediaries. In the event of deficiencies or incomplete documents, BNB may temporarily suspend the procedure until all omissions are corrected.
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The credit intermediary in Bulgaria is obliged to comply with high ethical standards, which are fundamental for building trust with customers and ensuring transparency in its activities. He must act in good faith and put the interests of the client first, providing clear, accurate and comprehensive information about the credit products offered. This includes an explanation of all the conditions, fees and risks associated with the loan, without hiding important details. The credit intermediary is not entitled to accept remuneration or other benefits from creditors unless this is clearly agreed and approved by the client. All actions of the intermediary must be aimed at protecting the interests of customers and comply with legal requirements and regulations.
The credit intermediary plays a key role in refinancing an existing loan, helping the client to find better terms and optimize their loan costs. This may include a reduction in interest rates, an extension of the loan term or even a change in the type of loan, for example, from consumer to mortgage. The intermediary assists the client in negotiations with the new lender and prepares all the necessary documents for refinancing. It also provides advice on the possible benefits and risks associated with refinancing, ensuring that the client is fully informed and can make the best decision according to their financial needs.
After registration, the credit intermediary has the obligation to inform the Bulgarian National Bank of any changes in circumstances that may affect its activities. This includes changes in the management of the legal entity, change of address, termination of contracts with creditors or any other significant changes. Any change must be declared in due time, submitting the necessary documentation and following the established procedure for updating the registration. These obligations are important to maintain transparency and fairness in the activities of the credit intermediary, as well as to ensure compliance with regulatory requirements.
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