A pilot on an existing crowdfunding permission

The firm is a proveedor de servicios de financiación participativa. It already lets people fund businesses, and it already moves those euros through a payment firm. The pilot does not ask it to become a different kind of institution. It asks it to let Lend2Friend bring lenders and businesses onto the firm's book, and to run the system that matches them, on loans the firm's own rules already know how to accept. Bringing the two sides is the start. The loans, and the investment those loans are, come from the match.

Lend2Friend is the technology supplier and the operator of the screen. It does not provide the crowdfunding service in its own name. It does not hold client money. It does not decide, in its own name, which business may borrow. It prepares the file, applies the rules the firm has approved, and stops where those rules say stop.

Each loan is a contract between the person who lends, the business that borrows, and the firm. The person is the lender of that named loan. The business receives the full principal and repays it in the same amount each month. Interest each month is on the balance still owed. The firm collects a fee of X points a year from interest the business actually pays. X is the same on every loan, and the operating agreement records it. Lend2Friend is paid by a software invoice: a fixed amount, plus a share of the fee the firm actually collects. The share is the same on every loan, so it does not depend on which business is chosen.

Borrowers are autónomos and companies borrowing for the business. A person borrowing for a purpose outside their trade is not in the pilot. Geographic and residency limits sit in the operating agreement, not in this note.

The contribution is the system that matches lenders to businesses, and that keeps matching them as the book grows. Lenders and businesses are brought onto the book. A loan appears when the system finds a fit. One business may be funded by several lenders in the same pass; one lender may fund several businesses. Each fit is a loan that was not on the firm's book before. That loan is the investment, and the firm's fee is earned on it.

A lender names an amount, the lowest yearly rate they will accept, and the shortest and longest term they can be without the money. A business names an amount, the most it will pay in yearly interest, and the term it needs. A pair can be matched when the business can pay at least X points a year more than the lender will accept, the term sits inside the lender's band, the two are different people, and the firm has approved the business.

A business is matched only when the money already free on the book can cover the whole amount it asked for. Anything less stays open until a later pass can finish it. The system does not reserve idle euros for an incomplete ask. Among asks that can be finished whole, it takes the largest first, then the next largest that still fits, so leftover money keeps funding smaller asks the pool can complete. Where one lender could fund two businesses, and a second lender can reach only one of them, the first lender is not used up on the business the second lender needs. Only among ways of completing those same asks does the system prefer the wider gap between the two rates, and then the order that has been waiting longer. The wider gap does not increase the firm's fee. Any amount above the X points is split between the lender and the business. Lend2Friend's variable charge is a share of the fee the firm collects, the same share on every loan. The system has nothing to gain by steering a euro toward one approved business rather than another.

The effect is continuous. When money finishes its four days, the open book is cleared together against every approved ask that already fits. Returned principal that the lender puts back to work joins the same book. A business is funded by the live money that already fits it, rather than by a round the firm has to assemble. The same capital, matched again as it returns, produces more loans than a single introduction would. That is the investment the channel adds.

Where the firm's authorisation includes individual portfolio management of loans, the allocation runs from the mandate the lender has already given. Where it does not, the same system proposes the fit and the lender confirms the business. The permission decides whether the confirmation is given once or each time. In both cases the match is what creates the loan.

The firm contributes four things. It already has all four. It is not asked to build a product, to hire a team for this channel, or to change its payment firm.

• The permission. Its authorisation to facilitate loans to businesses. If that authorisation also includes individual portfolio management of loans, later loans can be filled from a mandate the lender has already given. If it does not, the lender confirms each business. The pilot uses whichever of those two the authorisation actually contains.
• The payment rails. The payment firm the crowdfunding firm already uses: the accounts, the safeguarded funds, the transfers in, and the payouts out. Lend2Friend receives a key that can ask for movements inside those accounts. The firm can revoke the key, and revocation is immediate.
• The credit and pricing policy. The same policy the firm uses for a business loan today. Lend2Friend does not bring a second credit box. A file the policy does not clear is not funded.
• The approvals that only the firm can give. The credit refusal. The answer to a complaint. The response to an incident. The right to stop the channel.

Lend2Friend carries the matching system, and the work of running the channel every day, inside the boundary in the previous section.

• The brand and the marketplace for the pilot — so Lend2Friend can attract lenders and businesses onto your book.
• The screens a person and a business use: the rate, the term, the match, the state of each euro, and the list of loans.
• The preparation of each business file in the shape the firm's credit desk already reads, including the chase of missing documents. The desk sees a complete file, or it sees nothing.
• The matching system in section 02. Lend2Friend operates it inside rules the firm has approved. It proposes a loan only where those rules have already said yes. It does not look for a higher fee. The firm's fee is the same X points on every loan.
• The operation of the software against the payment firm's interface: identity, incoming transfers, the four-day hold, payout of principal, collection of instalments, and the split. The payment firm executes. Lend2Friend records the result.
• The first answer to a question about the screen. A complaint about the loan, the firm, or the money is placed in the firm's hands the day it arrives.
• A mirror of the ledger. The payment firm's record is the record of the money. Where the two disagree, the payment firm is followed, and the difference is raised the same day.

The table is the operating split. Decides means the action is not taken unless that party has said yes. Does means the daily work. The payment firm is named separately because it, and not Lend2Friend, is the party that holds and moves the euros.

The business receives the full principal at the start. Each month it pays the same amount, set so the loan is cleared over the agreed term. Interest that month is one twelfth of the yearly rate, charged on the balance still owed, so it falls as principal comes back. The rest of the payment is principal. The yearly rate the business pays is X points a year above the yearly rate the lender receives. That gap is the firm's fee. It is disclosed on the loan. It is taken only from an instalment the business has actually paid. It does not change according to which business is chosen.

Where the business is willing to pay more than X points a year above the lender's minimum, the extra is split equally between the lender and the business. An odd leftover basis point lowers what the business pays. The firm's X points are unchanged.

The example uses the suggested figure, X at 2.00 points. A loan of €6,000 over 12 months, with the lender at 4.00 percent a year and the business at 6.00 percent, produces a payment of €516.40 a month. The balance below is the amount still owed at the start of that month.

The last payment is €516.39, the amount required to finish the loan. Across a year in which every instalment is paid, the lender receives €131.19 of interest and the firm receives €65.60.

The pilot takes loans from about €1,000 to €10,000, for terms of 1 to 36 months, and only inside the band the firm's policy will approve. The product will not offer a yearly rate above 20 percent. A lower ceiling in the firm's policy prevails. A loan small enough to skip a credit check and an information sheet is not offered.

The person uses the bank account they already have. They are not asked to open a separate wallet, and their card is not charged. A card payment can be disputed after the business has been paid. A direct debit of the principal can be reversed for weeks. A transfer from their own IBAN is the rail that does not come back of its own accord. Repayments return to that same IBAN.

1. Identity. The payment firm's hosted check runs inside the Lend2Friend screen. It takes a few minutes. The holding of the money is opened in the background, under the firm's arrangement with the payment firm. The person sees their own IBAN as the place money comes from and the place it goes back to.
2. The mandate. They name an amount, the lowest yearly rate they will accept, and the shortest and longest term they can be without the money. The rate band and the term are the two parameters the mandate is built on.
3. The risk, taken once. Before the mandate can be used they complete the entry knowledge test and a simulation of the ability to bear loss, set at 10 percent of net worth. Where the result is weak, they are told they can lose all of the money, and they acknowledge that warning. They are not blocked from continuing. Where the amount is above the higher of €1,000 or 5 percent of that net worth, the further warning and consent are taken before the mandate is used. The test is repeated every two years and the simulation every year. The software runs the steps. The words are the firm's.
4. The transfer, and four calendar days. They send the amount from their IBAN. Where the payment firm supports SEPA Instant, the balance is visible in seconds. For four days it is locked. Cancelling returns it to the same IBAN, in full, with no fee. It is not lent during those four days. The payment firm holds it.
5. Later loans. From the fifth day, a business whose rate and term fit, and which the firm has approved, can be filled without a new decision and without a new four-day wait. This automatic step is used only when individual portfolio management of loans is on the firm's authorisation. Otherwise the person confirms each business, and the four days apply to that offer. Where a single confirmation would itself cross the €1,000 or 5 percent line, the warning is taken again on that confirmation.
6. What they can always see. Every loan is on their screen: the business, the rate, the maturity, the repayment schedule, the fees, and whether the instalment was paid. The mandate and each loan are kept for at least three years after maturity.
7. Money coming home. Each instalment can be paid to the same IBAN, or left in place to fund the next approved business if they chose that on the mandate. They can send a free balance home when they want it. The screen does not call the balance a deposit, a savings account, or a guaranteed sum. Once the money has become a loan, a deposit guarantee does not cover it. While it is still only a payment, waiting to be lent or waiting to be returned, it sits with the payment firm under that firm's safeguarding.

The borrower is an autónomo or a company, and the purpose is the business. A personal purpose is refused on the screen and does not reach the firm's desk.

1. The request. Lend2Friend takes the company, what the money is for, the amount, the term, the most they will pay in yearly interest, and the documents on the firm's checklist.
2. The checks the regulation already requires. No relevant criminal record for the people who represent the business, and the business is not established in a jurisdiction the European Union treats as non-cooperative or as high-risk for money laundering. The software collects the evidence. A miss stops the file.
3. The credit decision. The file is scored and priced under the firm's written framework. A file those rules already clear is shown a rate in the same sitting, and that rate includes the firm's X points. A file that needs a person goes to the firm's desk, and the screen says it is in review. It does not say it is approved. The firm can refuse any file, including one the rules would have cleared.
4. The information the lender must have. On a mandate channel, the lender reads one information sheet for the service before the mandate is given, and sees the detail of each loan after it is made. On a channel that confirms each business, that business's own sheet is in front of the lender before they commit. The business supplies the facts. The firm checks that the sheet is complete, clear, and not misleading. Lend2Friend will not open an offer while a sheet the firm has rejected is attached.
5. Disbursement. Live mandates, or lenders who have confirmed the offer and finished its reflection, fill the amount. The principal is paid to the business's registered IBAN. Where SEPA Instant is available, that payout is the same day. The screen says the loan has been paid out only when the payment firm confirms the payout.
6. The life of the loan. Each month the payment firm collects the same instalment by direct debit and splits it. Interest that month is one twelfth of the yearly rate on the balance still owed. The lender receives the principal portion and their interest. The firm receives the X points on that balance. Direct debit takes a banking day and can come back unpaid. Until the payment firm confirms collection, the instalment is shown as due, not as paid. A miss is visible to the lender, to the firm, and to Lend2Friend the day it happens. The chase follows the firm's existing arrears process. Lend2Friend sends the messages and the retries that process names. It does not agree a waiver, a change of terms, or a write-off.

Lenders are opened first. Their four days run before the first business is shown a rate that can be filled. A business the firm approves on a day when mandates are already live can be paid the same day. A business that arrives before any mandate is live is told it is waiting for funds. The wait is not described as an approval.

There is one door. A euro is in the person's bank, or in the business's bank, or at the firm's payment firm. It is never in an account Lend2Friend controls, and the key is not able to send it to one.

Lend2Friend stores these states against the payment firm's transaction identifiers. The store is a copy. At the end of each day the two records are compared. A break is an incident. The firm is told the same day, and no further allocation runs on the affected balance until the payment firm's record and the copy agree.

The firm issues a key to the payment interface it already uses, first in a sandbox and then for the pilot. The key has four general permissions. Registering a person's or a business's IBAN, and showing them where to send the money, do not use the key. Before any live euro, the sandbox is used to prove each permission, including a cancellation inside the four days, a refused file, a successful payout, a collected instalment, and a debit that comes back unpaid.

1. Open. Open a holding for a person or a business, and start the hosted identity check.
2. Hold. Report that a transfer has arrived, lock that balance for the reflection, and release the lock when the reflection ends.
3. Collect. Collect an instalment by direct debit, and record whether it was paid or returned unpaid.
4. Pay. Pay money only to an IBAN already registered for that person or that business: a cancel return, a business payout, a lender's share, or a free balance sent home. The firm's fee is retained on the platform.

Every request carries the identifier Lend2Friend uses for that loan or that mandate. Every response, and every notice the payment firm sends back, carries the payment firm's own identifier. Sending the same request again does not move the money a second time.

The rules on the key refuse a movement when any of the following is true. The reflection has not ended. The business is not approved. The amount, the rate, or the term falls outside the mandate. The destination is not the IBAN already registered for that person or that business. The fee is anything other than the X points the agreement names. The firm can revoke the key, and a revoked key fails closed. A key that can pay an IBAN nobody has registered is not the key this pilot uses.

Lend2Friend does not take its remuneration inside the split. The X points land with the firm, because the firm is the party whose permission the loan was made under. Lend2Friend invoices a fixed amount for each period, plus a share of the fee the firm has actually collected in that period. The share is the same on every loan. If an instalment is not paid, the firm collects no fee on it, and no variable amount arises from it. The agreement records the fixed amount and the share.

The pilot is the facilitation of loans under Regulation (EU) 2020/1503. The firm is the crowdfunding service provider. The business is the project owner. The person who provides the money is the investor and, on each loan, the original lender.

A consumer who borrows for a purpose outside a trade is outside that regulation, by Article 1(2)(a), and outside this pilot. An autónomo or a company borrowing for the business is a project owner. The screen requires the purpose and has no path onward for a personal one.

Filling loans from parameters the lender set in advance is individual portfolio management of loans. Recital 20 describes it in those words. It is an addition to the facilitation of loans, and it has to be written on the firm's authorisation. Where it is, Article 22(7) places the four-day reflection on the first mandate and not on each later loan. Where it is not written on the authorisation, the pilot does not switch it on. The person confirms the business, and the four days run on that offer.

The mandate includes at least two of the criteria in Article 6. This pilot uses the rate band and the maturity band. The firm discloses, in the mandate, how an allocation is chosen. The lender can open every loan. The records of the mandate and of each loan are kept for at least three years after the loan matures.

The price and the assessment of credit are the firm's, under Article 4 and Delegated Regulation (EU) 2024/358. Lend2Friend applies the method the firm has written down. It does not keep a second method.

Article 3(3) forbids paying or accepting a benefit for routing an investor toward one particular offer. The firm's X points do not rise or fall with the business that is chosen. The variable part of the software invoice is the same share of that fee on every loan, so it does not rise for one business rather than another. The gap is disclosed on the loan and taken only from interest that has been paid.

Article 10 requires the payments to run through a payment service provider. The firm already has one. The crowdfunding permission is not a payment licence, and the pilot does not ask the firm to obtain one. Lend2Friend supports that payment firm and does not at any time possess the funds. That is the difference between a technology supplier and a firm that would itself need an authorisation to hold or move client money.

The customer does not buy a share of a pool, a note, or a unit in a fund. Recital 19 provides that this permission is not a permission to manage assets collectively. Each allocation is a loan from that person to that business, and the screen shows that loan.

The firm may outsource the running of the platform. Recital 27. It remains responsible for the service. The operating agreement therefore gives the firm the means of that responsibility: approval of the rules before they run, a right of audit, notice of incidents, an exit that leaves the loan records and the money with the firm and its payment firm, and a key it can revoke. Those are the outsourcing points that have applied to crowdfunding firms under DORA since 17 January 2025.

The firm is not asked to rely on Lend2Friend for any decision the authorisation reserves to the firm. The actions that would put the firm outside its permission are blocked in the rules of the key and in the screen, and the firm can stop the channel without asking Lend2Friend to agree.

Complaints about a loan are answered by the firm, on the procedure it already publishes. The screen names the firm and gives that procedure. Lend2Friend puts the complaint in the firm's hands the day it is made, with the loan, the amounts, and the correspondence attached, and then sends the customer whatever the firm instructs. Lend2Friend does not issue the final answer.

Personal data used to perform the service is handled on the firm's instructions. The customer contracted with the firm. Lend2Friend processes that data to run the software, for no other purpose, and returns or deletes it when the firm says the service no longer needs it. Identity evidence is taken by the payment firm's hosted check, so the document images do not have to be stored by Lend2Friend.

If Lend2Friend is unreachable, two things remain true. The payment firm still holds every euro that has not been paid out or returned. The loan contracts are the firm's, and the firm has the schedule, the parties, and the payment history. Administering a live loan does not depend on Lend2Friend remaining at its desk. The supplier can be replaced without reconstructing the book from a system the firm cannot open.

The pilot is large enough to show a completed onboarding, a loan paid out, a monthly instalment, a missed instalment, and a complaint. It runs at the size the firm is willing to have on its book under this brand. Eligibility geography and residency are set in the operating agreement.

The operating agreement names the permission being used, the payment account, the fee, X, the fixed software amount, the share of the fee, the credit and pricing rules, the handling of data, the complaints path, the right of audit, the exit, and the prohibition on Lend2Friend holding client money. X is one gap, the same on every loan. Section 06 shows the suggested figure, 2.00 points. The agreement records the number, and it names the people on each side who can refuse a loan and revoke the key.

The firm's name is on the contract from the first loan. Lend2Friend attracts lenders and businesses through the marketplace and introducers under that agreement. The firm can still stop the channel at any time.

A yes is four decisions. It is not a build on the firm's side. From the day those four are given, Lend2Friend does the lifting: the marketplace, the pilot, the files, the matching system, the invitations, the reconciliation, and the changes to the product. The firm keeps the licence, the rails, the fee, credit, and complaints.

1. Confirm that the authorisation includes the facilitation of loans to businesses, and say whether it includes individual portfolio management of loans. The second answer chooses automatic allocation or a confirmation on each business. Both are built.
2. Name the payment firm, and issue a sandbox key limited to the four permissions in section 10.
3. Hand over the credit and pricing rules a file must satisfy, and name the person who sees the exceptions.
4. Sign the operating agreement described in section 14.