Decision No. 48/1 of 22.09.2026 Regarding the Conduct of an Unscheduled Inspection at OCN "ECOFINANCE TECHNOLOGIES" SRL

REPUBLIC OF MOLDOVA
NATIONAL FINANCIAL MARKET COMMISSION
77 Stefan cel Mare si Sfant Blvd, Chisinau, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md

DECISION
September 22, 2026 No. 48/1
Regarding the conduct of an unscheduled inspection at OCN "ECOFINANCE TECHNOLOGIES" SRL

According to data registered with the National Financial Market Commission (NFMC), during the period 01.01.2026 – 22.09.2026, over 1,000 petitions regarding the activities of non-banking credit organizations were submitted, of which approximately 20 percent concerned the activities of OCN "ECOFINANCE TECHNOLOGIES" SRL (IDNO 1018600034829, MD-2069, Chisinau, Calea Iesilor str., 6A, hereinafter – the participant).

The types of activities of the participant include the provision of non-banking loans, financial leasing, factoring operations, activities as a bancassurance agent, payment services, and the issuance of electronic money, as well as related or auxiliary activities associated with the implementation of non-banking credit activities.

In the course of examining the petitions, aspects requiring additional verification regarding loan costs, contractual clauses, and consumer information have been identified, including in relation to the offer and contracting of insurance products and/or other services.

Furthermore, the conclusion of distance contracts requires the examination of the effective conditions for presenting and accepting offers, the information communicated to consumers, and the consumers' effective ability to accept or refuse offered insurance products and/or other services.

Taking into account the significant number of registered petitions and the repetitive nature of the reported aspects, it is deemed necessary to initiate an unscheduled inspection at OCN "ECOFINANCE TECHNOLOGIES" SRL, in order to verify compliance with legal requirements regarding the protection of the rights of financial service consumers.

Since the conduct of this inspection is not provided for in the NFMC Control Activity Plan for 2026, it shall be carried out in the form of an unscheduled inspection.

At the same time, it should be noted that the participant's activity as a bancassurance agent is closely linked to credit activities, with insurance products being offered to consumers in connection with loans granted.

In this context, both the costs associated with insurance products and those associated with other contracted services shall be examined in light of the legal provisions limiting payments under loan contracts, as stipulated by Law No. 202/2013 on consumer loan contracts (Law No. 202/2013).

Therefore, it is established that the verification of the participant's activities as a non-banking credit organization and as a bancassurance agent targets the same consumers and the same contracting flows, which are interdependent.

Taking into account the circumstances outlined, considering the imperative of respecting the principle of administrative procedure efficiency, as well as ensuring the comprehensibility and transparency of the supervisory authority's activities, including reducing the administrative burden on the participant, it is concluded that it is opportune to initiate a single administrative procedure, with the object of verifying the participant's activities in both capacities.

In order to examine the reported aspects uniformly, the unscheduled inspection will target the participant's activities as a non-banking credit organization and as a bancassurance agent, in relation to contracts (legal acts) concluded during the period 01.07.2025 – 21.09.2026, by verifying:

1. the loan portfolio in terms of compliance with the provisions of Art. 5 para. (5) – (61), Art. 12 para. (1) lit. a) of Law No. 202/2013 and Art. 15 para. (7) of Law No. 202/2013 (in the version until October 25, 2025) and Art. 151 para. (1) of Law No. 202/2013;

2. the participant's activities as a non-banking credit organization and as a bancassurance agent in light of the use of unfair commercial practices, as provided for in Art. 13 of Law No. 105/2003 on consumer protection;

3. compliance with the provisions of Art. 1017, Art. 1020, Art. 1022, Art. 1024, Art. 1028, Art. 1055, Art. 1057, Art. 1061, and Art. 1064 para. (6), in part concerning related or auxiliary activities linked to non-banking credit activities, as well as Art. 1069 – 1072, Art. 1075 – 1079, and Art. 1081 of the Civil Code, in part applicable to clauses in loan contracts and contracts (legal acts) concerning related or auxiliary activities linked to non-banking credit activities;

4. compliance with the requirements provided for in Art. 4–6 of Law No. 157/2014 on the conclusion and execution of distance contracts for consumer financial services;

5. the participant's activities as a bancassurance agent in terms of compliance with the provisions of Art. 89 para. (1) lit. a), lit. b), lit. d), and lit. f), para. (21) – (25), and Art. 891 of Law No. 92/2022 on insurance or reinsurance activities.

In this context, the unscheduled inspection will be conducted on-site, at the participant's headquarters.

According to Art. 69 para. (1) of the Administrative Code, the administrative procedure is considered initiated with the first procedural action.

In this regard, given the procedural complexity of conducting the unscheduled inspection, the considerable volume of documents to be requested and analyzed, and the need to conduct a complete and objective examination of relevant circumstances, it is necessary to establish a longer term, in accordance with Art. 60 para. (5) of the Administrative Code and point 19 of the Regulation on the Administrative Control Procedure (NFMC Decision No. 60/10/2023), which shall not exceed 90 days, for the completion of the administrative control procedure.

Furthermore, according to data from the National Bank of Moldova, as of December 31, 2025, the loan portfolio managed by OCN "ECOFINANCE TECHNOLOGIES" SRL amounted to 254 million lei.

At the same time, in order to conduct the unscheduled inspection, it is necessary to establish a control team, consisting of 4 employees from the Consumer Protection Supervision Department of the NFMC, who will carry out the inspection based on the Control Plan attached to this Decision.

On the basis of Art. 4 para. (21) lit. b) and lit. c) and para. (23), Art. 8 lit. f1), Art. 9 para. (12), Art. 18 para. (3), Art. 20 para. (1) and para. (6), and Art. 22 para. (3) of Law No. 192/1998 on the National Financial Market Commission, Law No. 202/2013 on consumer loan contracts, Art. 36 para. (2) lit. g), Art. 37 para. (2) and para. (3), and Art. 38 para. (2) of Law No. 105/2003 on consumer protection, Art. 11 of Law No. 157/2014 on the conclusion and execution of distance contracts for consumer financial services, Art. 89 para. (3) lit. d), lit. i), and lit. l) of Law No. 92/2022 on insurance or reinsurance activities, the Civil Code, the Administrative Code, the Regulation on the Administrative Control Procedure (NFMC Decision No. 60/10/2023), and points 5, 16, and 19 of the Regulation on the Organization and Functioning of the National Financial Market Commission (NFMC Decision No. 57/11/2022),

The National Financial Market Commission DECIDES:

1. An administrative unscheduled control procedure is initiated ex officio regarding the verification of compliance by OCN "ECOFINANCE TECHNOLOGIES" SRL, in relation to contracts (legal acts) concluded during the period 01.07.2025 – 21.09.2026, with the provisions:

1.1. Art. 5 para. (5) – (61), Art. 12 para. (1) lit. a) of Law No. 202/2013, and Art. 15 para. (7) of Law No. 202/2013 (in the version until October 25, 2025), and Art. 151 para. (1) of Law No. 202/2013 on consumer loan contracts, in relation to loan contracts concluded during the period subject to control;

1.2. Art. 13 of Law No. 105/2003 on consumer protection, in the participant's activities as a non-banking credit organization and as a bancassurance agent;

1.3. Art. 1017, Art. 1020, Art. 1022, Art. 1024, Art. 1028, Art. 1055, Art. 1057, Art. 1061, and Art. 1064 para. (6), in part concerning related or auxiliary activities linked to non-banking credit activities, as well as Art. 1069 – 1072, Art. 1075 – 1079, and Art. 1081 of the Civil Code, in part applicable to clauses in loan contracts and contracts (legal acts) concerning related or auxiliary activities linked to non-banking credit activities;

1.4. Art. 4 – 6 of Law No. 157/2014 on the conclusion and execution of distance contracts for consumer financial services;

1.5. Art. 89 para. (1) lit. a), lit. b), lit. d), and lit. f), para. (21) – (25), and Art. 891 of Law No. 92/2022 on insurance or reinsurance activities, in the participant's activities as a bancassurance agent.

2. A term of 90 days is established for the completion of the administrative procedure mentioned in point 1, in accordance with the Control Plan (attached).

3. The unscheduled inspection shall be conducted during the period 01.10.2026 – 02.11.2026, on-site, at the participant's headquarters located at: Chisinau, Calea Iesilor str. 6A.

4. The control team is established with the following composition:

4.1. Mr. Radu Graur, Senior Specialist, Consumer Protection Supervision Department, team leader;
4.2. Ms. Liubovi Vacariuc, Senior Specialist, Consumer Protection Supervision Department;
4.3. Mr. Constantin Rosca, Senior Specialist, Consumer Protection Supervision Department;
4.4. Ms. Alina Pogor, Specialist, Consumer Protection Supervision Department.

5. OCN "ECOFINANCE TECHNOLOGIES" SRL shall provide access and present, upon request by the control team, any information, data from information systems and financial-accounting records, including flows and operational processes, call recordings, as well as any documents or records deemed necessary for the conduct of the unscheduled inspection.

6. This Decision enters into force from the date of adoption, is communicated to the recipient in accordance with the legislation, and is published on the official website of the NFMC (www.cnpf.md).

Dumitru BUDIANSCHI,
PRESIDENT