Decision on Conducting Thematic Control at OCN EASY CREDIT 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 12 May 2026 No. 23/2 On conducting thematic control within OCN "EASY CREDIT" SRL In accordance with the Control Activities Plan of the National Financial Market Commission for 2026 (appendix to Decision No. 62/4/2025 of the National Financial Market Commission (CNPF)), thematic control within OCN "EASY CREDIT" SRL (IDNO 1005600043669, MD-2001, Chisinau, Tighina St. 49/4, hereinafter – OCN/participant) is planned for the fourth quarter. In this context, according to data registered at the CNPF, in 2025, 482 petitions regarding the activity of non-banking credit organizations were submitted, of which 36 petitions concerned the activity of OCN "EASY CREDIT" SRL. During the examination of these, cases were identified that reveal non-compliance with the provisions of Art. 15 para. (7) lit. b) of Law No. 202/2013 on consumer credit contracts (as of 25.10.2025, hereinafter – Law No. 202/2013). Furthermore, since the beginning of the current year, 50 petitions have already been registered at the CNPF, which primarily concerned the same aspects of non-conforming application of Art. 15 para. (7) lit. b) of Law No. 202/2013, indicating a potential systemic nature of the noted non-compliances. Taking into account the significant number of petitions registered at the CNPF, the repetitive and potentially systemic nature of the noted aspects, as well as the need to prevent the continuation of any non-conforming practices towards consumers, it is concluded that it is necessary to initiate and carry out, with urgency, the thematic control in the second quarter of 2026, in order to effectively exercise the supervisory and control powers of the CNPF. The thematic control will have as its object the verification of the OCN's compliance with the provisions of Art. 15 para. (7) lit. b) of Law No. 202/2013 (as of 25.10.2025) and Art. 151 para. (1) lit. b) of Law No. 202/2013, in relation to credit contracts concluded during the period 01.01.2024 – 11.05.2026. In this context, the thematic control will be carried out 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.

1 Entry into force date of Law No. 189/2025 for the amendment of certain normative acts (consolidation of the framework for the protection of consumers' rights to financial services)

Regarding the subject, given the procedural complexity of conducting the thematic control, the considerable volume of documents to be requested and analyzed, as well as the need to carry out a complete and objective examination of the 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 (CNPF Decision No. 60/10/2023), which will not exceed 90 days, for the completion of the administrative control procedure. Moreover, according to data from the National Bank of Moldova, as of 31.12.2025, OCN "EASY CREDIT" SRL had concluded 103,867 credit contracts with consumers. At the same time, in order to carry out the thematic control, it is necessary to form an inspection team, consisting of 3 employees of the Consumer Protection Supervision Department of the CNPF, which will carry out the control based on the Control Plan attached to this Decision. On the basis of Art. 4 para. (21) lit. c), Art. 8 lit. f1), Art. 18 para. (3), Art. 20 para. (1) and para. (6), Art. 22 para. (3) of Law No. 192/1998 on the National Financial Market Commission, Law No. 202/2013 on consumer credit contracts, the Administrative Code, the Regulation on the administrative control procedure (CNPF 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 (CNPF Decision No. 57/11/2022), The National Financial Market Commission DECIDES:

1. The administrative procedure for thematic control regarding the verification of compliance by OCN "EASY CREDIT" SRL with Art. 15 para. (7) lit. b) of Law No. 202/2013 on consumer credit contracts (as of 25.10.2025) and Art. 151 para. (1) lit. b) of Law No. 202/2013 on consumer credit contracts, in credit contracts concluded during the period 01.01.2024 – 11.05.2026, is initiated ex officio.
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 thematic control is to be carried out during the period 20.05.2026 – 23.06.2026, at the participant's headquarters, located at: Chisinau, Tighina St. 49/4.
4. The inspection team is established in the following composition: 4.1. Mr. Radu Graur, senior specialist, Consumer Protection Supervision Department, head of the inspection team; 4.2. Ms. Liubovi Vacariuc, senior specialist, Consumer Protection Supervision Department; 4.3. Ms. Alina Pogor, specialist, Consumer Protection Supervision Department.
5. OCN "EASY CREDIT" SRL shall grant access and present, upon request of the inspection team, data from information systems, financial-accounting information systems, and other sources of information necessary for the conduct of the thematic control, as well as copies of all requested documents/information.
6. This Decision constitutes an administrative act and may be contested together with the individual administrative act adopted upon completion of the initiated thematic administrative control procedure.
7. This Decision enters into force from the date of adoption, is communicated to the recipient in accordance with legislation, and is published on the official website of the CNPF (www.cnpf.md). Dumitru BUDIANSCHI, PRESIDENT