Regarding the petition registered with the National Financial Market Commission no. 3612 on 12.05.2026, in relation to OCN "EASY CREDIT" SRL

REPUBLIC OF MOLDOVA NATIONAL FINANCIAL MARKET COMMISSION blvd. Ștefan cel Mare și Sfânt, no. 77, municipality Chișinău, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md DECISION 24 August 2026 No. 43/9 Regarding the petition registered with the National Financial Market Commission no. 3612 on 12.05.2026, in relation to OCN "EASY CREDIT" SRL

On 12.05.2026, within the National Financial Market Commission (CNPF), the petition of Ms. [...] (debtor) was registered (with no. 3612), through which the intervention of the CNPF is requested with reference to the legal relationship mentioned below.

I. Factual Circumstances

1. The legal relationship between OCN "EASY CREDIT" SRL (creditor) and the debtor was established based on Credit Contract no. [...] dated 24.05.2022 (Contract).
2. The credit granting conditions, resulting from the Contract, are the following:

1. total credit value: 35 000,00 MDL;
2. interest: 18.90 percent per annum, fixed;
3. administration fee: 0.76 percent monthly, calculated from the total credit value;
4. penalty for breach of payment schedule: 30 MDL, for each day of delay;
5. effective annual interest rate: 63.45 percent;
6. payment method – annuity, credit repaid in installments, according to the Repayment Schedule: 2 302,00 MDL monthly;
7. total value payable by the debtor: 55 248,00 MDL;
8. loan granting term: 24 months.

II. Procedural Circumstances 3. Through the CNPF President's Order no. 287 dated 19.05.2026 regarding the ex officio involvement of OCN "EASY CREDIT" SRL in the administrative procedure, initiated by the petition of Ms. [...], and the suspension of the administrative procedure, the creditor was involved, ex officio, in the respective administrative procedure. 4. Through the same Order, the administrative procedure was suspended, on the grounds of requesting from the creditor, via CNPF letter no. 05-5/1963 dated 20.05.2026, the submission of due explanations, the copy of the Credit File, as well as the copy of other documents connected thereto. 5. Subsequently, on 02.06.2026, the creditor submitted the requested documents and explanations to the CNPF (registered with no. 4350). 6. Consequently, arising from the complexity of the object of the administrative procedure and taking into account the imperative of carrying out complete investigations, which involve time for the meticulous examination of the presented evidence and the formation of objective and motivated conclusions, through the CNPF President's Order no. 408 dated

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on 24.06.2026 regarding the extension of the general term of the administrative procedure, initiated by the petition of Ms. [...], the general term of the administrative procedure was extended until 10.07.2026. 7. In this case, for the complete and objective examination of the factual circumstances, through the CNPF President's Order no. 440 dated 01.07.2026 regarding the suspension of the administrative procedure, initiated by the petition of Ms. [...], the administrative procedure was suspended until 15.07.2026 inclusive, being requested, via CNPF letter no. 2773 dated 02.07.2026, the submission by the creditor of additional explanations regarding the calculation method of the annual interest rate, related to Credit Contract no. [...] dated 24.05.2022, of information regarding the payments made by Ms. [...], indicating the method of allocation thereof, as well as the copy of relevant supporting documents. 8. As a result, on 15.07.2026, the creditor submitted the requested documents (registered at CNPF with no. 5970). 9. Subsequently, through the CNPF President's Order no. 494 dated 16.07.2026 regarding the suspension of the administrative procedure, initiated by the petition of Ms. [...], the administrative procedure was suspended until 30.07.2026 inclusive, being requested, via letter no. 05-5/3063 dated 17.07.2026, the submission by OCN "EASY CREDIT" SRL of evidence regarding the effective collection of the payments invoked in the presented explanations, indicating the date and amount of each payment, as well as the method of distribution thereof according to the obligations established in the Contract. 10. As a result, on 30.07.2026, the creditor submitted the requested documents (registered at CNPF with no. 6531). 11. Subsequently, through the CNPF President's Order no. 571 dated 05.08.2026 regarding the suspension of the administrative procedure, initiated by the petition of Ms. [...], the administrative procedure was suspended until 20.08.2026 for the conduct of the written hearing. 12. As a result, on 19.08.2026, the creditor submitted the exposition, as a hearing, in written form (registered at CNPF with no. 7227).

III. Legal Circumstances 13. In accordance with Art. 37 paragraph (2) of Law no. 105/2003 on consumer protection (Law no. 105/2003), "(2) The National Financial Market Commission carries out the control of compliance by the subjects indicated in Art. 4 paragraph (2 1 ) of Law no. 192/1998 on the National Financial Market Commission of the provisions of Art. 1069 – 1081 of the Civil Code in the part referring to contracts concluded with consumers and the finding of abusive clauses in contracts, upon consumer complaint or ex officio, under the law.". 14. According to Art. 1 of Law no. 105/2003, "consumer" is "any natural person who intends to order or purchase or who orders, purchases or uses products, services for needs not related to entrepreneurial or professional activity;". 15. Art. 3 of Law no. 202/2013, establishes that "interest rate related to the credit – interest rate expressed as a fixed or floating percentage applied annually to the amount drawn from the credit". 16. According to Art. 3 paragraph (1) and paragraph (2) of the Civil Code, "(1) Any natural person who, within a civil legal relationship,

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acts predominantly for purposes not related to entrepreneurial or professional activity has the quality of consumer. The natural person does not have the quality of consumer if the other party to the civil legal relationship does not have the quality of professional. (2) Any natural or legal person of public law or private law who, within a civil legal relationship, acts for purposes related to entrepreneurial or professional activity, even if the person does not have the purpose of obtaining profit from this activity, has the quality of professional.". 17. According to Art. 14 paragraph (1) of Law no. 202/2013, "(1) The calculation of the monthly interest rate shall be made based on the calendar year of 365 or 366 days, taking into account, in the numerator of the fraction of the formula, the effective number of days included between maturities, and in the denominator of the same fraction – 365 or, respectively, 366 days.".

IV. CNPF Assessment 18. Analyzing the contractual clauses, the information from the documents presented by the participants in the administrative procedure, through the prism of the requirements provided by Law no. 202/2013 and by the Civil Code, in particular, in relation to the normative framework enunciated above, the CNPF highlights the following. 19. Ab initio, the establishment of the quality of professional, held by OCN "EASY CREDIT" SRL in relation to the consumer, is claimed, in order to determine the normative framework applicable to the legal relationship submitted to examination. In correspondence with the information from the State Register of Legal Persons, OCN "EASY CREDIT" SRL has, as main object of activity, inter alia, the activity of granting non-bank credits, being registered in the Register of authorized non-bank credit organizations. Thus, it is concluded that OCN "EASY CREDIT" SRL carries out activity of granting non-bank credits, on a professional basis, based on the clauses and conditions offered by it. 20. Violation of the method of application of the interest rate related to the credit According to Section 3.02 letter a) of the Contract, "Contractual Interest. For making available and use by the Debtor of the credit amount, the latter undertakes to pay the Creditor a contractual interest, the rate of which is calculated annually from the drawn (received) credit amount. The annual size of the interest rate related to the credit under this contract is 18.90% being fixed. The interest will be returned by the Debtor monthly, being included in the composition of each monthly installment, in decreasing manner from the first monthly installment, towards the last monthly installment, according to the size and periodicity provided in Part 3. Credit repayment schedule. Consequences of non-execution." Thus, from the corroborated interpretation of Art. 3 and Art. 14 of Law no. 202/2013, it results that, the interest rate is applied exclusively to the amount effectively drawn from the credit and is calculated based on the current balance of the credit remaining to be paid, not to the total credit value. However, the mathematical calculation related to the "Repayment Schedule" from the Contract attests that the Creditor applied the interest rate to the total credit value throughout the duration of the Contract, which contravenes the provisions of Art. 3 and Art. 14 paragraph (1) of Law no. 202/2013. 21. From the considerations exposed above, based on Art. 1 paragraph (1), Art. 4 paragraph (2 1 ) letter c), Art. 8 letter t), Art. 9 paragraph (1) letter d), Art. 18 paragraph (3), Art. 20 paragraph (1), paragraph (6) and paragraph (7) and Art. 22 paragraph (3) of Law no. 192/1998 on the National Financial Market Commission, Law no. 202/2013 on credit contracts for

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consumers, Administrative Code and 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 violation by OCN "EASY CREDIT" SRL of the method of application of the interest rate related to the credit is found.
2. OCN "EASY CREDIT" SRL will recalculate, within 30 days, the interest according to legal provisions and will return the illegally collected sum.
3. Control over the execution of this Decision is assigned to the Credits Deposits Directorate within the Consumer Protection Supervision Department.
4. This Decision may be contested by submitting a prior request to the CNPF (MD-2012, municipality Chișinău, blvd. Ștefan cel Mare și Sfânt, no. 77), within 30 days from the date of communication.
5. This Decision enters into force on the date of adoption and is communicated to the recipients according to legislation and is published on the official website of the CNPF (www.cnpf.md). Dumitru BUDIANSCHI, PRESIDENT