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Does a New MFO, MFC, or MCC Need a Website? ​

When an entrepreneur who has decided to engage in microlending registers a company and enters data in the registry, they face questions about further business development. The owner of a financial company must comply with the requirements of legislation and regulators.

Regulatory Framework ​

1. Federal Law No. 151-FZ of July 2, 2010 ​

"On Microfinance Activities and Microfinance Organizations"(Latest edition: Federal Law No. 268-FZ of July 31, 2020)

This law regulates the activities of microfinance organizations (MFO), microfinance companies (MFC), and microcredit companies (MCC). In recent years, important changes have been made to it:

  • New requirements for information disclosure on the website have been established.
  • Rules for exclusion from the MFO registry have been clarified.
  • Provisions on remote client identification have been added.

2. Federal Law No. 353-FZ of December 21, 2013 ​

"On Consumer Credit (Loan)"(Latest edition: Federal Law No. 334-FZ of July 2, 2021)

This law regulates the procedure for providing consumer credits and loans. Recent changes have tightened requirements for transparency of lending conditions and protection of borrowers' rights.

3. Central Bank of Russia Directives ​

  • Bank of Russia Directive No. 3910-U of December 28, 2015:

    • Regulates information disclosure requirements for MFOs.
    • Requires posting the following information on the website:
      • Information about registration in the MFO registry.
      • Terms and conditions for providing microloans.
      • Information about company management.
      • Financial performance indicators.

  • Bank of Russia Directive No. 4243-U of December 27, 2016:

    • Establishes requirements for the form and methods of providing information to borrowers.

Information Disclosure Requirements ​

Main Obligations ​

According to FZ-151, Article 9, Paragraph 2:

A microfinance organization is obligated to post a copy of the rules for providing microloans:

  • In a place accessible for viewing and familiarization by any interested party.
  • On the Internet.

What Does This Mean? ​

  • The law does not require having specifically your own website, but the information must be accessible on the Internet without restrictions.
  • The requirement is relevant even for companies that operate only offline.

Additional Requirements ​

Exclusion from the Registry ​

According to FZ-151, Article 7, Paragraph 2.1:

Information about the exclusion of a legal entity from the state registry of microfinance organizations shall be posted:

  • At customer service locations.
  • On the official website of the legal entity.
  • On the Internet information and telecommunication network.

Example: If a company changes its name or organizational form, it is obligated to publish a notice of exclusion from the registry within 3 business days.

Consumer Credit ​

According to FZ-353, Article 5:

The creditor is obligated to post information about the conditions for providing, using, and repaying consumer credit (loan) on the official website on the Internet.

Personal Data Protection ​

In accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", MFOs are obligated to:

  • Post a privacy policy on the website.
  • Ensure protection of clients' personal data.

Recommendations for Creating a Website ​

Despite some ambiguity in the wording of legislation, creating your own website is the optimal solution for the following reasons:

1. Compliance with Regulator Requirements ​

  • Ability to promptly post up-to-date information.
  • Compliance with all regulatory requirements (for example, Central Bank of Russia directives).
  • Convenience for inspections by supervisory authorities.

Minimum Website Requirements: ​

  • Posting of microloan provision rules.
  • Information about registration in the MFO registry.
  • Privacy policy.
  • Company contacts.

2. Increasing Customer Trust ​

  • Having a website increases the level of trust.
  • Ability to describe working conditions in detail.
  • Posting scanned registration documents.

3. Marketing Advantages ​

  • Additional communication channel with customers.
  • Opportunity to promote services.
  • Creating an image of a reliable company.

Practical Example ​

One of our clients encountered a situation with license revocation when changing the company name and organizational form. Despite having a website, the regulator required:

  • Making changes to the information on the website after the organization was excluded from the registry.
  • Publishing a notice of exclusion from the registry within 3 business days.

Conclusion ​

Creating your own website for a microfinance organization is a practical decision that ensures:

  • Compliance with legislative requirements.
  • Increased customer trust.
  • Effective business development.

Important: Regularly check that the information on your website is up-to-date and complies with the latest legislative changes. This will help avoid fines and problems with regulators.