TITLE: Slovakia's National Bank Issues Guidance on Client Information Rules for Loan Intermediation
BODY:
On March 19, 2026, the National Bank of Slovakia (NBS), through its Capital Market Supervision Department, published a position statement establishing supervisory expectations for financial agents regarding compliance with client-facing conduct rules in loan intermediation activities.
The statement addresses the NBS's supervisory approach to information acquisition, provision, recording, and evaluation by independent financial agents (SFA) under the Financial Intermediation and Financial Advisory Act (Act No. 186/2009). The NBS identified inconsistent practices across market participants during supervisory activities and consultation responses, prompting clarification of its expectations.
Key areas covered include: (1) Information provision to clients must be documented and confirmed, with financial agents bearing the burden of proof regarding compliance. Information should be provided sufficiently in advance of loan applications, with agents demonstrating delivery through written confirmation or electronic records. (2) Recording of client information should occur continuously during assessment, with dates and times documented, and completed before loan applications are submitted. The NBS discourages template-based checkbox options for clients refusing information disclosure without substantive documentation of warnings about assessment limitations. (3) Suitability statements must be personalised based on client information gathered, not generic standardised text, and should be provided before loan applications. (4) For distance intermediation, all communication forms (email, telephone, electronic) must be recorded. (5) Financial agents must make reasonable efforts to provide all legally required information at the time of intermediation, informing clients when and how additional information will be provided.
The NBS indicated that non-compliance with these recommendations and applicable legislation may result in supervisory measures, remedial actions, and sanctions.