|Purpose||To clarify if an LSP (Lending Service Provider) can be an FIU|
|Description||An LSP is an intermediary that partners with lenders. As such, an LSP need not itself be “a registered and regulated entity”, with any of the four financial sector regulators.
If an LSP is not a registered and regulated entity, it cannot be an FIU in the AA ecosystem.
|Purpose||To clarify the role an LSP plays vis-a-vis the AA ecosystem, as per the OCEN protocol|
|Description||An LSP plays a role akin to a marketplace. It allows borrowers to state loan requirements, view loan offers and complete the process thereafter to avail of the loan.
As part of this journey, the front-end integration with an AA client – either via redirection, app-to-app integration or embedded library invocation – is the feature that the LSP may offer. This is just a digital workflow feature and does not involve the LSP receiving any financial information of the borrower.
All interactions vis-a-vis the AA, from placing a consent request, to receiving the (approved) consent artefact and then receiving data, always happen directly between the lenders and the AA.
|Purpose||To clarify if a borrower can provide consent to multiple lenders (FIUs) in a single interaction on an AA client|
|Description||In an LSP-led digital journey, the borrower expects to get a choice of loan offers from several lenders that he/she chooses.
In such an interaction, consent requests from all the lenders are simultaneously raised for the AA to present to the borrower. The AA presents all the consent requests in one single interaction with the borrower.
The borrower may approve one, more or all of the consent requests presented, in a single interaction on the AA client.