Country Manual Credits
Germany – Update 2025
out of Credit Institution’s Country of Establishment (Def, BT & Def)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Behaviour Template and Definitions and Concepts
Material changes
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that generally, there have not been any relevant legal or regulatory changes in Hungary since the last update.
Given the inherent threats for the Credit Institution of a leverage effect of Lombard credit (margin financing) agreement where the client’s/prospect’s portfolio serves as collateral, the answer for solicitation and negotiation of Lombard credit services have been changed to Grey zone for all activites onsite and on a remote basis to Germany. This is to reflect the increased risk level for the Credit Institution that local consumer protection rules may apply to a Lombard credit agreement with a prospect or client in Germany, even when the Credit Institution acts upon the client’s or prospect’s request. The potential legal risks for the Credit Institution under German consumer protection law manifest in particular in the case that the mandatory information requirements are not fully complied with.
The section on consumer protection rules have further been thoroughly reviewed and, where appropriated amended.
Non-material changes
The section on consumer protection rules have further been thoroughly reviewed and, where appropriated amended.
For more information, please contact us: info@brpsa.com
Geneva, December 5th 2025