Actor

IOBSP

Intermédiaire en Opérations de Banque et en Services de Paiement (banking and payment services intermediary)

A French status that governs the brokerage of credit and banking services. Registration with the ORIAS, in 4 categories depending on whether you act as a bank's agent, a client's agent, a broker or a MIOBSP.

Definition

An IOBSP (Intermédiaire en Opérations de Banque et en Services de Paiement) presents, offers or helps conclude banking operations (credit, deposits) or payment services, without itself being a credit institution or a PSP.

It is the French status of the credit broker and, more broadly, of the distributor of banking products. Registration with the ORIAS is mandatory; oversight is shared between the ACPR (ethics, competences) and the DGCCRF (commercial practices).

The 4 categories

The decree of 26 June 2012 distinguishes four categories, in principle non-cumulative:

  • Broker (cat. 1) — independent, mandated by the client, putting several banks into competition (Pretto, Meilleurtaux, Empruntis).
  • Exclusive agent (cat. 2) — mandated by a single institution, whose products it distributes.
  • Non-exclusive agent (cat. 3) — mandated by several banks, which it represents (not the client).
  • MIOBSP (cat. 4) — a sub-agent of an IOBSP in the three preceding categories (the local agent of a national broker).

ORIAS registration and professional competence

To be an IOBSP, you must:

  • register with the ORIAS (a paid annual renewal);
  • prove professional competence (level I: a 3-year finance degree or 2 years' experience; II: a 2-year degree or 1 year; III: 150 hours of training), depending on the category;
  • take out professional liability insurance;
  • hold a financial guarantee (≥ €115K) if collecting funds (rare);
  • demonstrate good standing (a compatible criminal record).

IOBSP vs PSP agent vs CIF

IOBSPPSP agentCIF
DistributesCredit, deposits, paymentsPayment servicesInvestment advice
On behalf ofA credit institution or PSPA PI / EMIThe client (advice)
RegisterORIASACPR (agents register)ORIAS + association
Professional competenceLevel I, II or IIIGood standing + trainingAMF + approved association

A single player can combine all three (Pretto is an IOBSP, sometimes a CIF), in separate compartments.

What an IOBSP cannot do

  • Grant credit on its own account: it presents an offer; the decision rests with the credit institution.
  • Take deposits: a temporary collection of funds requires the financial guarantee.
  • Perform AIS / PIS: reserved for authorized PSPs; an IOBSP must go through a partner AISP.
  • Provide investment advice: this requires the CIF status.

The IOBSP and fintech

The status is widely used by credit, real-estate and debt-consolidation fintechs:

  • Pretto, Meilleurtaux and Empruntis are mortgage brokers (cat. 1).
  • Younited became a credit institution (formerly Prêt d'Union) and carries the risk on its own account.
  • Algoan and Bridge are not IOBSPs: they provide scoring or data, without presenting credit.

In the PSD2 ecosystem

The IOBSP is not a PSD2 status (the directive does not deal with credit), but many IOBSPs leverage AIS data, through a partner AISP, to do alternative credit scoring or cash-flow underwriting — which brings the two worlds together.

Concrete examples

  • Mortgage brokerage: Pretto, Meilleurtaux, Empruntis, Cafpi, Vousfinancer — all cat. 1, mandated by the client, paid on commission by the bank (often ~1% of the principal).
  • Consumer credit / debt consolidation brokerage: Younited (now a credit institution), Solutis, Crédigo.
  • Non-exclusive agent: a local agent offering Cetelem + Sofinco + Cofidis.
  • Loi Lagarde: since 2010, a FISE must be provided for any mortgage, with a 10-day cooling-off period.
  • Remuneration: for mortgages, the commission is paid by the bank (passed on through the APR), not by the client.
  • Brokerage reform (2021, in force 2022): mandatory membership of an ACPR-approved association, which oversees ethics, continuing training and complaints.
  • Digitalization: digital brokers (Pretto, Helloprêt) collect payslips and statements via an AISP, cutting file preparation from 2 weeks to 24h.

Sources

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