Country _ Name
Bolivia
SectionTitle
Loan services/factoring/loan broking/finetrading
Body
FinTechs belonging to this category act as a loan creditor (even short and very short-term loans), are broking loans or receivables or conduct factoring of loans, which were given to private or business customers. In this business area you also find “peer-to-peer” (P2P) services, in which FinTechs enable a multitude of users to give loans (and brokered by the FinTech-platform) to other users or companies.

Finetrading is hereby a financial service of FinTechs, where they buy due receivables and grant the debtor an extension of payment time. 

As an ancillary service some FinTechs offer alternative credit assessment services to check the solvency of a borrower.

Introduction

Attitude of the country towards loan-giving-, factoring-, brokerage-, finetrading- and ancillary services

Bolivia encourages financial inclusion and economic diversification but regulates these financial services strictly through ASFI (Autoridad de Supervisión del Sistema Financiero). Below is a summary by service type:
Loan-Giving (Préstamos Directos)

  • Regulation: Allowed but tightly regulated under Ley de Servicios Financieros (Ley N° 393).
  • Authorized Entities: Only ASFI-licensed banks, cooperatives, microfinance institutions, or regulated FinTechs can lend.
  • FinTechs: Must be licensed financial entities or operate via the regulatory sandbox under Decreto Supremo N° 5384 (2025).
Factoring

  • Regulation: Legally permitted, widely used by SMEs; governed by commercial law and sometimes financial regulations depending on structure.
  • Supervision: Can be provided by financial institutions or commercial firms; ASFI oversight applies if offered broadly to the public.
  • FinTechs: Factoring FinTechs are viable but must comply with AML/CFT and financial reporting rules.
Brokerage Services

  • Regulation: Fully regulated under Ley del Mercado de Valores (Ley N° 1834); requires registration and authorization with ASFI and Bolsa Boliviana de Valores (BBV).
  • FinTechs: Innovation is welcome but formal licensing is mandatory; capital, reporting, and investor protection rules apply.
Finetrading (Trade Finance, Supplier Financing)

  • Regulation: Not specifically regulated as “finetrading,” but falls under commercial finance and structured lending laws.
  • Allowed: As long as it avoids unauthorized deposit-taking or securities issuance.
  • FinTechs: Allowed if compliant with AML, transparency, and licensing if financial intermediation is involved.
Ancillary Services (Credit Scoring, Data Analytics, Collections)

  • Regulation: Generally allowed with limited direct regulation unless handling personal data or financial intermediation.
  • Compliance: Must follow data protection, consumer protection, and transparency laws.
  • FinTechs: Supported, especially as they aid financial inclusion and transparency.


Legal affairs

Obligations and requirements to provide loan-giving-, factoring-, brokerage-, finetrading, and ancillary services described above

Providers of loan-giving, factoring, brokerage, finetrading, and ancillary services must comply with regulations mainly enforced by ASFI and follow relevant financial and commercial laws.

 Loan-Giving (Direct Lending / Crédito)
  • Allowed under Ley N° 393
  • Supervised by: ASFI.
  • Requirements:
    • Authorization as a bank, non-bank financial institution, cooperative, or fintech (via regulatory sandbox Decreto Supremo N° 5384).
    • Maintain minimum capital based on risk.
    • Follow AML/CFT laws (Law N° 004 and 262).
    • Have risk management and credit policies.
    • Respect consumer protection (clear contracts with interest rates, fees, terms).
    • Submit periodic reports to ASFI and UIF (Unidad de Investigaciones Financieras).
Factoring
  • Allowed as a commercial activity; ASFI supervision if structured as financial intermediation.
  • Requirements:
    • If non-financial (B2B invoice purchasing): commercial registration (Fundempresa), clear contracts, comply with tax and commercial laws.
    • If offered publicly or as financial intermediation: requires ASFI authorization, AML compliance, reporting, and operational controls.
Brokerage Services
  • Allowed under Ley N° 1834 (Ley del Mercado de Valores).
  • Supervised by: ASFI and Bolsa Boliviana de Valores (BBV).
  • Requirements:
    • Licensed as Casa de Bolsa (broker-dealer).
    • Meet capital and solvency requirements.
    • Employ experienced management and compliance officers.
    • Comply with market conduct, AML/CFT, and investor protection rules (disclosures).
    • Be a BBV member and submit audits and reports to ASFI regularly.
Finetrading (Supplier / Trade Finance)
  • Allowed but not specifically regulated; governed under general finance and lending rules.
  • Requirements:
    • If self-funded trade finance: register as a commercial company, transparent contracts, comply with tax, civil, and consumer laws.
    • If intermediating or managing third-party funds: require ASFI authorization, meet capital, AML, and compliance rules.
Ancillary Services (Credit Scoring, Analytics, Collections, Data Services)
  • Allowed with light regulation, subject to consumer protection and data laws.
  • Requirements:
    • No financial license needed unless handling funds or intermediating.
    • Comply with consumer protection laws and data protection (Law N° 164 on Telecommunications and ICT).
    • Contracts must be transparent and consent-based.
    • Credit reporting must register with credit bureaus (e.g., Infocred).


Additional comments regarding the legal situation for loan-giving-, factoring-, brokerage, finetrading-, and ancillary services or what FinTech’s must be aware of in this business area

Strict Regulation of Financial Intermediation
  • Loan-giving and brokerage are classified as financial intermediation, which only entities authorized by ASFI can perform.
  • Operating without a license — even through digital platforms — can be prosecuted as illegal financial activity under Ley N° 393.
  • FinTechs must clearly distinguish between:
    • Ancillary services (tools, tech platforms) that may not need a license.
    • Fund handling or investment decisions, which do require licensing.
Flexible Rules for Factoring and Finetrading
  • Permitted if they:
    • Do not manage third-party funds.
    • Use transparent contracts.
    • Focus on B2B transactions.
  • ASFI authorization may be required if activities involve public fundraising, risk transfer, or third-party fund management.
  • Fintechs should structure operations carefully to avoid unintentionally falling under financial intermediation rules.
Securities Brokerage Complexity
  • Fully regulated by Ley del Mercado de Valores (1834).
  • Requires Bolsa Boliviana de Valores licensing with:
    • Capital and solvency requirements.
    • Compliance with AML/CFT and investor protection rules.
    • Oversight by ASFI and the Bolsa Boliviana de Valores (BBV).
  • Fintechs can partner with licensed brokers or test solutions in the sandbox before applying for a full license.
 Ancillary Services: Legal Gray Areas
  • Services like credit scoring, analytics, or financial education are lightly regulated but must:
    • Avoid regulated activities (e.g., fund handling or deposit-taking).
    • Comply with Law N° 164 (data protection) and consumer protection standards.
  • Financial data sharing (e.g., credit history) requires user consent and, in some cases, registration with Infocred or other bureaus.
Fintech Sandbox (Decreto Supremo N° 5384, 2025)
  • Provides a controlled testing environment for innovative financial services (e.g., digital lending, factoring, embedded finance).
  • Requirements:
    • Submit proposals detailing model, risks, and consumer protections.
    • Operate within sandbox limits under ASFI supervision.
    • Use this stage to prepare for eventual licensing.
Key Risks for Fintechs
  • Misclassification of services (e.g., acting as a lender without a license) can lead to enforcement actions.
  • AML/CFT non-compliance can result in sanctions — even for ancillary services that influence financial decisions.
Unclear regulations for newer models (like finetrading platforms) require conservative legal structuring

Economic conditions

Market size for loan-giving-, factoring-, brokerage-, finetrading- and ancillary services and biggest companies in this business area

Loan-Giving (Préstamos Directos)
  • Market Size: Bolivia’s total credit portfolio in 2024 was around USD 30 billion, distributed as:
    • Commercial loans: ~40%
    • Microcredit: ~25%
    • Consumer loans>: ~20%
    • Housing loans: ~15%
FinTech lending: Less than 1% of total loans, but growing through the regulatory sandbox (DS N° 5384. Main Players:
Banco Nacional de Bolivia (BNB), Banco Mercantil Santa Cruz, BancoSol (microfinance leader), Banco FIE, Banco Unión (state-owned).

Factoring
  • Market Size: Estimated USD 150–300 million annually, mainly serving SMEs.
  • Trend: Increasing use as SMEs seek alternatives to traditional bank loans.
Main Players:
CrediFactor Bolivia, Banco Fortaleza, Banco FIE, Prodem, and Ecofuturo (microfinance institutions with SME-focused credit solutions).

Brokerage Services
  • Market Size: Bolivia’s capital market remains small and illiquid.
    • Bolsa Boliviana de Valores (BBV): ~USD 10 billion traded in 2024, mostly in fixed income and public debt.
    • Retail investors: Participation is low; digital brokerage is still limited.
Main Players:
BNB Valores, Boliviana de Valores S.A., Futuro Sociedad Agente de Bolsa, Bisa Valores S.A.

Finetrading (Trade Finance / Supplier Credit)
  • Market Size: No official data; estimated USD 500 million annually, mostly through:
    • Bank-backed instruments (e.g., letters of credit).
    • Informal supplier credit arrangements.
  • Fintech presence: No specialized finetrading FinTechs yet.
Main Players:
Banco BISA, Banco Mercantil Santa Cruz, Banco de Crédito BCP Bolivia.

Ancillary Services (Credit Scoring, Analytics, Collections)
  • Market Size: Small but growing, driven by digitalization and open banking discussions.
    • Growth areas: Digital credit scoring, collections automation, and SME management tools.
Main Players:
INFOCRED, CIFIN (credit bureaus), Solven, TuGerente, and emerging P2P/scoring tools under ASFI’s sandbox.



Additional comments regarding the economic situation for loan-giving-, factoring-, brokerage-, finetrading- and ancillary services or what FinTech’s must be aware of in this business area

Macroeconomic Challenges and Credit Risk
  • Bolivia’s economy is relatively stable but faces structural issues:
    • Low foreign currency reserves
    • Exchange rate pressure and inflation risks
    • High informality (over 70% of the labor force)
  • These factors heighten credit risk, particularly in consumer and SME lending.
  • Fintech requirement:Develop robust credit scoring using alternative data (e.g., mobile usage, payment history).
Underserved Markets and Credit Demand
  • High unmet demandexists among:
    • SMEs and microenterprises excluded from traditional loans
    • Rural and informal workers with no credit history
    • Younger consumers seeking digital-first solutions
  • Opportunities: Factoring and alternative lending models with mobile platforms, ow onboarding costs, and behavior-based analytics.
Digital Adoption and Fintech Growth
  • Internet and smartphone penetration is rising, especially in urban centers.
  • Expansion of digital wallets and online payment gateways creates opportunities for:
    • Embedded lending
    • Automated invoicing
    • Analytics-driven financial tools.
Capital Market and Finetrading Limitations
  • Bolivia’s capital market is shallow, dominated by institutional players and fixed-income products./li>
  • Retail brokerage and equity-based platforms face growth barriers without financial education and institutional partnerships.
  • Finetrading challenges:slow payment cycles, complex supply chains, and low trust among SMEs unless integrated with ERP or supply chain ecosystems.
Regulatory Tightness and Institutional Dominance
  • The financial system is highly regulated and centralized.
  • Banks and state-backed institutions dominate lending, making partnerships more feasible than direct competition for fintechs.
  • Regulators (ASFI, BCB) are open to innovation, but only under strictly controlled frameworks like the DS N° 5384 sandbox.


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