In a recent update, Google announced that personal loan apps will no longer have access to users’ contacts or photos effective May 31, 2023. This move is aimed at preventing loan apps from using this data to harass defaulting customers by sending messages to their contacts or blackmailing them.
Personal Loans Defined
Google defines personal loans as non-recurring loans given by an individual, organization, or entity to an individual consumer for purposes other than financing the purchase of a fixed asset or education. Consumers need information about the quality, features, fees, repayment schedule, risks, and benefits of loan products to make informed decisions.
Requirements for Personal Loan Apps
Apps that provide personal loans, including those that offer loans directly, lead generators, and those that connect consumers with third-party lenders, must have the App Category set to “Finance” in Play Console and disclose the following information in the app metadata:
1. Repayment Period
The app must provide the minimum and maximum period for loan repayment.
2. Maximum Annual Percentage Rate
The maximum annual percentage rate (APR), which generally includes interest rate plus fees and other costs for a year, must be disclosed.
3. Representative Example
A representative example of the total cost of the loan, including the principal and all applicable fees, must be provided.
5. Short-term Personal Loans
Apps that promote personal loans that require repayment in full in 60 days or less from the date the loan is issued are not allowed.
6. Compliance with Local Laws and Regulations
Google must be able to establish a connection between the developer’s account and any provided licenses or documentation proving their ability to service personal loans. Additional information or documents may be requested to confirm the account’s compliance with all local laws and regulations.
Apps that provide personal loans or have the primary purpose of facilitating access to personal loans (i.e., lead generators or facilitators) are prohibited from accessing sensitive data such as photos and contacts. The following permissions are prohibited:
Additional Requirements for Personal Loan Apps in Nigeria and Kenya
- Complete the Personal Loan App Declaration for Nigeria and provide the necessary documentation to support the declaration.
- Digital Money Lenders (DML) must adhere to and complete the LIMITED INTERIM REGULATORY/ REGISTRATION FRAMEWORK AND GUIDELINES FOR DIGITAL LENDING, 2022 (as may be amended from time to time) by the Federal Competition and Consumer Protection Commission (FCCPC) of Nigeria and obtain a verifiable approval letter from the FCCPC.
- Loan Aggregators must provide documentation and/or certification for digital lending services and contact details for every partnered DML.
- Upon Google Play’s request, provide additional information or documents relating to compliance with applicable regulatory and licensing requirements.
- Complete the Personal Loan App Declaration for Kenya and provide the necessary documentation to support the declaration.
- Digital Credit Providers (DCPs) should complete the DCP registration process and obtain a license from the Central Bank of Kenya (CBK). Provide a copy of the license from the CBK as part of the declaration.
- If not directly engaged in money lending activities and only providing a platform to facilitate money lending by registered DCP(s) to users, accurately reflect this in the declaration and provide a copy of the DCP license of the respective partner(s).
- Currently, only accept declarations and licenses from entities published under the Directory of Digital Credit