How It
Works
The CNV regulatory framework for crowdlending has several interlocking parts. This page explains how the system is structured, what legal vehicles are permitted, and what the registration process means in practice.
The architecture of
regulated crowdlending
Three parties,
one regulated framework
In a crowdlending operation, three parties interact: the investor who provides funds, the borrower (or project) that receives them, and the platform that facilitates the transaction. CNV regulations govern the platform's obligations to both investors and the market.
The platform acts as an intermediary — it cannot take deposits, it cannot guarantee returns, and it must maintain investor funds in segregated accounts. Its role is strictly defined by regulation.
How a regulated operation
unfolds
Platform Registers with CNV
Before operating, a platform must apply for registration as a Proveedor de Servicios de Financiamiento Colectivo (PSFC). The CNV evaluates the application against the requirements set out in Resolution 717/2018. Registration is not automatic — it requires meeting specific capital, governance, and operational standards.
Project is Listed with Required Disclosures
When a borrower wants to raise funds through the platform, the platform must publish a prospecto de emisión containing specific information about the borrower, the amount sought, the interest rate, the repayment term, and the risk profile. This document is regulated — its minimum contents are specified by the CNV.
Investors Participate with Regulated Limits
Investors can commit funds to projects. The CNV framework establishes limits on how much any individual investor may commit to a single project and across all crowdlending platforms, designed to prevent excessive concentration of risk for retail investors.
Funds Held in Segregated Accounts
Investor funds must be held in accounts that are separate from the platform's own operating funds. This segregation is a core investor protection — it means that if the platform faces financial difficulties, investor funds are not commingled with platform assets.
Platform Reports to CNV Regularly
Registered platforms must submit regular reports to the CNV covering their operations, the projects they have facilitated, default rates, and other regulatory metrics. This ongoing reporting is what makes supervision possible.
Permitted legal
vehicles
CNV regulations specify the legal structures through which crowdlending operations can be conducted. Each vehicle has distinct characteristics that affect how the investment is structured and what protections apply.
Pagarés
Promissory Notes
The most common instrument in Argentine crowdlending. The borrower issues a pagaré (promissory note) to investors, representing a direct debt obligation. The terms — amount, rate, maturity — are specified in the prospecto de emisión.
Fideicomisos
Financial Trusts
A fideicomiso financiero is a financial trust structure where assets (typically receivables) are transferred to a trust, which then issues certificates to investors. This structure can provide additional separation between the borrower's risk and the investment.
Obligaciones Negociables
Negotiable Obligations
Corporate bonds issued by companies seeking financing. When issued through crowdlending platforms, they must comply with both CNV securities regulations and the specific crowdlending framework requirements.
Important Note on Legal Vehicles
The descriptions above are educational summaries of the vehicle types referenced in CNV regulations. The specific legal characteristics, tax treatment, and implications of each instrument vary and depend on the specific terms of each operation. This is not legal or financial advice. Consult qualified professionals before making investment decisions.
What registered platforms
must do
Go deeper into
the regulations.
Our Regulations page breaks down each CNV resolution article by article with plain-language explanations.