CNV
Regulations
A plain-language guide to Argentina's crowdlending regulatory framework. We cover the key resolutions, investor rights, platform obligations, and official complaint channels — all in accessible language.
Educational Content Only
This page explains regulatory content for educational purposes. It does not constitute legal advice. For legal questions, consult a qualified attorney. For official regulatory information, visit the CNV website at cnv.gov.ar.
The Founding Framework
Resolution 717/2018 is the primary regulatory instrument governing crowdlending in Argentina. It established the PSFC (Proveedor de Servicios de Financiamiento Colectivo) registration category and defined the basic operating requirements for crowdlending platforms.
Defines the scope of the regulation and the concept of collective financing. Establishes that any platform facilitating financing between investors and borrowers must register with the CNV as a PSFC before commencing operations.
Sets out the registration requirements for PSFCs, including minimum capital requirements, governance structure requirements, and the requirement to designate a compliance officer. Applications must be submitted to the CNV with supporting documentation.
Defines the permitted instruments through which crowdlending operations can be conducted: pagarés, fideicomisos financieros, and obligaciones negociables. Each instrument type has specific disclosure and documentation requirements.
Establishes the mandatory content of the prospecto de emisión — the information document that platforms must publish for each financing project. Minimum content includes borrower identity, financial information, risk factors, fees, and repayment terms.
Defines investor limits: the maximum amount any individual investor may commit to a single project and across all PSFC platforms in a given period. These limits apply to retail investors and are designed to limit concentration risk.
Regulatory Updates Post-2018
Resolution 717/2018 has been modified and complemented by subsequent CNV resolutions that expanded and refined the framework. These modifications addressed gaps identified in practice and adapted the framework to market developments.
Subsequent resolutions clarified and expanded the reporting obligations of PSFCs, specifying the frequency, format, and content of reports that registered platforms must submit to the CNV for supervisory purposes.
Modifications addressed the procedures that platforms must follow when borrowers default, including notification requirements, collection procedures, and the treatment of recovered funds for distribution to investors.
Updates incorporated anti-money laundering and know-your-customer requirements applicable to PSFCs, aligning the crowdlending framework with broader financial sector AML/CFT obligations under Argentine law.
What investors are
entitled to
The CNV framework creates specific rights for investors in crowdlending operations. These rights exist regardless of what any individual platform's terms and conditions say — they are established by regulation.
Information
Rights
Right to a Complete Prospecto
Before participating in any project, investors have the right to receive a complete prospecto de emisión containing all information specified in CNV regulations. Platforms cannot list projects without this document.
Right to Risk Information
The prospecto must include a risk section describing the specific risks of the project and the borrower. This is a mandatory disclosure — platforms cannot omit risk information from project listings.
Right to Fee Transparency
All fees charged by the platform to investors must be clearly disclosed before any investment is made. Hidden fees or fees not disclosed in advance are not compliant with CNV regulations.
Right to Default Notification
When a borrower defaults, the platform must notify affected investors within the timeframes specified in CNV regulations. Investors cannot be left without information about the status of their investment.
Operational
Protections
Fund Segregation
Investor funds must be held in accounts separate from the platform's own funds. This protects investors if the platform faces financial difficulties — their funds cannot be used to pay platform debts.
No Platform Self-Investment
Platforms and their related parties are prohibited from investing in projects listed on their own platform. This protects investors from conflicts of interest where platform operators might favor their own investments.
CNV Supervision
Registered platforms are subject to ongoing CNV supervision. Investors in registered platforms have the backing of a regulatory supervisor who can investigate complaints and impose sanctions for non-compliance.
Complaint Channel Access
Investors have the right to file complaints with the CNV against registered platforms. The CNV is required to investigate complaints and can take enforcement action against platforms that violate regulations.
What registered platforms
must do
Pre-Operational Requirements
Before listing any projects or accepting any investor funds, a platform must complete the CNV registration process and meet all pre-operational requirements.
Maintain minimum capital levels specified by the CNV. Capital requirements are designed to ensure the platform has resources to operate and meet its obligations.
Establish a governance structure that meets CNV requirements, including the designation of a compliance officer responsible for regulatory adherence.
Implement technology systems that meet CNV security and operational requirements, including data protection and transaction integrity standards.
Continuous Operational Obligations
Once registered and operating, platforms must maintain compliance with ongoing obligations that apply to every project and every investor interaction.
Publish a complete and accurate prospecto de emisión for every project listed. Verify borrower information. Maintain records of all transactions for the periods specified in CNV regulations.
Submit periodic reports to the CNV on schedule. Maintain segregated investor accounts. Update disclosures when material information changes. Report defaults within required timeframes.
Maintain AML/KYC procedures for all users. Preserve conflict of interest controls. Respond to CNV information requests. Cooperate with supervisory inspections.
Platforms operating
without registration
When a platform facilitates crowdlending operations without CNV registration, it operates outside the regulatory framework. This has significant implications for investors.
Key Risk for Investors
Investors who participate in crowdlending operations through unregistered platforms lose all the protections that the CNV framework provides. There is no regulatory supervisor overseeing the platform, no mandatory disclosure requirements, no fund segregation rules, and no official complaint channel with authority to investigate or sanction the platform.
No Mandatory Disclosures
Unregistered platforms are not required to publish prospectos de emisión or provide any of the information that CNV regulations mandate. Investors have no regulatory right to this information.
No Fund Segregation
Unregistered platforms are not legally required to maintain investor funds in segregated accounts. Investor funds may be commingled with platform operating funds, creating risk of loss if the platform faces financial difficulties.
No CNV Oversight
The CNV has no supervisory authority over unregistered platforms. It cannot inspect their operations, require them to produce information, or impose sanctions for investor harm through its standard supervisory channels.
Regulatory Sanctions
Operating a crowdlending platform without CNV registration is itself a regulatory violation. The CNV can pursue enforcement actions against unregistered operators, including public warnings and referrals to other authorities.
How to Verify Registration
Investors can verify whether a platform is registered by consulting the CNV's public registry of PSFCs, available at cnv.gov.ar. Registration status is a matter of public record.
Limited Recourse
When things go wrong with an unregistered platform, investors have limited regulatory recourse. Civil remedies may exist, but the specific investor protections of the CNV framework do not apply.
Official complaint
channels
Investors who believe a registered platform has violated CNV regulations have access to official complaint channels. Understanding these channels — and what to expect from them — is part of knowing your rights.
CNV Complaint System
The CNV operates an official complaint system for investors. Complaints against registered PSFCs can be submitted through the CNV's website. The CNV is required to investigate complaints that fall within its supervisory jurisdiction.
cnv.gov.arWritten Complaint to CNV
Formal written complaints can be submitted to the CNV at its offices in Buenos Aires. Written complaints should include: the investor's identity, the platform's name and registration number, a description of the alleged violation, and supporting documentation.
Complaint GuidelinesCOPREC (Consumer Protection)
For issues that also involve consumer rights, investors may be able to use the COPREC (Consumidor.gob.ar) system. This system handles disputes between consumers and financial service providers and can complement CNV complaint processes.
consumidor.gob.arCivil Courts
Investors may also have recourse to civil courts for claims against platforms, regardless of whether the platform is registered. Civil remedies exist independently of the regulatory complaint process, though legal representation is typically required.
Consult a qualified attorneyWhat to Prepare Before Filing a Complaint
When preparing a complaint against a registered platform, gather: your account statements and transaction records, the prospecto de emisión for any affected projects, all communications with the platform, evidence of the alleged violation, and your personal identification documents. The more documentation you provide, the more effectively the CNV can investigate.
Questions about
the framework?
If you have questions about the regulatory content on this page, you can reach us through our contact form. We can clarify educational content but cannot provide legal advice.