---

name: prompt-pack-lending-platform-terms
description: Use when drafting terms of service for a digital lending platform offering consumer or SME loans. Covers loan application process, credit assessment disclosure, interest rate transparency, repayment terms, default consequences, collection practices, and consumer protection compliance. MENA-first: addresses UAE Central Bank, SAMA (KSA), and Banque du Liban requirements, interest/Sharia compliance considerations, and DIFC/ADGM regulated lending frameworks.
license: MIT
metadata:
id: prompt-pack.lending-platform-terms
category: prompt-pack
practice_area: fintech-payments
priority: P2
intent: [drafting, lending-platform-terms]
related:
- prompt-pack-payment-services-agreement
- prompt-pack-payment-facilitator-agreement
- prompt-pack-open-banking-api-terms
- prompt-pack-privacy-impact-assessment
- heuristic-always-state-jurisdiction-first
source: Louis — HAQQ Legal AI (github.com/sboghossian/mini-claude-for-legal)
version: "1.0"

Lending Platform Terms

When to use this

Use this skill when a digital lending platform, fintech company, or regulated financial institution needs to draft its borrower-facing terms of service governing the origination, disbursement, and repayment of loans. The document is addressed to borrowers and governs the relationship from application through loan closure or default.

Triggers:

• "Draft the loan terms for our consumer lending app."
• "We're launching an SME lending platform — what should the terms cover?"
• "We need terms that comply with UAE Central Bank lending regulations."

Required inputs

Input	Why it matters	Default
Platform name	Names the document	Ask user
Jurisdiction(s) of operation	Determines regulatory framework (licensing, consumer protection, interest rate caps)	Ask user
Borrower type	Consumer vs SME vs both — triggers different regulatory protections	Ask user
Loan products offered	Personal loan, SME working capital, invoice financing, buy-now-pay-later — determines product-specific clauses	Ask user
Sharia-compliance required	Determines whether interest-based or murabaha/ijara structure is used	Ask user
Regulatory licence held	Operating licence determines mandatory disclosure obligations	Ask user

Optional inputs

• Governing law and dispute resolution forum
• Credit bureau(s) used for credit assessment
• Collection agency relationships
• Privacy policy cross-reference
• Early repayment terms (whether permitted and at what cost)

Document structure

1. Introduction and Acceptance

• Platform identity and regulatory status (licensed by [UAE Central Bank / SAMA / BdL / DFSA / FSRA / etc.])
• Scope: these terms govern all loans originated through the platform
• Acceptance: by submitting a loan application, the borrower accepts these terms
• Capacity: borrower must be of legal age and capacity in their jurisdiction

2. Eligibility and Application

• Eligibility criteria: nationality, residency, minimum age, income thresholds
• Application process: steps to apply (KYC / AML submission, income verification, identity documents)
• Credit assessment: platform uses [named credit bureau(s)] and internal scoring models; approval at platform's sole discretion
• No guarantee of approval: explicitly state that submission of an application does not guarantee loan approval

MENA note: UAE requires credit bureau checks via Al Etihad Credit Bureau (AECB); KSA through SIMAH or Bayan Credit Bureau; platforms must comply with applicable credit reporting laws.

3. Loan Terms and Disclosure

For each loan product, disclose in clear language:

• Principal amount
• Annual percentage rate (APR) or equivalent total cost of credit disclosure
• For Sharia-compliant products: profit rate, murabaha cost price, and total payment amount instead of "interest"
• Tenor (term in months)
• Repayment schedule (monthly installments, amounts, due dates)
• Total amount repayable
• Fees: origination fee, processing fee, early repayment fee, late payment fee
• Any security or guarantees required

Consumer protection requirement: Most jurisdictions require disclosure of the total cost of credit (not just the nominal interest rate) in a standardized summary box before acceptance. Confirm local regulatory requirements.

4. Disbursement

• Method: transfer to verified bank account; timing (same day / T+1 / T+2)
• Conditions to disbursement: signed loan agreement, completed KYC, any required guarantees
• Currency: AED, SAR, USD — specify; for LBP-denominated loans, include FX risk disclosure given currency instability

5. Repayment Terms

• Due dates and payment method (direct debit, bank transfer, platform wallet)
• Prepayment: right to repay early; whether early repayment fee applies (many consumer protection regimes cap or prohibit early repayment penalties)
• Grace period (if any) after a missed payment before default is triggered
• Allocation of payments: typically applied first to fees, then interest/profit, then principal (disclose clearly)

6. Default and Consequences

Define default clearly: typically, a payment missed by more than [5 / 10 / 30] days, or material misrepresentation in the application.

On default:

• Late payment charge: state the daily/monthly rate (subject to regulatory caps)
• Acceleration: right of platform to declare the full outstanding balance immediately due
• Credit bureau reporting: notify the borrower that default will be reported to the applicable credit bureau
• Collection: the platform may engage licensed collection agencies; describe the process and borrower rights

Do not include: threats of criminal action for civil debt default (common misuse in some MENA markets); penalties that constitute unenforceable liquidated damages under applicable law.

7. Collection Practices

• Permitted contact channels and hours (comply with consumer protection guidelines on harassment)
• Right to assign the debt to a third-party collection agency or debt purchaser
• Debt restructuring: platform's discretion to offer restructuring; not a binding obligation

8. Consumer Protection

Include explicit statements of borrower rights under applicable law:

• Right to receive a copy of the loan agreement
• Right to early repayment (subject to fee, if any)
• Right to complain: internal complaints procedure, then regulatory ombudsman or supervisory authority
• Anti-discrimination: loan decisions not made on prohibited grounds

9. Privacy and Data Use

Cross-reference the platform's Privacy Policy. Specifically state:

• Credit bureau sharing: borrower consents to credit bureau reporting of application and repayment data
• Marketing: opt-in / opt-out for marketing use of data
• Fraud prevention: data shared with fraud prevention databases

10. Governing Law and Dispute Resolution

• For UAE-licensed platforms: typically DIFC Court or UAE courts with Dubai International Arbitration Centre (DIAC) arbitration option; consumer protection law may limit choice-of-law clauses
• For KSA: Saudi courts; CIBAFI arbitration for Islamic finance disputes
• Mandatory: consumer complaints must first go through internal process and then to regulatory ombudsman before arbitration

11. Amendments to Terms

• Platform reserves right to amend terms with [30-day] notice for prospective loans
• Existing loans governed by terms in effect at loan origination date
• Consumer protection law may restrict unilateral amendment of interest rates on existing loans

Jurisdictional notes

Jurisdiction	Key regulatory requirements
UAE	UAE Central Bank Consumer Finance Regulation and licensed lending framework; maximum APR caps apply to consumer loans; Al Etihad Credit Bureau mandatory checks; AMLCFT Law compliance.
DIFC / ADGM	DFSA / FSRA regulated lending; English law; more flexible product structuring available; primarily B2B / sophisticated borrowers.
KSA	SAMA licensed consumer finance companies; Sharia compliance required for most products; SIMAH / Bayan credit bureau integration; maximum profit rate caps under SAMA guidelines.
Lebanon	Banque du Liban licensing; severe currency instability — all loan terms must address USD vs LBP denomination; consumer lending market severely constrained.
Egypt	Financial Regulatory Authority (FRA) oversight of non-bank lending; Central Bank of Egypt for banks; consumer credit disclosure requirements under Egyptian Consumer Protection Law.

Common mistakes

• Failing to disclose total cost of credit: regulators in UAE, KSA, EU, and UK require the equivalent of an APR / APRC in a standardized disclosure; quoting only the monthly rate misleads borrowers.
• Sharia-non-compliant language: using "interest" in documents for Islamic finance products creates regulatory and reputational risk; use "profit rate" and "murabaha" / "ijara" terminology consistently.
• No complaints procedure: most consumer protection regimes require an internal complaints procedure with defined response timelines.
• Blanket data consent: MENA data protection laws (UAE PDPL, KSA PDPL) require specific consent for each processing purpose; a single "I agree to use of my data" clause is insufficient.

Related skills

• [[prompt-pack-payment-services-agreement]]
• [[prompt-pack-payment-facilitator-agreement]]
• [[prompt-pack-open-banking-api-terms]]
• [[prompt-pack-privacy-impact-assessment]]
• [[heuristic-always-state-jurisdiction-first]]