The Croatian National Bank has received numerous consumer queries in connection with the granting of online credit by a bank, which operates in the Croatian market under the name Ferratum and has a head office on Malta, regarding guarantees provided by a legal person with a head office in another Member State of the European Union subject to a fee.

The company that had previously operated under the name Ferratum Bank plc changed its name to Multitude Bank plc and operates as part of the group Multitude AG (previously Ferratum Oyj/Ferratum Group). However, in the Croatian market the Bank has continued to engage with consumers under its previous name Ferratum, as it is recognised in the market. We would like to emphasise that this is the same legal entity that currently operates under the name Multitude Bank plc.

With this regard, we find it necessary to point out that under Croatian regulations a guarantee, as a common instrument of collateral for the repayment of credit, is a legal transaction concluded between a creditor (in this case a bank) and a guarantor, whereby the guarantor assumes an obligation vis-á-vis the creditor to settle a valid and due obligation of the debtor, should the latter fail to do so.

It is common for consumers to turn to family members or other close persons as guarantors for credit agreements, whereby such guarantors provide the “service of being a guarantor” to the consumer free of charge. However, under applicable Croatian regulations it is not prohibited to conclude an agreement between a legal or natural person and a consumer – beneficiary of the credit – under which this person undertakes to act as the guarantor for the consumer in the credit agreement (that is, to conclude a guarantee agreement with the bank for the obligation of the consumer arising from the credit agreement), and the consumer undertakes to pay an appropriate compensation for the service. Such an agreement concluded between the person providing the guarantee and the consumer – beneficiary of the credit – is a separate agreement subject to a fee and should be viewed separately from the credit agreement. This means that the consumer is obligated to meet the obligations assumed under both agreements.

We would like to underline that the Croatian National Bank is not competent for the supervision of consumer protection when consumers select guarantors or for the supervision of legal relationships between consumers – beneficiaries of a credit – and guarantors. An appeal regarding the behaviour of a legal person established in another EU Member State may be submitted to the State Inspectorate competent for conducting inspection supervision in accordance with Article 142 of the Consumer Protection Act (Official Gazette 19/2022, 59/2023, 59/2026).

Therefore, it is exceptionally important for consumers, when concluding credit agreements with the Multitude Bank plc (which continues to engage with Croatian consumers under the name Feratum) or any other credit institution with a head office in another Member State that provides banking services directly within the territory of the Republic of Croatia and offers Croatian consumers credit online, to award special attention to the provisions of the terms and conditions of the loan agreement which regulate the contracting of guarantees, as well as when selecting a guarantor and concluding a possible agreement with the guarantor to carefully review all available information and submitted documentation connected with the specific contractual relationship with the guarantor, that is, get well acquainted with the obligations arising from the contractual relationship, and in particular with the obligation to pay a fee for being provided a guarantee.

We would like to warn consumers in particular to carefully check the terms and conditions, and the amount of the fee for the guarantee, as such a fee for the guarantee, in contrast to a usual guarantee which is not subject to payment, is paid regularly and independently from the regular repayment of the credit, and in case of defaulting on the payment, the fee for the guarantee is automatically prolonged against payment of new fees. Considering that the fee for a guarantee is concluded separately from a credit agreement, we would like to advise consumers to include in the overall cost of credit all cost they need to pay in connection with the credit agreement and the guarantee agreement – the interest rate, credit approval fee, fee for the guarantee and possible fees for the prolongation of the guarantee, in order to get a proper sense of the actual cost of a credit.

In addition, attention should also be paid to the account to which the amount due is paid since sometimes consumers are requested to pay the amount due under the credit agreement, as well as the fee for the guarantee, to the account of a third company which is neither the creditor nor the guarantor. We advise consumers to keep evidence of all payments.

We would also like to stress that claims under a credit agreement or a guarantee may be assigned to third parties, meaning that a consumer may receive a warning notice or a proposal for enforcement from a company the consumer never had a business relationship with. We would like to advise consumers to carefully read all documents and if they consider the claim as unfounded, seek legal assistance and undertake measures to protect their rights.

In addition, and in connection with credit agreements concluded online, we would like to refer you to the Press Release of the Croatian National Bank of 11 November 2026 which states that when concluding credit agreements with credit institutions having their head office in another Member State, the Croatian National Bank cannot provide the same level of monitoring of consumer protection as it does for clients of credit institutions with head offices in the Republic of Croatia whose operations it supervises.