You make payments, keep the receipts and wait for the loan to end. But the next demand includes more interest, fees and a balance that does not match your calculations. Before paying the disputed amount or signing a new agreement, establish exactly what is being demanded and on what basis.
The debt is growing: what to check first
- Request an itemised calculation: how much was disbursed, what was charged, which payments were recorded and how the balance arose.
- Compare each payment with the lender’s records: the receipt amount and the date funds were credited may differ.
- Check cost limits against the loan type, dates and applicable rules. A high DAE does not itself prove a violation.
- Challenge a specific entry and its basis. A complaint does not automatically cancel the debt, stop charges or authorise you to stop paying.
You paid on time — why is there still a debt?
You send the next payment and see a debt again. The reason may lie in interest, payment records or a disputed charge. To understand where your payments went, you need a detailed calculation: the total shown in an app does not explain it.
In Decision No. 39/3 of 10 August 2026, the National Commission for Financial Markets — CNPF — found violations in 973 of 309,609 EASY CREDIT agreements reviewed, concluded between 1 January 2024 and 11 May 2026. The decision concerns specified agreements, not all the company’s customers.
The regulator allowed 180 days for the measures prescribed in the decision. Agreements in Annex 3, already covered by final court judgments, are excluded from those measures: CNPF did not revisit judicial decisions. An order addressed to the lender does not itself confirm that money has already been paid back.
For a borrower, the conclusion is specific: check your own agreement and the stage of your own dispute. While an unexplained amount remains in the demand, you cannot assess what is justified to pay, what to challenge or whether a document needs an urgent response. Start with a calculation that can be checked entry by entry.
Reconciling the loan: documents, payments and balance in one table
Request a calculation as of a specific date and collect documents covering the whole period. The latest receipt or a screenshot of the total balance will not show what happened earlier.
You need the agreement with its annexes and schedule, proof of disbursement, all receipts and statements, and the lender’s detailed calculation. Add agreements changing the terms, letters reducing charges and any confirmation of closure. Also keep payment demands received.
Bring the information together in a simple table:
| Item | Where to find it | What to check |
|---|---|---|
| Amount originally disbursed | Statement, disbursement document | How much you actually received and how it relates to the total credit amount in the agreement |
| Interest | Agreement, calculation of charges | The rate, period and amount to which the calculation was applied |
| Fees and other payments | Agreement terms, itemised breakdown | The description, basis and date of each entry |
| Late-payment penalties | Lender’s calculation | The breach, period and amount on which they were charged |
| Each payment you made | Receipt and lender’s records | The date, amount credited and its allocation |
| Balance as of the chosen date | Detailed calculation | Which amounts make it up and which payments were deducted |
The National Bank of Moldova’s guidance notes that a payment may arrive after it is sent, while a payment-terminal fee may reduce the amount received by the lender. Compare both the crediting date and amount with the receipt.
Hypothetical example. MDL 20,000 was disbursed, MDL 42,000 has been paid, and the lender still claims a balance. The difference between payments and disbursement is MDL 22,000. If the general cost cap equal to the amount disbursed applies to this loan, the principal-plus-cost benchmark is 20,000 + 20,000 = MDL 40,000. The discrepancy needs examination. But neither the full difference nor the amount above that benchmark automatically becomes a refund: the composition of charges, payment records and consequences of the specific violation must be established.
Mark each discrepancy: “payment not found”, “different date”, “unexplained fee”, “no basis for the penalty”. This is already a specific question for the lender. The formula “everything paid minus everything received” shows a difference, but does not replace a legal assessment of overpayment.
Does the debt fail to match your payments?
We will check the agreement, charges and payment records. We will assess grounds for recalculation, repayment of disputed amounts or a defence against the lender’s demand, and identify the next step. Prepare the agreement, statements and any reply or payment demand received.
Three cost limits: 50%, 0.04% and the overall cap
The interest rate, other payments and total cost have different limits. To apply them to your calculation, you need the loan type, dates and the relevant version of the rules. The following are reference points for an ordinary consumer loan.
50% caps the annual interest rate, not DAE. DAE expresses the total cost of credit as an annual percentage and includes, among other things, interest and fees. According to BNM’s explanation, late-payment charges are not included in DAE. A DAE above 50% therefore does not itself prove that the interest-rate cap has been exceeded.
0.04% per day caps the combined other related payments, excluding interest, calculated on the total credit amount. The base is not the current balance; the cap is shared, not separate for each fee. With a total credit amount of MDL 20,000, the arithmetic benchmark is 0.04% × 20,000 = MDL 8 per day for those payments combined. Check a one-off fee at the date it was charged: averaging it over the whole term may conceal a breach of the daily cap. In CNPF Case No. 51/1, the regulator identified a violation specifically when examining other payments, including a disbursement fee.
The overall cap concerns cost in addition to repayment of principal. In a case covered by the rule, the established cost — interest, fees, penalties and other payments — must not exceed the amount disbursed. This does not mean that all repayments, including principal, are limited to the original disbursement alone.
A specific exception concerns a loan for purchasing, building or renovating/modernising a home, secured by immovable property to ensure performance of the loan obligation. It cannot be shortened to “any security removes the cap”: those housing-related terms require separate analysis.
Since 25 October 2025, the relevant provisions have been moved to Article 15¹ of the consumer credit law. A reference to the former Article 15(9) needs checking against the dates and applicable version; older agreements also require examination of transitional rules. In the August case, CNPF assessed established obligations, including penalties: you do not need to wait until the disputed amount has actually been paid to start checking it.
Recalculation, early repayment and a “discount”: different outcomes
Recalculation corrects a disputed charge; early repayment requires a calculation as of the closure date; a discount may change only some terms. Before agreeing, establish exactly what happens to the other demands.
A confirmed violation of applicable limits may trigger consequences under which the lender can demand only the amount originally disbursed. If you have already paid more, grounds for a refund are assessed separately. Such a claim needs support from a specific rule, violation and applicable version of the law.
Check what the lender has definitively waived. In Decision No. 39/3, CNPF considered Article 15¹(6)/(7): a waiver of the excess must be real, final and unconditional. In the circumstances examined, a discount “if you keep paying on time” was not accepted as such a waiver. Nor does a smaller amount claimed in court itself mean the remaining claim has been waived. The letter or new agreement should therefore make clear which amounts have been removed and which conditions the lender attaches to the reduction.
For early repayment, request a separate calculation as of your chosen date. Check the reduction of cost relating to the remaining term and the basis of any fee. Before paying “to close everything”, obtain a written calculation of the full settlement amount. Afterwards, check how the payment was recorded and the closure document.
A written complaint: the specific entry and contacting CNPF
In the complaint, identify the date, disputed entry, amount and supporting document, together with your details and agreement number. Ask how that amount was calculated. A starting point for your complaint could read:
Please provide a calculation under agreement No. [number] as of [date]: the original disbursement, interest, fees, penalties, each payment received and its allocation, and the balance. My documents and your calculation differ regarding [entry, amount, date]; supporting evidence is attached. Please explain the documentary and legal basis of this amount, check the payment records and correct the calculation if an error or violation is identified. If the disputed amount has already been paid, please consider grounds for refunding it. Please provide a reasoned written response. Attachments: [list]. Date, signature.
Submit it under the lender’s published procedure and keep proof of registration. An ordinary email without a qualified electronic signature is not always sufficient, although the lender may allow an electronic complaint without one.
If the response contains only a total or a reference to the agreement, check whether your discrepancy has been explained. For example, where was the payment you identified recorded, and for what period was the disputed fee charged? Keep the original calculation and response: this shows what changed after the complaint and which question remains unexplained.
Since 1 October 2026, CNPF Regulation No. 25/6 has applied: as a general rule, the provider’s final response is due within 15 working days of registration of the complaint. An extension is permitted in cases provided for by law. This is the lender’s response deadline, not a guarantee of recalculation or a refund within that period.
If the complaint is refused or no response is received, you can contact CNPF. Under the official procedure, attach the original complaint, proof of submission and any reply. An electronic submission to CNPF itself requires an electronic signature: an ordinary scan of a handwritten signature does not replace it. Check the submission rules.
The lender refused or is already recovering the debt: what to review with a lawyer
After a refusal, its grounds need assessment; if you receive a document from a court or an enforcement officer, the necessary action and deadlines must be identified separately. Do not wait for the ordinary complaint response if proceedings are already underway. Keep the whole document and proof of its receipt date.
A complaint does not provide universal permission to stop paying. It does not itself suspend charges, court deadlines or enforcement. Decisions about payments depend on the agreement, calculation and stage of the case.
A lawyer can compare the terms and applicable version of the law, check a particular charge, payment records and the lender’s corrections. They can then assess grounds for recalculation, a refund or a defence against the demand, and prepare a reasoned position. If there is already a court judgment on the debt, that materially changes the analysis: news about regulatory action does not replace examination of judicial documents.
Bring the agreement, reconciliation table, receipts, calculation and lender’s response to the consultation. Instead of the general question “can the loan be written off?”, you can address a specific one: why was this amount charged, what evidence is available and what substantiated claim could come next?