Offer to introduce a moratorium (suspension) on repayment of obligations for loan products and measures to preserve the stability of the financial system
In accordance with the Decision on Interim Measures for Banks to mitigate the consequences of the COVID-19 pandemic in order to preserve the stability of the financial system (RS Official Gazette No 103/2020 – hereinafter referred to as: the Decision) adopted by the National Bank of Serbia on 27 July 2020 that entered into force on 28 July 2020, Mobi Banka ad Beograd (hereinafter referred to as: the Bank), provided to its customers, on 31 July 2020, the Offer to apply moratorium on repayment of obligations for the Bank's loan products (hereinafter referred to as: the Offer).
1. When does the moratorium begin to apply and how long will it apply
In accordance with the aforementioned Decision, a suspension on repayment of obligations (moratorium) shall be introduced for all loan products being repaid in the period between 1 August 2020 and 30 September 2020. Suspended repayment of obligations (moratorium) shall also apply to loan obligations that fell due in July 2020, and were not settled by the customers.
We would like to point out that the National Bank of Serbia stipulated in the Decision that the moratorium does not apply to obligations for payment operations services (account maintenance fees, commission fees for transactions, etc.).
2. What does a customer need to do if they do not want the suspension of repayment (moratorium) to apply
All users of the Bank's loan products who do not want the moratorium to apply, i.e. who want to continue settling their obligations that fall due during August and September 2020, are required to notify the Bank thereof by 10 August 2020 at the latest, in the following manner:
- Electronically: by sending a notice declining the offer to suspend the repayment of obligations for loan products to the Bank's email address at firstname.lastname@example.org from the e-mail address registered by the customer with the Bank.
- By making a call to the Bank's Contact Center at 063 9005 and choosing option 4, then option 1 to automatically decline the offer. If the customer makes the call from a phone number that was not registered with the Bank, he/she will need to dial the Contact Center and talk to an operator to decline the offer of moratorium;
- Personally, by submitting the notice at the Bank's branch office, located at Omladinskih brigada 88, New Belgrade,
- By sending the signed notice by regular mail to the Bank's headquarters at Omladinskih brigada 88, New Belgrade, stating the following purpose: Declining the Moratorium.
The notice declining the moratorium needs to include the customer’s personal data (name, last name and the last three digits of the customer’s JMBG personal identification number), as well as the number/numbers of loan agreement, credit card agreement, or agreement on current account for which an overdraft was approved and for which they decline the application of moratorium. If the customer has several loan products with the Bank, he/she can choose to which loan agreement/credit card/current account authorized overdraft the moratorium will apply and to which it will not apply.
In the event that the customer has several loan products with the Bank, and fails to specify, in the notice declining the moratorium, the number of agreement for which he/she does not want the moratorium to apply, we will consider that the notice applies to all loan products that the client has with the Bank.
If, during the moratorium, the customer makes a payment in full into the loan sub-account for the obligations due in a certain month (July, August or September 2020), the Bank will not apply the suspension to the repayment of these loan obligations for the month in question, during the moratorium, and shall consider that the customer has given up the suspension of repayment for the settled obligation.
The customer can settle the obligations for loan products by paying the amount of due obligations in full into the basic account of the Bank No. 908-11501-07, and entering the number of the loan/credit card agreement as the reference number. Obligations for current account authorized overdraft can be settled by paying funds into the current account for which the authorized overdraft was approved.
Payment of funds by the customer in the manner described above implies that the moratorium offer was declined for the claims due and settled.
3. Application of repayment suspension (moratorium)
If a customer fails to decline the offer by 10 August 2020 in one of the manners stated in item 2, the Bank will consider that the customer has accepted the Offer and will automatically apply the suspension on repayment for all loan obligations that will fall due in the period starting on 1 August 2020, and ending on 30 September 2020. Suspension on repayment of obligations (moratorium) automatically applies to any outstanding liabilities for loan products that fell due in July 2020.
4. What does the moratorium on repayment of obligations entail
The moratorium is a suspension on repayment of obligations for loan products used by the Bank’s customers and implies that the payment of all obligations for loan products shall be deferred until the end of moratorium on 30 September 2020.
4.1. Accruing interest during the moratorium
During the moratorium, the Bank shall:
- Calculate, for loan obligations, the regular contractual interest on the amount of outstanding debt that does not include any obligations that fall due during the moratorium;
- Calculate the regular (contractual) interest on the used amount of funds, for obligations based on credit cards and current account authorized overdraft.
4.2. A representative example of the amount of liabilities before and after the end of the moratorium until the end of the repayment period
Representative examples for overdraft and credit card can be found on the following link.
A representative example of a cash loan repayment after the moratorium:
|A representative example of a dinar cash loan paid in March 2019 (16 installments repaid)|
|Loan amount||240.000 RSD|
|Repayment||24 months||24 months + 2 months moratorium|
|Monthly instalment||11.142,27 RSD||11.313,79 RSD*|
|Difference in monthly installment: RSD 171.52 Accrued interest during the moratorium: RSD 1,379.03|
|Nominal interest rate||10,75%, fixed|
|* installment amount after the suspension on repayment of the borrower's obligations (moratorium) for a period of two months|
4.3. Automatic extension of the validity period of the authorized overdraft and credit card if the validity period expires during the moratorium
In the event that the validity period of the account authorized overdraft or credit card expires during the moratorium, the validity period shall be automatically extended for the duration of the moratorium.
5. Termination of moratorium and manner of obligation repayment
The Bank will send a notice to all users of loan products, who have opted for the suspension on repayment of loan obligations, to their registered e-mails, including information on the expiration date of the moratorium, as well as the repayment manner after the moratorium expires.
5.1. Manner of repayment of liabilities upon termination of the moratorium for individual loan products of the Bank
After the moratorium ends, the customer shall continue the repayment as follows:
- For annuity loans, after the repayment period is extended by two months, or by three months (if the suspension on repayment of obligations also applies to liabilities that fell due in July 2020 and were not settled by the customer), the Bank will distribute the agreed regular interest rate calculated during the moratorium evenly over the remaining loan repayment period. The customer will pay the interest calculated in this manner during the moratorium together with the regular monthly obligation (monthly annuity) until the expiry of the contracted loan term.
- For credit cards, after the repayment period is extended by two months, or by three months (if the suspension on repayment of obligations also applies to liabilities that fell due in July 2020 and were not settled by the customer), the customer will pay the interest accrued during the moratorium in equal amounts over the next 12 months.
- For current account authorized overdraft, after the repayment period is extended by three months, the customer will repay the interest accrued during the moratorium and the outstanding obligations from the previous moratorium in accordance with the remaining repayment term. The validity of the authorized overdraft will be extended for the duration of the moratorium.
- Regular interest shall not attributed to the principal debt.
The Bank shall also distribute, in the manner specified in the previous paragraph, any default interest calculated during the moratorium on claims due before the moratorium applied. Default interest shall not attributed to the principal debt.
In addition to the above, the Bank will provide its annuity loan users with new repayment plans, including all the details of loan repayment, without any additional cost for the customer.
5.2. Additional ways to repay obligations
Within seven days of receiving the repayment plan referred to in item 5.1, the customer may request the following from the Bank, instead of applying the defined repayment manner upon the termination of moratorium:
- To settle all obligations covered by the moratorium (all annuities from the moratorium period , within seven days, principal and regular interest), in this case the monthly installment and repayment period remain the same (hereinafter referred to as: Option 1), or
- To settle all obligations based on regular interest calculated during the moratorium, with an extension of the loan repayment period for the duration of the moratorium (hereinafter referred to as: Option 2).
If the customer opts for one of the offered repayment methods, he/she needs to make a special request to the Bank in writing and provide funds on his/her current account to settle the obligations using the selected repayment method. The request for application of the stated loan repayment manner (option 1 or option 2) can be sent by the customer within 7 days of receiving the Bank's notification, from the registered e-mail address to email@example.com. Personal data (name, last name and the last three digits of JMBG personal identification number), the number of the loan sub-account and the loan repayment manner that the customer wants to apply need to be included in the request.
6. Repayment of loan obligations through a standing order and an administrative ban
On 28 July 2020, the Bank terminated the collection of obligations for loan products through standing orders and administrative bans.
Customers who intend to decline the moratorium have no reason to worry because if a customer submits a notice declining the offer within the prescribed period (until 10 August 2020), the Bank is obliged to collect liabilities due after 28 July 2020 in the amount that would have been collected if the Bank had not suspended payments on standing orders (without any additional interest calculation), as well as to activate a standing order.
With this in mind, all customers who want to settle their obligations that fell due in July 2020, i.e. obligations that fell due by 31 July 2020, need to make a payment in the amount of obligations due directly to the loan sub-account, or by making an internal transfer from the current account to the loan sub-account via the Bank's application.
The customer can settle the obligations for loan products by paying the funds to settle the due obligations in full into the basic account of the Bank No. 908-11501-07, and entering the number of the loan/credit card agreement as the reference number. Obligations for current account authorized overdraft can be settled by paying funds into the current account for which the authorized overdraft was approved. Payment of funds by the customer in the manner described above implies that the moratorium offer was declined for the claims due and settled.
7. Other measures and activities of the Bank to preserve the financial system stability
In addition to applying the moratorium on repayment of liabilities in the manner previously described, the Bank will apply a number of other measures and activities to preserve the stability of the financial system in the Republic of Serbia from 01 August 2020 until 30 September 2020:
- The Bank shall not charge default interest on overdue and outstanding claims incurred during the moratorium;
- The Bank shall not initiate enforcement proceedings;
- The Bank shall not initiate forced collection procedure against the debtor;
- The Bank shall not take any other legal action to collect the receivables from the debtors;