Charges and fees

4.35 Can the banks charge normal arrangement fees for new loans under the guarantee?

For new loans, it is permitted to make the usual charges applicable before the coronavirus crisis, such as arrangement fees and commitment fees.

4.36 How will payment of the fees be organised (one shot or pro rata)?

State guarantee fee for guaranteed loans:

  1. pricing = EU minimum of 50 or 100 basis points on an annual basis according to the duration of the credit (whether or not exceeding 36 months)
  2. pro rata according to the term of the loan, due on the whole of the capital regardless of whether the loan was actually taken up in whole or in part
  3. payable by the bank to the government; reporting by each bank
  • line per line details of all qualifying loans granted since the date of entry into force of the Law, including those already repaid or terminated in whole or in part
  • the Treasury calculates the premium on the basis of the reporting (maximum available capital x term, expressed in days, divided by 360 x premium)

Further rules on the procedure for the payment of the fee will be defined by Royal Decree.

4.37 What happens if the guarantee fee is unpaid or not paid in full?

Execution of the State guarantee is suspended if the premium is unpaid or not paid in full.

4.38 What charges must SMEs pay on guaranteed loans under the second guarantee scheme?

A distinction should be made here according to whether or not the duration of the guaranteed credit exceeds 36 months:

  • For a new additional loan or credit line with a maximum maturity of 36 months: the nominal maximum interest is 2% (excluding the “fee”). The fee comes to 50 basis points pro rata according to the term of the loan.
  • For a new additional loan or credit line with a with a maturity of more than 36 months and maximum 5 years: the nominal maximum interest is 2,5% (excluding the “fee”). The fee comes to 100 basis points pro rata according to the term of the loan.

The fee is compulsory under the EU rules on State aid. The credit institution can also choose to charge a total interest to the customer, without specifying the part covered by the fee.

4.39 Will all banks charge interest at 2% or 2,5% (excluding the fee) on new guaranteed loans under the second guarantee scheme?

No, this is a maximum (depending on whether or not the maturity of the guaranteed credit exceeds 36 months); free competition applies here.

4.40 Does the fee form part of the maximum interest that can be charged in the case of non-financial SMEs?

No. The fee of 50 or 100 basis points (depending on whether or not the maturity of the guaranteed credit exceeds 36 months) is compulsory under the EU rules on State aid and is additional to the maximum interest rate of respectively 2% or 2,5%.

4.41 How is the guarantee fee calculated in individual cases, given that the guarantee covers only part of the exposures?

This fee has to be paid on the whole capital of new additional loans and credit lines, i.e. the whole amount of the loan (including unused amounts on new additional credit lines).

4.42 Is the guarantee fee also payable for new additional loans expiring earlier than 31 December 2021?

Yes. The guarantee fee is also payable for guaranteed loans granted from the date of entry into force of the Law (24 July 2020) and repaid before 31 December 2021.

4.43 Is the guarantee fee also covered by the State guarantee?

Yes, the State guarantee covers principal and interest, including the guarantee fee.