El vacío legal de la regulación española en materia de crowdfunding

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CLAVES:

  • La ley de fomento de financiación empresarial crea por primera vez en España un marco regulatorio para las empresas de crowdfunding y crowdlending.
  • Entre los requisitos para cosntituir una compañía de este tipo se encuentran las limitaciones al capital aportado por inversores acreditados e inversores no acreditados.
  • Las empresas del sector han de obtener el visto bueno de la CNVM para regularizar su situación. La opinión generalizada en las compañías es que la regulación ayudará a crear confianza entre los inversores.
  • Un vacío legal de la ley es que no se prevé el aseguramiento contra el fraude, algo que si sucede en otros países como Canadá o Reino Unido. AIG ha lanzado un producto asegurador para el sector destinado para estos países.

La irrupción en el mercado de la financiación de las empresas de crowdfunding ha supuesto una revolución que ha cogido por sorpresa a competidores y legisladores. En España los intentos para regularizar esta actividad ya han comenzado. La promulgación de la Ley de fomento de financiación empresarial, el pasado abril, pretendía, no terminar con este tipo de actividades sino regularlas con el fin de garantizar que la financiación colectiva y las empresas relacionadas con esta actividad actuaran en un entorno regulado.

La ley de fomento de la financiación empresarial

El legislador, entendiendo que existen riesgos de que los fondos destinados a financiar un proyecto concreto puedan ser utilizados para otros fines diferentes a su cometido inicial, trata de mitigar estas eventualidades. Para evitar fraudes cuatro son los puntos en esta ley que han de ser tenidos en cuenta en relación con las empresas de financiación colectiva (crowdfunding) o de financiación colectiva (crowdlending) y el capital máximo que pueden recolectar:

  • Se establece un límite en cuanto a la cuantía con la que puede ser financiada un proyecto dado a través de estos medios (2 millones de euros), salvo que dicho proyecto sea avalado por inversores acreditados, en cuyo caso la cuantía asciende a 5 millones de euros.
  • La cantidad máxima que un inversor no acreditado puede aportar a un proyecto son 3.000 €.
  • Del mismo modo un inversor no acreditado puede, como máximo, financiar varios proyectos auspiciados en una misma compañía con una cuantía máxima de 10.000 euros en total.
  • Se establece, asimismo, la obligación de que toda inversión haya sido debidamente razonada por el inversor.

Además, la ley establece una serie de requisitos en relación con las actividades de las compañías de crowdfunding y crowdsourcing. Dichas compañías no podrán ofrecer servicios de asesoramiento financiero.

Otros de los aspectos que regula la Ley es la actividad a la que se deberían de limitar las plataformas de financiación colectiva:

  • Se entiende como financiación colectiva aquella limitada a la emisión de obligaciones u acciones ordinarias y privilegiadas.
  • La emisión o suscripción de participaciones en sociedades de responsabilidad limitada.
  • La solicitud de préstamos.

En cuanto a los requisitos financieros:

  • El capital social mínimo ha de ser de, al menos 60.000 €.
  • En caso contrario las compañías han de suscribir un seguro de responsabilidad civil profesional, o equivalente, con una cobertura mínima de 300.000€, pero en ningún caso están obligadas a cubrir monetariamente si hay casos de fraude.

Adicionalmente las compañías del sector han de obtener, como requisito indispensable para desarrollar su actividad, el visto bueno de la CNMV para poder operar en España. Algunas empresas ya han obtenido dicha licencia.

Licencias concedidas en España a empresas de Crowdsourcing y Crowdlending

Desde que la ley fue puesta en funcionamiento son varias las entidades que han obtenido una licencia para operar como Plataformas de Financiación Colectiva (PFC), que es como denomina la ley a este tipo de empresas. El consenso entre los inversores y los directivos de las compañías de financiación colectiva es que la nueva regulación y en especial el requisito de obtener una licencia para operar es beneficioso, no sólo para las compañías, sino también para los inversores.

En palabras de Pepe Borrell, director de Crowdcube en España: “Estamos muy satisfechos con esta nueva acreditación, porque por primera vez en la historia las startups y pymes españolas disponen de un mercado regulado en el que poder realizar ampliaciones de capital de manera ordenada. Cada vez son más las empresas que podrían acudir a las vías de financiación tradicional y optan por el crowdequity”.

Carles Escolano, cofundador de Arboribus (otra de las compañías que han recibido la licencia) asegura que la nueva ley permitirá que el crecimiento del sector se acelere. Añade “Ofrece la seguridad jurídica imprescindible para que inversores institucionales incorporen este tipo de activo a sus carteras de inversión y para que EAFIs y gestores patrimoniales tengan garantías suficientes para recomendárselo a sus clientes.”

Aún quedan vacíos legales por cubrir

Los riesgos a los que se enfrentan los inversores cuando confían en una empresa de crowdfunding o crowdlending son muchos y en España, actualmente, la ley no protege a los usuarios frente a los fraudes.

La compañía aseguradora AIG ha lanzado recientemente un seguro destinado a cubrir los posibles fraudes en actividades de financiación colectiva. En principio este seguro no será lanzado en España. De momento se podrán contratar estos servicios únicamente en Canadá y el Reino Unido aunque desde la compañía prevén que el producto será fácilmente exportable a otros mercados si la legislación se adapta a ello.

La compañía Eureeca, con base en Reino Unido y Dubai, ha sido la primera en contratar este seguro.

La ley de fomento de financiación empresarial no obliga a las compañías proveedoras de servicios de crowdfunding o crowdlending a ofrecer un seguro a sus clientes o inversores. “La Ley de Fomento de la Financiación Empresarial, que regula el crowdfunding en España, no contempla una cobertura ante este tipo de fraude”, explica José Moncada, CEO de La Bolsa Social.

Si las previsiones de AIG son correctas una ausencia de seguros en este sector no ayudará a mentalizar a las empresas e inversores de la seguridad de sus inversiones en plataformas de crowdsourcing y crowdfunding. Según Lex Baug, directivo de la compañía aseguradora, “el sector sólo es tan fuertes como la confianza que inspire en sus inversores”.

En el único caso en que sí que se obliga a que las compañías provean de un seguro es en el caso del equity crowdfunding.

En otros países, como Reino Unido o Canadá, sí que es exigido por la legislación que las empresas de crowdfunding y crowdlending provean de seguros a inversores y clientes.

La actividad reguladora en lo que respecta a crowdfunding y crowdlending no ha parado de crecer en los últimos años en muchos de los países del entorno europeo y americano. En Estados Unidos, Francia, y Alemania (y los ya mencionados Reino Unido y Canadá) se han promulgado leyes para regular el sector.

Fuente: BBVA Research

En Europa la Comisión Europea lleva estudiando las plataformas de crowdfunding desde 2014 y aún no se han tomado medidas concretas. Dado que en ninguno de los países europeos citados (salvo el Reino Unido) se han establecido medidas de protección contra fraude mediante seguros y dado que el estudio por parte de la comisión está más encaminado a potenciar el mercado del crowdfunding en lugar de regularlo, es de esperar que la situación no vaya a cambiar durante un tiempo.

SPANISH FINTECH. La CNMV establece condiciones severas para el Crowfunding. 27 de Mayo de 2016 [consultado 31-08-2016]. Disponible en: http://spanishfintech.net/la-cnmv-establece-condiciones-severas-crowfunding/

FINTECH MOVE. Notas sobre la Ley 5/2015, de fomento de la financiación empresarial. 06 de noviembre de 2016 [consultado 31-08-2016]. Disponible en: http://www.fintechmove.com/crowdfunding/notas-sobre-la-ley-52015-de-fomento-de-la-financiacion-empresarial/

LA CELOSÍA. Los inversores españoles en crowdfunding no disponen de un seguro contra fraudes. 29 de agosto de 2016 [consultado 31-08-2016]. Disponible en: http://www.lacelosia.com/los-inversores-espanoles-en-crowdfunding-disponen-de-un-seguro-contra-fraudes/

BUSINESS WIRE. AIG Launches a New Equity Crowdfunding Insurance Product to Protect Investors. 24 de mayo de 2016 [consultado 31-08-2016]. Disponible en: http://www.businesswire.com/news/home/20160524005941/en/AIG-Launches-Equity-Crowdfunding-Insurance-Product-Protect

COMISIÓN EUROPEA. commission staff working document. Crowdfunding in the EU Capital Markets Union. 03-05-2016 [consultado 31-08-2016]. Disponible en: http://ec.europa.eu/finance/general-policy/docs/crowdfunding/160428-crowdfunding-study_en.pdf

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