Article 35 · Law 5/2019

Pre-borrower information

This document explains who provides the mortgage-intermediation service, how the service is remunerated, the nature of any advice and how to make a complaint. Please keep a copy for future reference.

Version: 26 July 2026

Registration

Banco de España · E790

Status

Non-tied mortgage-credit intermediary

Advice

Available; not presented as independent advice

Remuneration

May be paid by the borrower and by a lender, as disclosed in advance

1. Identity, registration and supervision

Maxim Zhosan acts as a mortgage-credit intermediary and is registered in the Banco de España Register of Mortgage Credit Intermediaries under code E790. The registration can be checked through the official registers published by Banco de España.

The competent supervisory authority is Banco de España, without prejudice to the powers of other consumer, data-protection or judicial authorities.

2. Relationship with lenders

The intermediary is not tied to, and does not work exclusively for, any particular lender. The lenders considered in a case depend on their criteria, geographic coverage, available products and the borrower’s circumstances.

The service does not guarantee access to every product available in Spain or approval by any lender.

3. Mortgage advice

Mortgage-advice services may be provided. Because the intermediary may receive remuneration from lenders, the service is not advertised or described as independent advice.

Before a personalised recommendation is made, the scope, products considered, conditions and remuneration of the advice will be set out in writing. The recommendation will be based on current information about the borrower’s personal and financial circumstances, preferences and objectives, and a copy will be provided on paper or another durable medium.

4. Amounts payable by the borrower

The initial mortgage review does not by itself create an obligation to pay a fee. A borrower fee may apply to an intermediation or advisory service only where it has been expressly agreed in writing before that paid service begins.

The applicable agreement will state the exact amount or an objectively determinable calculation method, the included services, taxes where applicable and the payment conditions.

5. Lender commissions and other incentives

The intermediary may receive a commission or other remuneration from a lender or another party if a mortgage is completed or another agreed event occurs. The existence, amount, calculation method and, where relevant, payment frequency depend on the lender and the particular transaction.

Where the exact amount is not known when this document is provided, it will be disclosed later in the personalised information or service documentation before the borrower becomes bound. A non-tied intermediary receiving commissions from more than one lender must, on request, provide information about the different types and amounts of commission paid by the lenders whose products are offered.

6. Borrower fee and lender commission

Where a borrower fee and a lender commission are both payable, they are separate forms of remuneration. The borrower fee is not automatically deducted from, or reduced by, the lender commission. Both will be disclosed in the applicable agreement or personalised information before the borrower becomes bound.

7. Information supplied by the borrower

The borrower must provide complete, accurate and up-to-date information and supporting documents within the requested timeframe. If sufficient verifiable information is not provided, a lender may be unable to assess creditworthiness and the loan may not be granted.

Only after the relevant service agreement is in place and the borrower instructs the intermediary to approach lenders will the necessary information be presented faithfully to the relevant lender for its own creditworthiness assessment, subject to data-protection law. Submitting the initial review form does not send data to lenders.

8. Complaints and out-of-court redress

Complaints may be submitted free of charge to reclamaciones@harborone.es or to the postal address stated above. A reasoned decision will be issued in less than one month. If the complaint is rejected or is not answered in time, the complainant may refer it to the Banco de España Complaints Service within one year from the date the original complaint was filed.

The full procedure is available on the Complaints page of this website.

9. Keeping this information

Use the print control on this page to print or save a dated PDF copy. When electronic delivery is connected to the application workflow, the applicable version will also be included with the submission confirmation.