Kaptl × TurnKey Lender — Product Offer & Contract Summary¶
Compiled from: signed MSA / Order Form (30 June 2026), signed DPA (30 June 2026), Decision Tree, Approval Logic, IFRS 9 Accounting Policy, and the TurnKey Lender solution brochure.
1. The product Kaptl will offer¶
Core product — a standard EUR-denominated consumer cash / personal installment loan:
- Fixed monthly installments (principal + interest)
- Measured at amortised cost under IFRS 9 — the accounting policy treats this as a textbook SPPI case ("nothing exotic")
- Business model: Hold to Collect — loans are held to collect contractual cash flows over their life; sales are incidental / infrequent
Sizing
| Customer type | Max amount | Max term |
|---|---|---|
| New customer | €3,000 | 18 months |
| Repeat customer | Up to existing approved limit | — |
Roadmap products (not in initial scope)
- Earned Wage Access (EWA) — included in TurnKey's commercial terms at no extra license / professional-services cost once launched, but explicitly not committed as part of the initial implementation scope or delivery timeline. The first annual portfolio-tier review is tied to the EWA go-live date (12 months after), not the core platform go-live.
- KYC — deferred to Phase 2 (Shufti Pro, iDenfy under evaluation), layered on top of the ID + liveness check already built into origination.
2. Automated decision logic¶
Applies to every application via TurnKey's Decision Engine, in this order:
Fraud & Lists Checks
→
Hard Rules
→
Soft Rules
→
Approve / Review / Reject
Repeat customers loop back at their existing approved limit.
Fraud & lists
Reject on hit
- Multiple applications in a short period
- Fake ID / photo of ID / copy of ID / stolen identity
- Cross-application matching (email + phone)
- Internal blacklist
- External blacklists
- Sanctioned persons
Hard rules
Fail → Reject
Basic eligibility — every one must pass.
- Age 20+
- Bulgarian citizenship
- Valid ID (photo / copy) + liveness test
- Credit history: 0 current DPD; MaxDPD <15 in last 12 months; no write-off / legal / other bad status per AnaCredit (ex-CCR)
- Up to 5 active loans (max 1 from an NBFI)
- At least 1 successfully closed loan (repeat borrowers)
- Minimum €1,200 official net monthly income
- More than 6 months with current employer
- More than 12 months total employment in last 24 months
- Permanent or long-term fixed employment contract
- Self-employed / civil contract → possible approval only after additional verification (not an automatic pass)
Soft rules
Fail → Review
Route to manual underwriting rather than an automatic reject.
- Debt-to-income < 50%
- Free cash flow ≥ €400 / month after existing loan obligations (per register)
- Located outside Bulgaria → flagged
- Data mismatch → flagged
Approve — straight-through
Review — manual underwriting
Reject
3. What TurnKey Lender delivers¶
| Module | Key capabilities |
|---|---|
| Loan Origination | Configurable application flows, document templates, dictionaries, disclaimers, loan offers |
| Underwriting | Multiple loan offers, manual decisioning, 2-level approval flow, blacklisting / whitelisting |
| AI Decision Engine | Anti-fraud, credit policy, internal & geolocation rules, built-in scoring, customizable rules against external data providers |
| Calculations Engine | Schedule types, fees (NSF, disbursement, past due, rollover, payoff, etc.), EIR / APR / XIRR / IRR, rollover & restructuring |
| Loan Servicing | Disbursement / payment via PSP, auto-charges, promise-to-pay, manual write-offs |
| Debt Collection | Priority queues, collectability scoring, delinquency buckets, action plans, call scripts |
| Reports | Portfolio, operational, risk, underwriting, credit scoring, Excel report builder |
| Notifications | Automated email / SMS on 30+ triggers, 200+ smart markers, customizable templates |
| Security / Compliance | SOC 2 Type II, PCI DSS, NIST, OWASP, ISO 27001, GDPR plug-in |
Custom integrations (in initial scope)
AnaCredit / BNB registry check, NSSI Bulgaria (1 check), EasyPay disbursement / repayment, OTP / SMS / email provider, Bulgarian-language customer-facing UI (backoffice may remain English).
All custom integrations above are contingent on Kaptl supplying the required access, credentials, and approvals.
4. Commercial terms¶
- License Commencement Date — tied to the actual Customer Go-Live Date, currently estimated 7 September 2026; not triggered automatically by the estimate. Requires: platform live in production, SOW scope materially complete, credentials issued, UAT completed / accepted, and written confirmation of readiness.
- Delivery — Professional Services delivery timeline up to 11 weeks (Exhibit A / SOW).
- Support — Premium, 24/5 coverage, 2 hr Sev1 / 4 hr Sev2, 30 requests / month, 3 authorised contacts. New / modified credit rules within existing scope: 48-business-hour delivery to UAT (unlimited requests). Net-new products / material workflow changes require separate scoping.
- Hosting — TurnKey covers all cloud hosting costs for the platform environment for the full term.
- White-labelling — Included: Kaptl branding, colours, logos and terminology throughout customer-facing sections. No "Powered by TurnKey Lender" attribution without written consent.
- Portfolio tier review — Annual; first review 12 months after EWA go-live (not core platform go-live). Tier is locked between reviews regardless of interim fluctuation; increases apply prospectively only, never retroactively.
- Liability cap — 150% of the applicable annual tier, based on the trailing 12 months.
- Termination — Kaptl may terminate for TurnKey's uncured material breach (14-day cure + 7-day further notice). After the 3-year Initial Term, either party may terminate for convenience with 1 month's written notice.
- Initial Term — 3 years.
5. Open items to track¶
Open items now live in the live checklist — tick them off there as they close. Delivery milestones are tracked on the Delivery Timeline & Go-Live page, and vendor credential/contract progress on Vendor Onboarding Status.