English-speaking clients
who arrive prepared.

Plain Finance — Adviser Participation Terms (v3.2, September 2026)

Draft for legal review, not final.

Between Oscar Rojas, Alt-Mariendorf 50, 12107 Berlin ("Plain Finance", "we"), and you, the adviser. Questions: advisors@plainfinance.de.

1. What this is: we only introduce

Plain Finance introduces English speakers in Germany to independent, licensed advisers who work in English. We give no advice, compare or recommend no products, and arrange no contracts: we pass on requests from people who ask to be put in touch. For mortgages and insurance we act only as a tipster (Tippgeber): Plain Finance never collects or forwards documents, never prepares or checks an application, never names a lender, insurer, rate or product, and never says whether a client qualifies. Our guides and calculators are for the client's own understanding. You take part as an independent professional: these terms create no employment, agency or partnership.

2. Eligibility

You confirm that you:

• hold the licence or registration that each activity you offer here requires (§§ 34d, 34f, 34h or 34i GewO, or registration as a Rentenberater under § 10 RDG), entered in its public register;
• hold the professional indemnity insurance the law requires for it; and
• can advise and write in English.

Keep your profile accurate (licences, register numbers, areas, how you're paid), and tell us without delay if a licence, a registration or your insurance lapses, is restricted or is withdrawn. Which requests reach you follows the licences on your profile (section 7).

3. What we provide

• Requests in your areas that your licences cover, each with a summary and a clarity score.
• Before you take a request, a summary without the client's name or contact details. Once you take it: the client's contact details and when they can be reached, a request page with a file you share with them, and a PDF of the request.
• An adviser portal with your requests, your limits, your prices, your month and your invoices.

Each request reaches at most two advisers per round, and a further round only if the client asks for one. How a request reaches you depends on its payment model (6.2): a per-request request that fits an adviser's limits (4.9) is offered to one such adviser at a time, and otherwise goes to up to two advisers, the first to take it getting it; an access request goes to a pool, where up to two advisers see its summary and the first to take it gets it. A client who already works with you through Plain Finance may ask for a new request to be offered to you first (section 7).

No guarantee of volume, quality or fit. AI summaries and clarity scores are aids only: your own professional assessment prevails. The client's figures are their own, checked by no one. In the founding phase, volume may be low or zero.

4. Your commitments

4.1 Free first conversation. For each request you take, whatever its payment model, you offer the client a first conversation free of charge, by phone or video.

4.2 Say how you are paid. Before any paid work or product arrangement begins, tell the client clearly whether you are paid by commission from a product provider, by a fee from the client, or both. This comes on top of every disclosure the law requires of you, including any disclosure of what you pay us that your own rules require (for example § 17 FinVermV). Take a request from a client who asked for fee-only advice only if you advise them for a fee, without commission.

4.3 Prompt contact. Make a first contact attempt within 48 hours of taking a request (weekends and public holidays extend this), at the times the client gave where you can. If you can't reach them, record it on the request page.

4.4 Taking a request is a commitment. Take a request only if you intend to handle it. If you can't go on with one, release it promptly, on the request page or by email to advisors@plainfinance.de. We may limit how many requests you hold without a confirmed first contact, and, after a reminder and a further 48 hours without contact or reply, return an untouched request to the platform.

4.5 Professional duties remain yours. Needs assessment, advice, suitability, product selection, information and documentation duties, cost and remuneration disclosure, identification under anti-money-laundering law, and every other duty of your licence are yours alone.

4.6 Confidentiality and data protection. Everything about a request, including the summary you see before you take it, is confidential. Use it only to assess and handle that request, as a controller in your own right under the GDPR. Don't use it for marketing, don't contact clients whose requests you didn't take, don't pass it on, and delete what you have of requests you didn't take. Don't ask for health details through the request page: ask the client directly, under your own duties. Your links and portal login are personal: don't forward or share them. These duties continue after you leave.

4.7 Feedback and check-ins. We ask clients whether you got in touch and, about 60 and 120 days after you take their request, what they did and whether you helped them with anything else. We use the answers to check our introductions and to reconcile further topics under 6.7, and may ask you about a difference; we don't show you the answers. Repeated reports that you never got in touch, complaints about undisclosed pay or pressure selling, or further topics not recorded under 6.7 may lead to suspension or removal (section 8).

4.8 Documents. We never collect or forward documents for a mortgage or insurance request, in either direction: ask the client directly for what you need. On a fee-only or pension request, a document the client chooses to upload reaches only the adviser who took the request, never before the take. Use documents only for that client, check them yourself under your own duties, and delete your copies if you release the request or nothing comes of it.

4.9 Limits and offers. You may set limits in the adviser portal: the states the property may be in, the smallest loan, the residence status and work situations you take, and how many requests a month. Limits decide offers, which are made only on per-request topics; in the pool, only the monthly limit applies. Limits use lending facts only (the property's state; the loan, meaning the price plus purchase costs less the client's own funds, from the client's own figures; residence status; work) and never nationality. A fact not yet known counts as outside a limit that asks for it.

By saving limits, you agree to take the requests offered to you within them, inside the response window. An offer is yours alone until 22:00 on the next working day after it is made; when the client has reported a date, for three hours between 07:00 and 22:00. If you can't take one for a reason your limits couldn't express (a conflict of interest, say), pass on it on the request page, and it goes to the next adviser. We record how many offers you take, and may pause offers to an adviser who repeatedly lets them lapse or passes without such a reason. You may change or remove your limits at any time; offers already made stay yours to answer. If you also ask for requests outside your limits, they reach you as ordinary requests (section 3), with no duty to take them. Nor is there a duty to take an offer made because the client asked for you (section 7).

5. You and the client

Any advice, brokerage or other contract is between you and the client alone. You set your own fees or earn your own commissions. We are not a party to it and are not liable for your services or for the products you arrange.

6. What you pay

6.1 Clients pay nothing. Clients never pay us, and we never pay clients or pass them any part of what you pay. We tell clients how we're paid before they send a request, without stating amounts.

6.2 Two payment models, by the kind of request. Which model applies follows the kind of professional a request is for, not you:

• Per request: requests for a mortgage broker (§ 34i GewO; "financing expert" to clients) or an insurance broker (§ 34d Abs. 1 GewO). You pay the price list's price (6.3) for each one you take, whether it was offered to you alone or sent to two, and never for requests you only view or pass on.
• Access: requests for a fee-only adviser (§ 34i Abs. 5, § 34d Abs. 2 or § 34h GewO) or a pension adviser (Rentenberater, § 10 RDG). You pay a flat monthly access fee, the same whichever requests you take, and nothing per request. These requests go to the pool (section 3).
• With licences for both, you pay per request on per-request topics and the access fee for access topics.
• Tax advisers and lawyers are not on the platform and pay nothing, ever (§ 9 StBerG, § 49b Abs. 3 BRAO).

6.3 The price list. Prices per request taken, net:

No VAT is charged: Plain Finance is a small business under § 19 UStG (Kleinunternehmerregelung). A free place pays nothing. Nothing is charged yet. We'll tell you at least 30 days before the first charge, and you can leave at no cost before it applies.

For a mortgage, the band follows the loan (the price plus purchase costs, less own funds) in the client's own figures when you take the request; if they give none, the lowest band applies. A request that asks whether to go public or private costs nothing when you take it; if the client then takes out a private health policy through you, that is a further topic under 6.7 at the private-insurance price. One price list for everyone: we agree no individual prices. The same list on one page, to print: the price sheet.

6.4 Founding advisers and free places. The first ten advisers to join ("founding advisers") pay 50% of every price and of the access fee, for one year, starting on the later of their activation date and the date charging begins. The discount ends on the first anniversary of that date (28 February for a 29 February start); full list prices apply from then. Monthly access fees use the price at the start of the month, including when billed later. An adviser we give a free place pays nothing while it lasts.

6.5 VAT. Prices and the access fee are net. While Plain Finance is a small business under § 19 UStG (Kleinunternehmerregelung), we charge no VAT, and every invoice says so: "Gemäß § 19 UStG wird keine Umsatzsteuer berechnet (Steuerbefreiung für Kleinunternehmer)." If that changes, we add VAT at the statutory rate, show it on every line, and tell you at least 30 days before.

6.6 Notice of charges and changes. We tell you in text form at least 30 days before we first charge you anything, the first access fee included, and before any change to prices, bands, the access fee, the payment models or these terms. You may leave at no cost before the change applies.

6.7 Follow-on business: 24 months. A client we introduce to you stays our introduction for 24 months from when you take their request. They are the same client whether they come back through their Plain Finance account or with the same email address. If, within those 24 months, you take on another topic with them, by taking another of their requests or otherwise, you pay the difference between that topic's price and the highest price you already paid for them in the period, if it is higher. An access topic costs nothing extra. If the client came to you on the access model, you have paid nothing for them yet, so a per-request topic costs its full price. Record any further topic you take on outside a request on the request page ("Add a topic for this client") within 30 days of taking it on.

6.8 No passing on. Never charge the client for what you pay us: not directly, not as part of your fee, and not through the costs of a product.

6.9 Credits. Within 7 days of taking a request you may, once: report that the client's figures turned out outside your limits, and the charge is credited in full; or correct a charge that used the wrong topic or loan band, and the difference is credited. We may look into reports, and may reverse credits and end your participation for manifest misuse.

6.10 Statements and invoices. At the start of each month we email you a statement of the previous month's charges and credits. Each line names the request by its case number, never the client, with the topic and band, the list price, your tier and anything deducted under 6.7. Once we charge (6.6), the same lines come as an invoice, one a month: as a PDF by email, by post, or both, as you choose on your invoices page. Email is the default until you choose; by accepting these terms you agree to receive invoices as PDFs by email (§ 14 Abs. 1 Satz 5 UStG), unless you choose post. Tell us within 30 days if a line looks wrong: we correct an invoice by cancelling it and issuing a new one.

6.11 Payment. Pay each invoice by bank transfer within 14 days of its date, to the account it names. Nothing is charged before the start date we announce in text form at least 30 days ahead (6.6), and you may leave at no cost before then.

7. How matching works

Which requests you are sent, and in what order, depends only on these parameters, in this order (Art. 5 of Regulation (EU) 2019/1150):

1. the kind of professional the request is for, and whether your licences, and how you're paid, cover it;
2. the money areas you chose, matched against the request's area and any second area its AI summary notes;
3. the client's choice between fee-only and commission advice, where they made one;
4. the limits you set, and room in your monthly limit (in the pool, only the monthly limit);
5. a client's own request to offer a new request first to the adviser they already work with through Plain Finance;
6. advisers who named the area before those who take every area;
7. whoever has been sent the fewest requests in the last 30 days;
8. whoever has waited longest since their last one;
9. a rotation that differs from request to request, so no adviser comes first because of when they joined.

What you pay, your tier, a founding place and the price of a request never affect whether or when you are sent a request, and there is no way to pay for a better position. We check this every month.

8. Suspension and ending

You may end your participation at any time, in text form, with immediate effect. We may end it in text form, telling you why, 30 days before it takes effect. We may end it at once, telling you why, only where the law requires it, for a serious reason (for example a licence or insurance that lapsed, or manifest misuse), or after repeated breaches of these terms. We may pause offers or requests to you for the reasons in 4.4, 4.7, 4.9 and 6.9, and tell you why when we do; you can reply, and we look at it again. Requests you already took must still be handled properly or released promptly (4.4), and charges for them remain due. 4.5, 4.6, 4.8, 5, 6.7 and 6.8, and section 6 for charges that already arose, continue after you leave.

9. Your data, and what you can see

We process your data as our privacy policy describes. You see the summaries of requests offered or shown to you; the client's details and the shared file of the requests you take; and your offer record, statements and invoices in your portal. You see nothing about requests you weren't sent, or about other advisers. When you leave, your portal closes; keep a copy of anything you need.

10. Our liability

We run the platform with reasonable care, but can't promise it is always available. We are liable without limit for intent and gross negligence and for injury to life, body or health; for slight negligence only for breaching an essential contractual obligation, limited to the foreseeable, typical damage. We are not liable for clients' existence, conduct or solvency, or for the outcome of any advice or product.

11. Final provisions

German law applies. We tell you about changes to these terms in text form at least 30 days before they take effect; if you neither object nor leave before then, the changes apply. If a provision is invalid, the rest stays in force.