{"id":5246,"date":"2026-11-12T01:54:52","date_gmt":"2026-11-12T00:54:52","guid":{"rendered":"https:\/\/www.ondara.group\/non-bank-financial-institutions-ecb\/"},"modified":"2026-11-12T01:54:52","modified_gmt":"2026-11-12T00:54:52","slug":"non-bank-financial-institutions-ecb","status":"publish","type":"post","link":"https:\/\/www.ondara.group\/en\/non-bank-financial-institutions-ecb\/","title":{"rendered":"Non-bank financial institutions: what the ECB watches"},"content":{"rendered":"<p><strong>Non-bank financial institutions are asset managers, funds, insurers and other vehicles that channel savings into the economy and extend credit without being banks or taking deposits; and in November 2026 they are once again in regulators&#8217; sights.<\/strong> On 5 November, Isabel Schnabel, a member of the ECB&#8217;s Executive Board, warned that their rapid growth can complicate monetary policy and called for tougher rules for them. Five days later, Australia&#8217;s market regulator published its second review of private credit, criticising transparency. Here is what all this means for a private investor looking at Spain. This article is educational and is not an investment recommendation.<\/p>\n<h2>What non-bank financial institutions are<\/h2>\n<p>Supervisors group them under the label non-bank financial intermediation (NBFI). It covers investment funds, pension funds, insurers, private debt vehicles, securitisation vehicles and lending platforms. They are sometimes called &#8220;shadow banking&#8221;, but the term is loose: many of them are regulated, just under different rules from a bank.<\/p>\n<p>The key difference is where the money comes from. A bank lends using deposits that customers can withdraw at any time, which is why it faces very strict capital and liquidity requirements. A non-bank lends with capital entrusted by investors who accept the risk and, usually, a fixed term. In Spanish real estate finance, this segment is what is known as alternative lending.<\/p>\n<h2>What the ECB said in November 2026<\/h2>\n<p>In a speech in Frankfurt on 5 November 2026, reported by Reuters, Schnabel made three main points:<\/p>\n<ul>\n<li><strong>Monetary policy transmission.<\/strong> A growing share of government debt is held by non-banks, some of them highly leveraged. If rates move quickly, these investors may be forced to sell, amplifying volatility.<\/li>\n<li><strong>Regulation.<\/strong> Europe should not loosen bank rules but should ask more of hedge funds, investment funds and insurers.<\/li>\n<li><strong>Central banks as a safety net.<\/strong> If these entities force interventions to stabilise markets, the central bank may end up straining its own mandate.<\/li>\n<\/ul>\n<p>This is not a new stance. In an October 2025 speech, Schnabel explained that the share of non-banks in total credit had risen from 12% to 30% and argued for a <a href=\"https:\/\/www.ecb.europa.eu\/press\/key\/date\/2025\/html\/ecb.sp251003_1~edb1443d00.en.html\" target=\"_blank\" rel=\"noopener\">macroprudential framework for the non-bank sector too<\/a>. And in its May 2026 Financial Stability Review, the ECB called for close monitoring of opaque, interconnected private markets, while noting that it does not see them as a systemic concern per se in the euro area.<\/p>\n<h2>Trends: what is happening worldwide and in Spain<\/h2>\n<ul>\n<li><strong>Australia, 10 November 2026.<\/strong> ASIC, Australia&#8217;s markets regulator, published its second private credit review: it examined 24 funds with around AUD 18 billion under management and found that complex structures, opacity and poor disclosure of fees and conflicts of interest persist (<a href=\"https:\/\/www.abc.net.au\/news\/2026-11-10\/asic-slam-250-billion-dollar-private-credit-sector\/107365226\" target=\"_blank\" rel=\"noopener\">ABC News<\/a>).<\/li>\n<li><strong>United States, November 2026.<\/strong> Seven of the ten large semi-liquid private credit vehicles followed by an industry tracker prorated their latest redemption window: investors who wanted out could only partly exit. We covered this in <a href=\"https:\/\/www.ondara.group\/en\/private-credit-redemptions-liquidity\/\">private credit redemptions<\/a>.<\/li>\n<li><strong>United States, 9 November 2026.<\/strong> The Federal Reserve opened its first survey of lending standards in direct lending, precisely because of the lack of data on the sector (see <a href=\"https:\/\/www.ondara.group\/en\/private-credit-lending-standards\/\">private credit lending standards<\/a>).<\/li>\n<li><strong>Spain, October 2026.<\/strong> According to the Observatory of Alternative Financing with Mortgage Collateral in Spain, with market analysis by PwC and a legal framework by Cuatrecasas, alternative lending accounts for 20% of the total in Spain, compared with 75% in the US, 50% in the UK and 40% in France and Germany; volume lent rose from EUR 1,473 million in 2023 to EUR 2,583 million in 2025 (<a href=\"https:\/\/www.pwc.es\/es\/real-estate\/observatorio-financiacion-alternativa-colateral-hipotecario-espana.html\" target=\"_blank\" rel=\"noopener\">PwC<\/a>). We expand on these figures in <a href=\"https:\/\/www.ondara.group\/en\/alternative-mortgage-lending-spain-2026\/\">alternative mortgage lending in Spain<\/a>.<\/li>\n<\/ul>\n<h2>Why regulators watch non-banks<\/h2>\n<p><img data-dominant-color=\"938e7f\" data-has-transparency=\"false\" style=\"--dominant-color: #938e7f;\" decoding=\"async\" src=\"https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos.webp\" alt=\"Regulation of non-bank financial institutions: stacked folders and documents\" width=\"1680\" height=\"945\" class=\"aligncenter size-full wp-image-5242 not-transparent\" loading=\"lazy\" srcset=\"https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-200x113.webp 200w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-300x169.webp 300w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-400x225.webp 400w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-600x338.webp 600w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-768x432.webp 768w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-800x450.webp 800w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-1024x576.webp 1024w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-1200x675.webp 1200w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos-1536x864.webp 1536w, https:\/\/www.ondara.group\/wp-content\/uploads\/2026\/11\/entidades-no-bancarias-regulacion-documentos.webp 1680w\" sizes=\"auto, (max-width: 1680px) 100vw, 1680px\" \/><\/p>\n<p>The concern is not that lending outside the banking system is bad in itself. It is that certain combinations of features can turn a local problem into a general one. Supervisors focus above all on four:<\/p>\n<div class=\"tabla-seo\">\n<table>\n<caption>Source: ECB (speech of 5 November 2026 and May 2026 Financial Stability Review) and ASIC (November 2026); prepared by Ondara Group, November 2026<\/caption>\n<thead>\n<tr>\n<th>Risk monitored<\/th>\n<th>What it means<\/th>\n<th>What to ask as an investor<\/th>\n<\/tr>\n<\/thead>\n<tbody>\n<tr>\n<td>Liquidity mismatch<\/td>\n<td>The vehicle promises frequent redemptions but invests in loans that cannot be sold quickly<\/td>\n<td>When and how can I get my money back? Are there redemption limits?<\/td>\n<\/tr>\n<tr>\n<td>Leverage<\/td>\n<td>The vehicle borrows to invest more, amplifying gains and losses<\/td>\n<td>Is there debt ranking above my investment? Who gets paid before me?<\/td>\n<\/tr>\n<tr>\n<td>Opacity<\/td>\n<td>Limited information on valuations, fees and conflicts of interest<\/td>\n<td>What information do I receive on each deal, and how often?<\/td>\n<\/tr>\n<tr>\n<td>Interconnection<\/td>\n<td>Banks and non-banks fund each other; stress can spread<\/td>\n<td>What does repayment depend on: the asset, the borrower or third parties?<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n<p>In Spain, the CNMV (the national securities regulator) publishes an annual <a href=\"https:\/\/www.cnmv.es\/portal\/publicaciones\/publicacionesgn?id=56\" target=\"_blank\" rel=\"noopener\">monitor of non-bank financial intermediation<\/a>. Its latest edition, covering 2024, concluded that the sector is growing while keeping a low risk profile.<\/p>\n<h2>What it means for a private investor in Spain<\/h2>\n<p>For a saver with cash sitting in the bank who is considering alternative lending, there are two readings.<\/p>\n<p>On the one hand, the growth of non-bank lending meets a real need. In Spain, bank lending to real estate and construction fell by 80% between 2008 and 2025, according to Banco de Espa\u00f1a (the Spanish central bank) data cited by the Observatory. That retreat has left projects and phases that banks no longer finance and that private lenders now cover.<\/p>\n<p>On the other hand, more regulatory attention means investors should demand what supervisors demand: clarity on liquidity, leverage and the information they will receive. Not all structures are the same:<\/p>\n<ul>\n<li><strong>Semi-liquid or open-ended vehicles.<\/strong> They offer periodic exit windows but can limit them if many investors ask to leave at once, as is happening in the US.<\/li>\n<li><strong>Deal-by-deal investment.<\/strong> The investor knows which loan and which collateral they are in. The money is illiquid until maturity, but the term is known from the outset and does not depend on what other investors do.<\/li>\n<li><strong>Leveraged vehicles.<\/strong> If the vehicle borrows, the investor ranks behind that lender in the repayment order.<\/li>\n<\/ul>\n<p>At Ondara we have worked since 2018 on a deal-by-deal basis: every loan is secured on a real property asset, we analyse the collateral value, the LTV and the exit plan before offering it, and investors deal directly with the management team. We pursue target double-digit returns, never guaranteed, and the minimum investment is EUR 25,000. For how the upfront analysis works, see <a href=\"https:\/\/www.ondara.group\/en\/private-real-estate-debt-due-diligence\/\">due diligence in private real estate debt<\/a>, and learn more <a href=\"https:\/\/www.ondara.group\/en\/who-we-are\/\">about who we are<\/a>.<\/p>\n<h2>Risks to consider<\/h2>\n<ul>\n<li><strong>Loss of capital.<\/strong> If the borrower does not pay and enforcing the collateral does not cover the debt, you may lose part or all of your investment. Property collateral mitigates, but does not eliminate, that risk.<\/li>\n<li><strong>Illiquidity and term.<\/strong> The money is tied up until maturity, and the term may be extended if the exit is delayed.<\/li>\n<li><strong>Regulatory change.<\/strong> New rules for the non-bank sector may change costs, structures or disclosure requirements.<\/li>\n<li><strong>Contagion risk.<\/strong> Stress in other markets, such as US private credit, can tighten financing conditions and delay refinancings or sales.<\/li>\n<li><strong>Manager risk.<\/strong> The quality of analysis and monitoring depends on the team that structures and oversees each deal.<\/li>\n<\/ul>\n<h2>Frequently asked questions<\/h2>\n<h3>What is a non-bank financial institution?<\/h3>\n<p>An entity that finances the economy or invests savings without being a bank or taking deposits: funds, insurers, private debt managers or lending platforms, among others.<\/p>\n<h3>Are non-banks regulated?<\/h3>\n<p>Many are, but under rules different from banks. Depending on their activity, they are supervised in Spain by the CNMV, the Directorate-General for Insurance and Pension Funds or Banco de Espa\u00f1a. The current debate is whether a macroprudential framework is needed for the sector as a whole.<\/p>\n<h3>Is &#8220;shadow banking&#8221; the same as alternative lending?<\/h3>\n<p>Not exactly. &#8220;Shadow banking&#8221; is a colloquial and often imprecise phrase. Alternative lending is the part of non-bank activity that lends to companies or projects, such as private debt secured on property.<\/p>\n<h3>Does the ECB speech affect my private debt investment?<\/h3>\n<p>Not directly: it is not a rule. But it signals where European regulation may go and is a reminder of which risks to check before investing.<\/p>\n<h3>What should I ask before investing with a non-bank?<\/h3>\n<p>How and when you get your money back, whether the vehicle is leveraged, what collateral backs each loan, what information you will receive and what fees you pay.<\/p>\n<h2>In summary<\/h2>\n<ul>\n<li>Non-bank financial institutions lend and invest without being banks; in the euro area their share of credit has grown sharply in recent years.<\/li>\n<li>On 5 November 2026, Isabel Schnabel (ECB) called for tougher rules for them because of their effect on monetary policy and financial stability.<\/li>\n<li>Supervisors watch liquidity, leverage, opacity and interconnection; these are the same questions an investor should ask.<\/li>\n<li>In Spain, alternative lending still accounts for 20% of the total and fills gaps left by banks.<\/li>\n<li>All investments carry risks, including the loss of capital.<\/li>\n<\/ul>\n<p>If you would like to know how we invest, <strong><a href=\"https:\/\/www.ondara.group\/en\/investors\/\">register as an investor<\/a><\/strong> and we will explain how it works. The minimum investment is EUR 25,000.<\/p>\n<p><em>This article is for information purposes only and does not constitute an investment recommendation or financial advice. All investments carry risks, including the possible loss of the capital invested, and past or target returns do not guarantee future returns. Analyse each opportunity with a professional before investing.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Non-bank financial institutions: what the ECB called for in November 2026, what supervisors monitor and what to ask before investing in private debt in Spain.<\/p>\n","protected":false},"author":1,"featured_media":5239,"comment_status":"","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[20,22],"tags":[],"class_list":["post-5246","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-inversiones-alterativas","category-private-credit"],"_links":{"self":[{"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/posts\/5246","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/comments?post=5246"}],"version-history":[{"count":0,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/posts\/5246\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/media\/5239"}],"wp:attachment":[{"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/media?parent=5246"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/categories?post=5246"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.ondara.group\/en\/wp-json\/wp\/v2\/tags?post=5246"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}