We provided legal support to Google regarding a notification from the Superintendence of Banking, Insurance and Pension Funds Managers (SBS) requesting the suspension to grant access to the general public, in connection with some mobile applications that are available in the Google Play Store. Such Apps were allegedly money lending applications, which (according to the official communication), have been reported to the SBS by users due to: (i) loans they did not request; or (ii) when requesting them, being threat by means of extortion methods to renew or payments.
We provided a fully assessment of the applicable banking regulation and the possible consequences in the scenario that Google does not comply with the SBS requirement. Also, we provided legal accompanying to the client when they met with the SBS explaining the particularities of the participation of Google in relation of the mobile apps questioned. We also provided a legal strategy on the approach to the authority and how solve its queries.
