Nera Capital
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Thomas della Peruta,
Thomas, listen to me carefully. Your chat is complex and well-detailed. You’d do well to submit it as a complaint. That way you’ll have an official response to possibly contest and legal records. That’s my advice as a mistreated investor.
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Detailed questions that are completely viable and in fact should be asked by the Bank of Latvia to Mintos as the principal supervisory authority. At least it is worthwile to send this to them as a concerned investor. Mintos probably lacks the courage to answer these questions and will come up with an argument like interfering with the process might lead to negative effects in the reclaiming of the investments.Excuses we heared many times before.
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Ugo,
What do you suggest doing? How can we protect ourselves? Let's do it all together!0 -
This is an email I sent to complaints@mintos.com
Subject: FORMAL COMPLIANCE INQUIRY: Nera Capital Funding 2 DAC Exposure & Risk Mitigation Review (Investor ID: [Insert Your Mintos ID Here])Dear Mintos Investor Support / Compliance Team,I am writing as an active investor with direct financial exposure to the notes issued via NERA CAPITAL FUNDING 2 DESIGNATED ACTIVITY COMPANY (DAC), which are currently flagged as "Negotiating" and classified under "In Recovery" status on your platform.My specific exposure to Nera Capital Funding 2 DAC amounts to €1,581.13 out of my €12,098.69 total account value, representing exactly 13.06% of my entire active portfolio on Mintos. Given that these notes have a stated maturity date extending to 2028, this high concentration level and prolonged asset freeze directly and severely impact my personal capital allocation, liquidity, and overall risk mitigation strategy on your platform.I am formally requesting explicit clarification regarding the severe structural disconnect between Nera Capital's public corporate updates—which highlight new fund milestones and institutional asset expansion—and the ongoing default on retail investor cash flows on Mintos.As a licensed investment firm regulated by the Bank of Latvia (Latvijas Banka) under the EU MiFID II framework, Mintos owes its clients a strict statutory duty to act honestly, fairly, and professionally. In light of this, please provide substantive, compliance-level answers to the following operational and legal points:- Ring-Fencing and Cross-Collateralization of Irish DAC Structures: Has Mintos legally analyzed whether the capital structures of Nera Capital’s newly announced alternative funds are ring-fenced from the legacy special purpose vehicle—specifically Nera Capital Funding 2 DAC—backing my Mintos Notes? Is there any enforceable legal mechanism, corporate guarantee, or inter-creditor agreement that allows capital from these new milestones to be deployed to cure the defaults on this specific DAC?
- Adherence to Mintos Risk Disclosure (Version 6, 03.03.2025): Your disclosure notes under 'Risks specific to Notes' that recovery costs take priority over retail investor distributions. I formally demand an itemized disclosure of all recovery costs, legal fees, or administrative deductions currently being charged against the Nera Capital Funding 2 DAC pool by Mintos or its agents. Furthermore, under the 'Intermediary Risk' clause, please provide evidence of the pre-issuance and ongoing cross-border due diligence Mintos performed on the ~80 UK law firm intermediaries prior to freezing my €1,581.13.
- Independent Verification of SRA Impact: Mintos has previously stated that the default stems from a voluntary payment halt by UK law firms undergoing a Solicitors Regulation Authority (SRA) solvency review. What independent legal audit or direct verification has Mintos obtained to confirm that these funds are genuinely paused for compliance reasons, rather than masking a material insolvency event at the borrower level? Relying solely on the borrower’s unverified representations fails the standard of care required of an EU-licensed investment firm.
- Transparency on "Negotiating" Status and Restructuring Terms: In light of the heavily delayed restructuring term sheets, what is the exact progress of the active negotiations? When will Mintos transition from generic platform updates to a full disclosure of the economic terms, proposed recovery timelines, or potential haircuts? Investors require hard data to independently evaluate the commercial viability of the recovery plan for notes maturing in 2028.
As an investor managing a 13.06% exposure to this specific counterparty, I require transparent documentation to evaluate my portfolio’s risk. Please escalate this inquiry to your Legal and Compliance departments. I look forward to a comprehensive response detailing the exact legal protections and recovery frameworks currently being enforced.Sincerely,[Your Full Name]
Mintos Investor ID: [Insert Your Mintos ID Here]
Email Address: [Your Registered Email Address]0 -
For anyone who was unable to join the Discord group for Mintos investors affected by Nera Capital / Nera Notes, here is a new invite link: https://discord.gg/TJkmfSzkc
The link will remain valid for 30 days from the date of posting.0 -
Eleftherfos,
A fine letter. Thanks for sharing it with us. Unfortunately, I am much, much more exposed than you are.
I agree. Regards.0 -
Kas ta tas i štuka eur, baigais support hubs, kuru pat neviens neapskatās no Mintos. Protams, ka nera nav pienācīgi izvērtēts un kā gluma zivs spirināsies tagad. Info atjauninājumos mēnešiem ir vienāds teksts, tā kā nedaudz ir jābūt cieņai pret investoriem un tekstu nevar copy paste likt to pašu. Ja nav nekā, ieraksta nav jauna info. Nevis mēneša beigās būs kaut kāds figļi migļi un nākošā mēnesī copy paste. Baigā jēga būt top investoram ar bezmaz 100k/eur saldējumu uz nera. Nrviens , izskatās nav pārbaudījis Nera spēju atmaksāt aizdevumus, kas dokumentos ir norādīts, ka ir darīts - značit nepilnvērtīgi. Jau mēnesis pagājis, citos ziņu update ir x3, bet septembrī pēkšņi vairs nav jauna info pat ne 2x. Vēl nera tur bīda kaut ko ar čaulas izmaiņām kā brūnais kailgliemezis, varbūt mēģina nolekt no saistībām mazie zaglēni. Par šo viņi jau ir parādā investoriem papildus procentus, neviens netaisījās tiem suslikiem neko dāvināt.
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SADALNE,
Write in English. We are unable to translate.0 -
It’s a bitter pill to swallow. We trusted Mintos as the best European platform in terms of experience and reliability, only to end up in this Nera disaster—a company that swallowed up our savings and continues to operate blithely on other platforms. Yet, I don't believe the fault lies solely with us. What about the due diligence—both before and during the process? I invest across ten platforms, and it is only with Mintos that I’ve encountered these issues. It’s not just Nera; there was also the EDS bond default and, to top it off, the Air Baltic bonds that ended up in Chapter 11. I hold three defaulted securities, with over €100,000 frozen and no idea what will become of it all. I’ve lost my peace of mind0 -
Write to the Bank of Latvia, just as others have done, to get someone to stand up for you!
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sorry, I was pretty busy, did anyone got a reply to the concept letter by @ Eleftherfos Chatzipantelis.
Mintos has started a new charming offensive with Edge, to make an appointment with your new and fresh accountmanager. I believe everyone should use that momentum to seriously complain about the situation with Nera and all the other problems that created a 185 million loss of investors money since 2017.
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Ugo, I absolutely agree. Read my post from yesterday. I am—or rather, we are—suffering a financial disaster withwith Nera Capital via Mintos, then with EDS bondsyet it’s as if nothing has happened. They’re even offering us a personal manager! I’ve written to the Bank of Latvia. You should do the same.0 -
Tomm1q can you share a new invite for the discord group?
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Heres official legal response to my letter cited above. As concluded they state that if dissatisfied with response I could escalate out-of-court to Bank of Latvia etc, obviously alluding they hold a strong legal position, they are covered which means it is meaningless to escalate: " To: ELEFTHERIOS CHATZIPANTELIS Mintos ID: 6634204
Email: ehatzip@gmail.com
From: AS Mintos Marketplace Skanstes Street 50, Riga, LV-1013, Latvia
Riga, refer to the date in the timestamp of the electronic signature Case reference: C_226_ID_6634204
Nomenclature No: LVMM/08-01-2026-172
Response to complaint sent to Mintos on 04.09.2026.
Dear Eleftherios,
AS Mintos Marketplace, registration No. 40103903643 (hereinafter – Mintos, or – we) have received your complaint dated 04.09.2026 (hereinafter – Complaint) in relation to your investment in Notes issued by SIA Mintos Finance No. 16 (hereinafter – the Issuer) with Nera Capital Funding 2 Designated Activity Company as Lending Company (hereinafter – Nera, and the Notes – Nera Capital Notes), and we have investigated it.
Your Notes were issued under the Base Prospectus of the Issuer dated 10.06.2024 (hereinafter – the Base Prospectus). References in this letter to Conditions are to the Terms and Conditions of the Notes set out in Section 10 of the Base Prospectus (hereinafter – the Conditions), which are distinct from the Mintos Terms and Conditions governing the use of the platform.
Your Complaint asks four questions: whether other funds managed or raised by Nera Capital are ring-fenced from Nera and whether any mechanism exists to apply them to Nera's obligations; the recovery costs and due diligence referred to in our risk disclosure; how the information about the SRA review has been verified; and the status of the restructuring. We address each below.
The maturity of your Notes
Your Complaint refers to Notes with a stated maturity extending to 2028. The 2028 date shown on the platform is the expected recovery horizon, not the maturity of the Notes. The original Maturity Date of each Set of Notes is stated in the applicable Final Terms. Under Condition 11.6, where any amounts on the Notes remain outstanding on the Maturity Date, the Maturity Date is automatically postponed until those amounts are paid. The Notes have therefore not reached their Maturity Date for the purposes of the Conditions, and have not been redeemed.
1. Separation of Nera's assets from other funds
Nera Capital's arrangement across its funders is to hold each funder's claim portfolio in a separate designated activity company. Nera Capital holds the claim proceeds and divides them by funder, so that each funder holds the claim portfolio it has funded. Nera holds only the loans funded through the Mintos Notes structure, as stated in our update of
This reply is prepared by AS Mintos Marketplace and is signed with an electronic signature. Validity of e-signature can be checked here: https://www.eparaksts.lv/en/
22.05.2026. The separation therefore works in both directions: the portfolio funded through your Notes is not available to other funders, and the capital of other funds is not part of the assets backing your Notes.
Your contractual claim is against the Issuer. Under Conditions 2.3 and 12.1 of the Base Prospectus, the Issuer's payment obligation is limited to the sums it actually receives in respect of the underlying loans. On support from the wider group: there is no Guarantor for these Notes and none is specified in the Final Terms. The Base Prospectus provides for a Guarantor where one is stated in the Final Terms for a given series, and for the series in which you hold Notes none is stated. There is therefore no corporate guarantee to enforce.
The remaining information requested under this point goes beyond what relates to your Complaint and your investments on the Mintos platform, and will not be provided.
2. Recovery costs and due diligence
You are right that our Disclosure of risks of investing in financial instruments states that investors will only receive payment after payment obligations of a higher priority, such as taxes or recovery costs, have been settled. This reflects the Priority of Payments in Condition 7 of the Base Prospectus, under which costs, including legal fees incurred in recovery and restructuring, are paid before amounts due to Noteholders. Under Condition 17.5, Mintos informs Noteholders of such costs before requesting their compensation, charges them only up to the amount recovered, and does not charge for its in-house staff or resources. The treatment of recovery and legal costs under the restructured arrangement is among the matters being documented in the agreements still to be signed.
The Intermediary risk section you refer to concerns companies involved in transferring funds from the borrowers and the lending company to Mintos. In this structure, the UK law firms are not intermediaries but the borrowers, and the Lending Company lends to a few, carefully selected law firms, as described in Section 8 of the Base Prospectus. The figure of approximately 80 law firms refers to the firms covered by the SRA review across the UK market, as stated in our update of 22.05.2026. The risks that have materialised are those described in the same section of the Disclosure: that if a borrower does not make a scheduled payment on time, the investor will also not receive a payment on time, and that the lending company could fail to honour its contractual obligations, including the buyback obligation.
On due diligence: the process applied to Nera Capital was the same process applied to the onboarding of other lending companies on the platform. Section 8 of the Base Prospectus describes the analysis of the borrowing law firms before cooperation begins, covering how they manage court cases, their financial standing and their compliance with regulatory requirements, and their continuous monitoring thereafter. The ongoing assessment of the Lending Company is reflected in the Mintos Risk Score, whose changes and the reasons for them are published on the Mintos Risk Score Updates page; for Nera Capital these included downgrades of the buyback strength subscore with effect from 10.01.2025 and 08.04.2025, and of the loan servicer efficiency subscore with effect from 10.10.2025. Beyond this and the information already available to investors, we are not in a position to disclose further details of the due diligence performed. Should Latvijas Banka request this information, Mintos will provide it.
3. Verification of the SRA review
Mintos is not a party to the SRA review, and SRA investigations are confidential and are not publicly disclosed by the SRA. We are therefore not in a position to confirm independently when it commenced, what its scope is, which firms it covers, or what stage it has reached. As stated in our update of 22.05.2026, we have been informed that the review concerns the solvency requirements of the law firms, and that the firms paused their payments while it proceeds.
What we are able to state is what Mintos knew and when. Scheduled payments from the borrowing law firms ceased in late March 2026. On 16.04.2026 we published an update stating that we were in contact with Nera Capital to clarify the situation regarding the temporary overdue funds. On 20.04.2026 Mintos was informed of the SRA review, given by
This reply is prepared by AS Mintos Marketplace and is signed with an electronic signature. Validity of e-signature can be checked here: https://www.eparaksts.lv/en/
the firms as the reason for the suspension of payments, and on 21.04.2026, the following day, we published the first information about the payment delay on the Overdue page, together with a notice on the Secondary Market page.
On being informed of the SRA review, Mintos engaged local solicitors specialising in SRA investigations, and they have been included in our correspondence on the matter since.
4. The status of the restructuring
The Consensual Restructuring Agreement has been signed, as confirmed in the update published on 02.09.2026, with other creditors following the same approach. A number of related transaction documents still need to be finalised and signed before the restructuring can be fully implemented. The timetable for those agreements has moved from the end of September indicated in that update; their signing is now planned for the end of October 2026. We give you that as the plan currently being worked to rather than as a commitment, and the restructuring legal counsel is pressing the law firms to finalise the information required.
The Consensual Restructuring Agreement does not require any consent, vote, approval or waiver from Noteholders. The restructuring was carried out at the level of the underlying assets, namely the Issuer's rights against Nera, and does not amend the Conditions. Once the remaining agreements have been signed, Mintos will inform investors of the terms of the Consensual Restructuring Agreement as they apply to Notes held on Mintos. Mintos has not assigned Defaulted status to Nera Capital, as a restructuring solution was reached within 180 days of the suspension.
On recovery expectations: the recovery figure displayed on the platform reflects the full nominal value of the receivables as preserved under the restructuring, which does not contemplate any write-down of principal. It is not a probability-weighted estimate and it is not a statement that full repayment is certain or likely. Actual recovery depends on the outcome of the underlying litigation, may be less than the nominal amount, and cannot be guaranteed. As disclosed in Section 2 of the Base Prospectus, the risk of partial or total loss of invested capital cannot be excluded. The 2028 horizon is based on the current litigation strategy, which includes grouped proceedings intended to process claims more efficiently than individual actions. On 30.06.2026 a UK court ruled on a procedural matter confirming that large groups of similar consumer claims may proceed collectively; a ruling specific to the grouping strategy for the claims in this portfolio remains pending. The horizon is an expectation based on the strategy currently being pursued, not a commitment to a date.
Conclusion
We have not identified a failure by Mintos to comply with its contractual or regulatory obligations in this matter. The portfolio backing your Notes is held separately from the portfolios of Nera Capital's other funders; recovery costs rank ahead of Noteholders as disclosed, subject to the limits in Condition 17.5; Mintos engaged solicitors specialising in SRA investigations on being informed of the review, and they have been involved in our correspondence on the matter since; and the terms of the restructuring will be communicated to all investors once the remaining agreements have been signed. We recognise that an exposure of this size, with no confirmed recovery date, is a significant matter for your portfolio, and Mintos will continue to pursue recovery on behalf of all affected investors, including you.
Please note that, under the terms of our Complaints policy, this is our final response.
If you are dissatisfied with it, you may refer your complaint to the following out-of-court dispute resolution services:
This reply is prepared by AS Mintos Marketplace and is signed with an electronic signature. Validity of e-signature can be checked here: https://www.eparaksts.lv/en/
If you're a consumer, you can refer a complaint in accordance with the provisions of the Consumer Rights Protection Law of the Republic of Latvia to the Consumer Rights Protection Centre, located in Brivibas Street 55, Riga, LV-1010, Latvia. If you believe Mintos violates applicable laws and regulations, you can refer your complaint to Latvijas Banka, the central bank of Latvia, by emailing info@bank.lv. If your complaint is in line with the rules of the Ombudsman of the Finance Association of Latvia, you may submit a complaint by sending it to their office at Doma laukums 8A, Riga, LV-1050, Latvia. Yours sincerely,
AS Mintos Marketplace
Elmārs Ciganovics
Investor Service Lead
This reply is prepared by AS Mintos Marketplace and is signed with an electronic signature. Validity of e-signature can be checked here: https://www.eparaksts.lv/en/
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Eleftherfos,
A response not very different from the one I received. The Bank of Latvia, too, raised no objections.0
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