What a mortgage credit intermediary is and how to check they are registered

What an ICI does in practice

In a mortgage purchase, an ICI typically does the following:

• Analyse your profile (income, debts, savings, type of property).
• Compare policies across multiple lenders (not just a single offer).
• Prepare documentation for mortgage applications and property valuations.
• Explain the FEIN, FiAE and, where applicable, coordinate the notary transparency record (acta notarial) required by law.
• Negotiate terms within the limits permitted by each bank.

The term 'mortgage broker' is what many people search for on Google; however, the official register refers to a mortgage credit intermediary. What matters is the registration number, not marketing jargon.

Why registration matters

Law 5/2019 subjects ICIs to strict rules regarding information disclosure, advertising, conflicts of interest and registration. Supervision and registration fall under the Banco de España or the relevant autonomous community, depending on the intermediary's scope of operation.

Operating without registration or failing to identify oneself correctly exposes consumers to opaque practices (hidden fees, unexplained tied products, pressure to sign). Verifying registration is the essential first filter for building trust.

How to verify registration

1. Access the mortgage credit intermediaries search portal on the Banco de España website (official register).
2. Locate the exact registered business name and the registration code provided by the firm.
3. Check that their scope of activity covers your transaction (purchase, transfer, debt consolidation, etc.).
4. Request written confirmation of who pays the fees (you, the bank, or a combination of both) before proceeding.

If the intermediary does not provide their registration number or the registered name does not match, stop there.

Mandatory pre-contractual information

The law mandates transparency before a credit contract is signed. You must receive clear, understandable information on:

• The identity and registration details of the intermediary.
• Fees, commissions and who pays them.
• The number of lenders they work with and whether any exclusivity exists.
• Reflection periods and document delivery deadlines (including the FEIN within legal timeframes where applicable).

The FEIN (European Standardised Information Sheet) outlines the essential terms of the loan. The FiAE provides additional required information specific to Spain. The acta notarial under Article 15 reinforces transparency prior to signing when required by law.

What an ICI is not

• They are not the entity granting the mortgage (the bank remains the lender).
• They do not replace the notary or the land registrar.
• They do not guarantee approval for the maximum loan amount on their own: this depends on each lender's credit scoring and policy.
• They must not impose insurance or linked products without explaining alternatives (the law restricts unfair cross-selling).

Sky Real Estate and ICI D-286

Sky Real Estate acts as a mortgage credit intermediary registered with the Banco de España under code D-286. The group's mortgage advisory service compares offers from numerous lenders for transactions across Spain, offering remote management as well as physical offices in Madrid, Valencia, Zaragoza and Mallorca if you prefer face-to-face assistance.

We are not the bank: we negotiate in your best interest within the parameters of each institution's policies. Any additional intermediary costs must be explained before you make a commitment, as required by Law 5/2019.

When it makes sense to use an ICI

It is usually worthwhile if:

• You want to compare multiple lenders using a single application file.
• Your profile is complex (self-employed, pre-existing debts, mortgage transfer/subrogation).
• You are purchasing under tight deadlines and need to coordinate valuation, formal offer and deposit agreements (arras).
• You wish to alter the terms of an existing mortgage or evaluate debt consolidation prudently.

In property sales, a buyer backed by an ICI can unblock the transaction without you, as the seller, having to handle someone else's mortgage application. For buyers, an ICI aligns actual borrowing capacity with the offer price.

Common mistakes

• Signing a preliminary deposit agreement (arras) without knowing whether financing is viable.
• Confusing an informal pre-approval with a formal loan offer.
• Accepting tied products (insurance, direct debits) without comparing total costs.
• Failing to verify registration simply because 'the estate agency recommended them'.

Related articles

To learn more about borrowing capacity, read how much mortgage you can get based on your salary. If you are self-employed, review what banks require from self-employed applicants.

To request an initial assessment, visit the mortgage credit intermediaries service from Sky Real Estate.