APP rejected for 3. 2.1 Business: Other Business Model Issues - Acceptable

So what does your app actually do?

My app provides regular financial products (eg. bonds or private equity) issued by financial institutions instead of loans. Our company holds financial license runing the business (already uploaded in recent app submission) via http://gs.amac.org.cn/amac-infodisc/res/pof/manager/101000013483.html. Since we are running loan business, we can't provide the materials required.

Hope you can help me out.

My app provides regular financial products (eg. bonds ).

Since we are running loan business, we can't provide the materials required.

I wonder if there isn't a problem with the rejection form and the rejection reason using the wrong boiler plate text.

In the review guidelines, 3.2.1 is: "Apps used for financial trading, investing, or money management should come from the financial institution performing such services or must use a public API offered by the institution in compliance with its Terms & Conditions."

A really, really common cause for 3.2.1 rejections is the developer account not being registered to the business (in this case, the financial institution) as a business developer account. Are you registered properly? If you aren't, that could be why you're getting the repeated rejection.

Disclaimer: All of the search results I see for "Internet Loan Information Agency" point towards regulations for a country I don't reside in.

App Review rejected your app for "financial trading" as per the guidleine they referenced. You are welcome to ask them to correct their error in writing "loan application".

Thanks for your timely response. Actually, my company is a financial institution with legal business license and financial permit from Chinese government. But review team kept asking for proofs for "Internet Loan Information Agency" which I don't have. If they put my app in a correct catergory, I am happy to provide those materials.

Thanks! The real problem is that they did not listen to me. I asked them to make the corretion several times but every time they replied with the same message asking me to provide the materials list for "loan application". If we are treated as financial inistitution instead of internet loan, I think the materials should be different. Take this-"Business License that verifies the authorization from the Internet Loan Information Agency" for example, If we don't have loan bussiness, how can I provide the proof.

Is there any other way to talk to app review team?

You wrote:

>My app provides regular financial products (eg. bonds ).

App Review cited 3.2.1 in their rejection. You seem to be focused on their use of the term "loan application" - you are welcome to point out to App Review that your app does not provide loan applications but rather "regular financial products". But I hope you realize that your app may appear to be violating 3.2.1 as per App Reviews comments but with "loan application" replaced with "financial trading, investing, or money management". Here's an obvious suggestion:

Respond to App Review as if they had written:

"Guideline 3.2.1 - Business - Other Business Model Issues - Acceptable

We found that your app facilitates loan applications, financial trading, investing, or money management, but the seller and company names associated with your app do not reflect the financial institution in the app or its metadata, as required by Guideline 3.2.1(viii) of the App Store Review Guidelines.

Next Steps

To help us proceed with the review of your app, please provide the following information. The more information you can provide upfront, the sooner we can complete your review.

1. Both a copy and the direct link to the government website of your Business License that verifies the authorization from the Internet Loan Information Agency

2. Both a copy and the direct link to the government website of your Finance Permit issued from the local finance governing authority

3. A copy of the Value Added Telecom Business Operation Permit issued by the local Ministry of Information Industry and Technology

4. Your app’s and service’s Terms & Conditions.

5. In the case of dispute, what resolution mechanism does your app and service offer?

6. What is your responsibility in such case? Is such responsibility stated clearly in the Terms & Conditions?

7. How will the involved parties trace one another?

8. License numbers for the Business License, Finance Permit, and Value Added Telecom Permit in the Review Notes section.

Additionally, please ensure your app’s Support and Privacy URLs in the metadata direct users to the webpages with appropriate information.

Please attach documentary evidence in the App Review Information section in iTunes Connect. In accordance with section 3.2(f) of the Apple Developer Program License Agreement, you acknowledge that submitting falsified or fraudulent documentation can result in the termination of your Apple Developer Program account and the removal of your apps from the App Store. Once Legal has reviewed your documentation and confirms its validity, we will proceed with the review of your app."

Hi, PBK,

I had already re-subimitted all the materials as you suggested but review team rejected the app again without pointing out which rule we break. They just repeatedly replied with the same message you just post. I am wondering if they read the explanation and materials?

I put the answer to the questions and attachment in Note/Remark section under App review information. Is it correct?

Hi MarkWei,

I have the same rejection reason to you.

May I ask if your App is finally on the shelf? How to solve this problem? Thank you very much

App Review reply message as follow:

Guideline 3.2.1 - Business - Other Business Model Issues - Acceptable

The seller and company names associated with your app do not reflect the financial institute name, as required by Guideline 3.2.1(viii) of the App Store Review Guidelines.

Next Steps

Your app must be published under a seller name and company name that reflects the financial institution name. If you have developed this app on behalf of a client, please advise your client to add you to the development team of their Apple Developer account.

Please note that submitting documentation showing permission to publish this app on behalf of the financial institution will not resolve this issue. This app must be submitted under the financial institution’s own Apple Developer account.

Once created, you cannot change your seller name or company name in App Store Connect. For assistance with changing your company name or seller name, you will need to contact us. Select Membership and Account to request an update to your Apple Developer account information.