Article 2(1), point (a), of Regulation {EU) 2020/1503 (hereinafter, 'ECSPR') defines a 'crowdfunding service' as "the matching of business funding interests of investors and project owners through the use of a crowdfunding platform and which consists of any of the following activities:
(i) the facilitation of granting of loans;
(ii) the placing without a firm commitment basis, as referred to in Annex I, Section A, point (7), of Directive 2014/65/EU, of transferable securities and admitted instruments for crowdfunding purposes issued by project owners or a special purpose vehicle, and the reception and transmission of client orders, as referred to in point (1) of that Section, in relation to those transferable securities and admitted instruments for crowdfunding purposes.
Article 2(1), point (c), of the ECSPR defines 'individual portfolio management of loans' as "the allocation by the crowdfunding service provider of a pre-determined amount of funds of an investor, which is an original lender, to one or multiple crowdfunding projects on its crowdfunding platform in accordance with an individual mandate given by the investor on a discretionary investor-by-investor basis".
We would appreciate clarification as to the legal nature of the activity of individual portfolio management of loans. We would specifically appreciate if the European Commission could confirm that it should be considered as forming part of the notion of crowdfunding service and, if yes, that it should be regarded as ancillary to the activity of facilitation of granting loans referred to in Article 2(1), point (a )(i).

According to Article 2(1), point (I) of Regulation {EU) 2020/1503 {hereinafter, 'ECSPR'), a crowdfunding project means "the business activity or activities for which a project owner seeks funding through the crowdfunding offer".
We would appreciate clarification on how the phrase "business activity or activities" should be interpreted in the context of the ECSPR.
More specifically, we would welcome confirmation that this provision does not prevent per se:
(i) public law entities or other non-profit entities from acting as project owners for the purposes of the ECSPR, or
(ii) to seek funding for projects related to public infrastructure, utilities and other types of projects involving the provisions of public sector services.

According to Article 48(1) ECSPR, "crowdfunding service providers may continue in accordance with the applicable national law to provide crowdfunding services that are included within the scope of this Regulation until 10 November 2022 or until they are granted an authorisation referred to in Article 12, whichever is sooner" (emphasis added).
We would appreciate clarification on the meaning of "in accordance with the applicable national law" generally, and specifically whether the transitional period will apply in the following cases:
(i) no national law specifically governing crowdfunding activities exists. However, national law provides that crowdfunding services can be performed by investment firms authorised under Directive 2014/65/EU of the European Parliament and of the Council
(ii) no national law specifically governing crowdfunding activities exist s. However, national law provides that crowdfunding activity requires neither authorisation nor a licence.

What are possible indications of an illiquid or indivisible asset, for the purpose of the application of the ECSPR?

What type of underlying asset can an SPV give exposure to?