In a case when the customer acts as the creditor or the creditor, on the conclusion of loan agreements, the credit the Law N 223-FL doesn't extend.
The Ministry of Economic Development explained that loan agreements, the documents and data confirming obligation fulfillment under such agreements it is necessary to place in a unified information system. We believe, department meant those contracts which customers sign under the Law N 223-FL.
Document: Letter of the Ministry of Economic Development of the Russian Federation of 30.03.2016 N D28i-773