No. However, we note that there are only regulations of the State Bank of Vietnam (SBV) on syndicated loans of credit institutions that allow the appointment of a foreign lender among the syndicated lenders to handle the roles of lender, arranger and security agent. It is unclear if a foreign lender can play these agency roles if it is not a lender in the lending transaction. 

From a practical perspective, in relation to medium- and long-term offshore loans, since the identity of the facility agent and the security agent is described in the application for registration of the foreign loan with the SBV, it is arguable that if the foreign loan documentation has been examined and the foreign loan registration certificate recording the identity of the facility agent and the security agent has been issued by the SBV, the SBV is deemed to consent to the proposed foreign agency arrangement.

No; however, there is a requirement for the borrower to deduct withholding tax (currently set at 5%) from the amount of interest and fees payable to the lender under the finance documents (see the answer to question 5 of the "When lending to borrowers" section).

Foreign lenders are not required to report their transactions in Vietnam. However, credit institutions that provide account services for payments in relation to offshore loans are subject to a specific statistical reporting regime under the regulations of the SBV.

No. 

Yes, if the approach is on a limited basis, i.e., made one-to-one and not to the public. This is because a general approach to potential customers in Vietnam for offering loans could be regarded as "advertising," which may only be provided by licensed advertising agencies in Vietnam.