Kernrechtsfrage
Whether the cantonal decision violated the applicant's right to be heard by relying on grounds not expressly used by the first authority.
Extrahierter Entscheid
No. The refusal decision already relied on the statutory requirements of reliability and irreproachable activity, so the applicant could anticipate the grounds examined on appeal.
Extrahierte Begründung
The first-instance decision cited both the Consumer Credit Act and the ordinance, and expressly found that the applicant lacked a good reputation and guarantees of irreproachable activity, not only that he had a disqualifying conviction.