blender
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Post by blender on Nov 19, 2019 22:49:54 GMT
May I suggest you move to Assetz quickly and take the appropriateness test.
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macq
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Post by macq on Nov 20, 2019 8:17:59 GMT
at the end of the day which ever One you pick on any platform,will in the future if anything goes wrong probably carry about as much weight as a 12 year old ticking the i am 18 box on iplayer to watch peaky blinders
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Post by RateSetter on Nov 20, 2019 10:17:03 GMT
Of course, the FCA has defined what a sophisticated investor is for a long time. The issue is not this, the issue is that ratesetter has a very loose interpretation of a sophisticated investor to include anybody who has invested in p2p in the last two years and requires anybody who wants to certify as 'restricted' that they don't have more than 10% of their net assets in p2p. This is crazy as it means that the very person who the legislation was meant to protect will not be eligible to declare that they are restricted. Good morning. We’d like to clear up any confusion on this. The definition of a self-certified sophisticated P2P investor has been provided by the FCA. For anyone who would like the full technical detail: The FCA has inserted a new provision into the existing COBS 4.7.9 rule which modifies the declarations for certified High Net Worth investors, certified sophisticated investors and self-certified sophisticated investors. COBS 4 can be found here. The new provision will be COBS 4.7.9(2)(b) and it replaces references to ‘unlisted company’ with ‘P2P agreement or P2P portfolio’. COBS 4.7.9(2)(b) says: “ in the statement in COBS 4.12.8R, the reference to “unlisted company” must be replaced with a reference to “P2P agreement or P2P portfolio”;” Therefore point (b) in the declaration for self-certified sophisticated investors in the context of P2P is as follows: “ I have made more than one investment in a P2P agreement or P2P portfolio in the two years prior to the date below”. The new provision - COBS 4.7.9(2)(b) - is set out on page 62 of the FCA’s Policy Statement PS19/14 (the document which sets out all the regulatory changes for the P2P sector) which can be found here.
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cb25
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Post by cb25 on Nov 20, 2019 10:55:18 GMT
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pom
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Post by pom on Nov 20, 2019 11:01:57 GMT
There are three separate issues here: 1) Can the 10% investment limit be enforceable give that a) people may not not what their net wealth is, b) people may wrongly declare that their investments in p2p are under 10% of net wealth and c) there seems to be no way for the platform either to know what somebodies net wealth is or what somebodies p2p investments on other platforms are. Therefore the test will always be a self declaration thing and liable to easy circumvention. My opinion: probably not but better than nothing. One would hope that platforms will at least have some sort of sanity check whereby if someone has declared themselves a restricted investor they are limited to £24,999.99 and if they go over that are then asked "are you now HNW? If not you clearly have more than 10% invested"....but with lots of platforms around that still gives "restricted" investors a lot of scope to get into trouble... What would perhaps be helpful is if for restricted investors their dashboard clearly stated "you currently have £x invested with us. As a restricted investor this implies your net wealth is >10x, or more if you invest in other p2p platforms. Under FCA guidelines please consider reducing your investment if this is not the case" Yeah I can really see it happening....its not really in platforms interests to police it!
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pip
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Post by pip on Nov 20, 2019 11:17:57 GMT
Of course, the FCA has defined what a sophisticated investor is for a long time. The issue is not this, the issue is that ratesetter has a very loose interpretation of a sophisticated investor to include anybody who has invested in p2p in the last two years and requires anybody who wants to certify as 'restricted' that they don't have more than 10% of their net assets in p2p. This is crazy as it means that the very person who the legislation was meant to protect will not be eligible to declare that they are restricted. Good morning. We’d like to clear up any confusion on this. The definition of a self-certified sophisticated P2P investor has been provided by the FCA. For anyone who would like the full technical detail: The FCA has inserted a new provision into the existing COBS 4.7.9 rule which modifies the declarations for certified High Net Worth investors, certified sophisticated investors and self-certified sophisticated investors. COBS 4 can be found here. The new provision will be COBS 4.7.9(2)(b) and it replaces references to ‘unlisted company’ with ‘P2P agreement or P2P portfolio’. COBS 4.7.9(2)(b) says: “ in the statement in COBS 4.12.8R, the reference to “unlisted company” must be replaced with a reference to “P2P agreement or P2P portfolio”;” Therefore point (b) in the declaration for self-certified sophisticated investors in the context of P2P is as follows: “ I have made more than one investment in a P2P agreement or P2P portfolio in the two years prior to the date below”. The new provision - COBS 4.7.9(2)(b) - is set out on page 62 of the FCA’s Policy Statement PS19/14 (the document which sets out all the regulatory changes for the P2P sector) which can be found here. Thanks for this, it's not an approach I agree with but I understand you are hamstrung by the wisdom of the FCA. To me using the terms 'sophisticated', 'restricted' etc. are totally misleading and not useful, but I blame the FCA for this, I have no real idea what these terms mean. Maybe some sort of quiz or scenario questions would be much better e.g. 'if a platform fails, most of the loans you thought were secured turns out not to be, all the funds frozen, the ring-fencing you thought your funds had up in smoke and the FCA wipes their hands of it, will you feel comfortable having lost 50% of your life savings' (slight tongue in cheek but based on FS a pretty valid question!). I still have a fundamental problem with the Ratesetter questions in that it requires somebody to confirm that they have less than 10% of their assets in p2p investments to certify as restricted. I see that the FCA handbook only requires restricted investors to certify that they will not invest more than 10% of their assets in p2p. P2P sites are supposed to risk assess customers based on their self-assessment answers. Huge question mark for me is how therefore should I answer the question if I have more than 10% of assets in p2p, but don't feel I am sophisticated. I am forced to not answer 'restricted' but I could be the very type of person that these rules were meant to help.
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aju
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Post by aju on Nov 20, 2019 11:29:40 GMT
Good morning. We’d like to clear up any confusion on this. The definition of a self-certified sophisticated P2P investor has been provided by the FCA. For anyone who would like the full technical detail: The FCA has inserted a new provision into the existing COBS 4.7.9 rule which modifies the declarations for certified High Net Worth investors, certified sophisticated investors and self-certified sophisticated investors. COBS 4 can be found here. The new provision will be COBS 4.7.9(2)(b) and it replaces references to ‘unlisted company’ with ‘P2P agreement or P2P portfolio’. COBS 4.7.9(2)(b) says: “ in the statement in COBS 4.12.8R, the reference to “unlisted company” must be replaced with a reference to “P2P agreement or P2P portfolio”;” Therefore point (b) in the declaration for self-certified sophisticated investors in the context of P2P is as follows: “ I have made more than one investment in a P2P agreement or P2P portfolio in the two years prior to the date below”. The new provision - COBS 4.7.9(2)(b) - is set out on page 62 of the FCA’s Policy Statement PS19/14 (the document which sets out all the regulatory changes for the P2P sector) which can be found here. Thanks for this, it's not an approach I agree with but I understand you are hamstrung by the wisdom of the FCA. To me using the terms 'sophisticated', 'restricted' etc. are totally misleading and not useful, but I blame the FCA for this, I have no real idea what these terms mean. Maybe some sort of quiz or scenario questions would be much better e.g. 'if a platform fails, most of the loans you thought were secured turns out not to be, all the funds frozen, the ring-fencing you thought your funds had up in smoke and the FCA wipes their hands of it, will you feel comfortable having lost 50% of your life savings' (slight tongue in cheek but based on FS a pretty valid question!). I still have a fundamental problem with the Ratesetter questions in that it requires somebody to confirm that they have less than 10% of their assets in p2p investments to certify as restricted. I see that the FCA handbook only requires restricted investors to certify that they will not invest more than 10% of their assets in p2p. P2P sites are supposed to risk assess customers based on their self-assessment answers. Huge question mark for me is how therefore should I answer the question if I have more than 10% of assets in p2p, but don't feel I am sophisticated. I am forced to not answer 'restricted' but I could be the very type of person that these rules were meant to help. Good question, especially as I cannot find a way at present to change the option I selected should I subsequently feel it is incorrect as it seems to have disappeared from the accounts section that it was on a few days ago. If I had a bad memory I would not now know what I am considered by RS towers. Perhaps RateSetter knows where the options have been moved to.
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aju
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Post by aju on Nov 20, 2019 12:36:08 GMT
Perhaps RateSetter knows where the options have been moved to. - you can see the options by logging into your account, clicking on "Account Settings" at the top of the screen and then clicking the pencil icon next to "Classification". , I've tried it now in 4 browsers and no I don;t get the classification text on any of the options and definitely no pen. Perhaps you need to check something has not changed as I can't see it at all anymore
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Post by erniec on Nov 20, 2019 12:37:26 GMT
Yes, no sign of that for me either:  |
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aju
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Post by aju on Nov 20, 2019 12:39:45 GMT
Yes, no sign of that for me either: You beat me to it, it was there on the 15th and I used it on both our accounts to check nothing had changed from when we actually made our options. Having read some of the other threads I wondered if RS had made some changes as a result of FCA recent changes and they haven't actually reinstate the option correctly
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Post by RateSetter on Nov 20, 2019 12:45:22 GMT
, I've tried it now in 4 browsers and no I don;t get the classification text on any of the options and definitely no pen. Perhaps you need to check something has not changed as I can't see it at all anymore Please accept my apologies, the post earlier was incorrect and it has been removed. The functionality we mentioned to view the options will be live in the member area in the next few days and we will post an update on this thread. Thank you.
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macq
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Post by macq on Nov 20, 2019 13:28:19 GMT
Well that's not very sophisticated  |
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Post by bernythedolt on Nov 20, 2019 15:27:48 GMT
Ratesetter ticked the "When tinkering with the user interface, we will invest no more than 10% of our total effort" box...  |
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robski
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Post by robski on Nov 20, 2019 16:13:06 GMT
Good morning. We’d like to clear up any confusion on this. The definition of a self-certified sophisticated P2P investor has been provided by the FCA. For anyone who would like the full technical detail: The FCA has inserted a new provision into the existing COBS 4.7.9 rule which modifies the declarations for certified High Net Worth investors, certified sophisticated investors and self-certified sophisticated investors. COBS 4 can be found here. The new provision will be COBS 4.7.9(2)(b) and it replaces references to ‘unlisted company’ with ‘P2P agreement or P2P portfolio’. COBS 4.7.9(2)(b) says: “ in the statement in COBS 4.12.8R, the reference to “unlisted company” must be replaced with a reference to “P2P agreement or P2P portfolio”;” Therefore point (b) in the declaration for self-certified sophisticated investors in the context of P2P is as follows: “ I have made more than one investment in a P2P agreement or P2P portfolio in the two years prior to the date below”. The new provision - COBS 4.7.9(2)(b) - is set out on page 62 of the FCA’s Policy Statement PS19/14 (the document which sets out all the regulatory changes for the P2P sector) which can be found here. Thanks for this, it's not an approach I agree with but I understand you are hamstrung by the wisdom of the FCA. To me using the terms 'sophisticated', 'restricted' etc. are totally misleading and not useful, but I blame the FCA for this, I have no real idea what these terms mean. Maybe some sort of quiz or scenario questions would be much better e.g. 'if a platform fails, most of the loans you thought were secured turns out not to be, all the funds frozen, the ring-fencing you thought your funds had up in smoke and the FCA wipes their hands of it, will you feel comfortable having lost 50% of your life savings' (slight tongue in cheek but based on FS a pretty valid question!). I still have a fundamental problem with the Ratesetter questions in that it requires somebody to confirm that they have less than 10% of their assets in p2p investments to certify as restricted. I see that the FCA handbook only requires restricted investors to certify that they will not invest more than 10% of their assets in p2p. P2P sites are supposed to risk assess customers based on their self-assessment answers. Huge question mark for me is how therefore should I answer the question if I have more than 10% of assets in p2p, but don't feel I am sophisticated. I am forced to not answer 'restricted' but I could be the very type of person that these rules were meant to help. The problem I feel with anything like this is people will ignore it. Interest only mortgages, S&S, P2P, not declaring car mods, not taking out travel insurance etc etc The general public are nothing but consistent in taking irrational decisions no matter how hard people try to stop them
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macq
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Post by macq on Nov 20, 2019 16:58:09 GMT
Ratesetter ticked the "When tinkering with the user interface, we will invest no more than 10% of our total effort" box... perhaps they could not see the pencil
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