rscal
Posts: 911
Likes: 500
|
Post by rscal on Dec 21, 2023 19:25:35 GMT
By 70 percent from last year ... on the 'High Net Worth Investor' rule (specifically the rule that SoMo uses)? I ask b/c whereas 4th Way's review from last September (and presumed current when published) states Not anymore however. Today (21 December) the same condition quoted by SoMo' is: And there is now a different set of criteria for being a self-certified 'sophisticated' investor: So no longer simply "Invested in more than one unlisted company in the past two years (such as through crowdfunding websites)" This may now be correct, but then when did it come in and why didn't 4th Way seem to know about it unless it is even more recent (as I suspect) . a SEVENTY percent increase in the requirements! |
|
ilmoro
Member of DD Central
'Wondering which of the bu***rs to blame, and watching for pigs on the wing.' - Pink Floyd
Posts: 10,852 
Likes: 11,079
|
Post by ilmoro on Dec 21, 2023 19:55:59 GMT
By 70 percent from last year ... on the 'High Net Worth Investor' rule (specifically the rule that SoMo uses)? I ask b/c whereas 4th Way's review from last September (and presumed current when published) states Not anymore however. Today (21 December) the same condition quoted by SoMo' is: And there is now a different set of criteria for being a self-certified 'sophisticated' investor: So no longer simply "Invested in more than one unlisted company in the past two years (such as through crowdfunding websites)" This may now be correct, but then when did it come in and why didn't 4th Way seem to know about it unless it is even more recent (as I suspect) . a SEVENTY percent increase in the requirements! Comes in at end of Jan. Actually comes from the government assets.publishing.service.gov.uk/media/65491981bdb7ef000d4af915/Consultation_response_document_-_updates_to_financial_promotion_exemptions.pdf
|
|
rscal
Posts: 911
Likes: 500
|
Post by rscal on Dec 21, 2023 20:50:11 GMT
Just to update: SoMo seems to have granted me 'a certificate' when I select 'none of the above' for 'self-certified sophisticated' (I'm in for another period. So that's 'all right' then)
Tush, tush. The Government had not changed the thresholds since 2001 so 70% is just inflation catch-up!
|
|
Greenwood2
Member of DD Central
Posts: 4,245
Likes: 2,688
|
Post by Greenwood2 on Dec 21, 2023 20:53:33 GMT
I assumed it was rule changes, not just SOMO being difficult.
|
|
Greenwood2
Member of DD Central
Posts: 4,245
Likes: 2,688
|
Post by Greenwood2 on Dec 22, 2023 10:50:00 GMT
Just to update: SoMo seems to have granted me 'a certificate' when I select 'none of the above' for 'self-certified sophisticated' ( I'm in for another period. So that's 'all right' then) Tush, tush. The Government had not changed the thresholds since 2001 so 70% is just inflation catch-up! If the new rules come in in January, Somo may ask again then...
|
|
rscal
Posts: 911
Likes: 500
|
Post by rscal on Dec 22, 2023 12:45:18 GMT
Just to update: SoMo seems to have granted me 'a certificate' when I select 'none of the above' for 'self-certified sophisticated' ( I'm in for another period. So that's 'all right' then) Tush, tush. The Government had not changed the thresholds since 2001 so 70% is just inflation catch-up! If the new rules come in in January, Somo may ask again then... Here's what they have relayed to me this morning:
|
|
Greenwood2
Member of DD Central
Posts: 4,245
Likes: 2,688
|
Post by Greenwood2 on Dec 22, 2023 12:52:27 GMT
If the new rules come in in January, Somo may ask again then... Here's what they have relayed to me this morning: So only new investors are likely to be impacted. Good to know.
|
|
|
|
Post by Ace on Dec 23, 2023 10:51:35 GMT
If the new rules come in in January, Somo may ask again then... Here's what they have relayed to me this morning: I couldn't find anything in the document linked by ilmoro above that would allow them to certify you based on your previous questionnaire. It's also not clear to me that being "able to navigate the site as before" includes being able to invest in new loans. It seems, from para 4.4, that they can follow-up on promotions that they first made before 31st Jan 2024 for up to another year. However, it seems that they won't be able to promote any new investments to non-certified members after that date. The old definition of being sophisticated if you had made more than 1 unlisted investment previously was clearly bonkers, but removing that without a more sensible definition is equally bonkers. It effectively means that only rich people can invest in P2P in future. This has the potential to ruin many decent platforms. It will be very interesting to hear how other platforms address this. As I read it, the average investor will no longer be able to bung a tenner in the likes of a very low risk platform like Loanpad, but will still be able to put their whole wealth in a single listed share! It seems that the regulators have decided to effectively kill the industry rather than bothering to regulate it. I really hope that I've got the wrong end of the stick.
|
|
benaj
Member of DD Central
Posts: 4,862
Likes: 1,592
|
Post by benaj on Dec 23, 2023 10:57:23 GMT
I am not aware all platforms follow the same rules. Earlier this year, I re-certified myself on LendInvest by buying small shares on Seedrs, just 2 shares from 2 companies, unlisted investments? They accepted it.
|
|
|
|
Post by Ace on Dec 23, 2023 11:17:00 GMT
I am not aware all platforms follow the same rules. Earlier this year, I re-certified myself on LendInvest by buying small shares on Seedrs, just 2 shares from 2 companies, unlisted investments? They accepted it. That rule, of being able to self-certify if you've invested in more than 1 unlisted investment, is being removed on 31st Jan 2024. See the linked document above.
|
|
benaj
Member of DD Central
Posts: 4,862
Likes: 1,592
|
Post by benaj on Dec 23, 2023 11:38:45 GMT
We probably have to find out how these rules are being implemented next year.
There was one company asking for HNW evidence before I started lending FS, Lendy and etc. They asked for too many documents and questions and I couldn’t passed it.
|
|
ilmoro
Member of DD Central
'Wondering which of the bu***rs to blame, and watching for pigs on the wing.' - Pink Floyd
Posts: 10,852
Likes: 11,079
|
Post by ilmoro on Dec 23, 2023 12:14:50 GMT
Here's what they have relayed to me this morning: I couldn't find anything in the document linked by ilmoro above that would allow them to certify you based on your previous questionnaire. It's also not clear to me that being "able to navigate the site as before" includes being able to invest in new loans. It seems, from para 4.4, that they can follow-up on promotions that they first made before 31st Jan 2024 for up to another year. However, it seems that they won't be able to promote any new investments to non-certified members after that date. The old definition of being sophisticated if you had made more than 1 unlisted investment previously was clearly bonkers, but removing that without a more sensible definition is equally bonkers. It effectively means that only rich people can invest in P2P in future. This has the potential to ruin many decent platforms. It will be very interesting to hear how other platforms address this. As I read it, the average investor will no longer be able to bung a tenner in the likes of a very low risk platform like Loanpad, but will still be able to put their whole wealth in a single listed share! It seems that the regulators have decided to effectively kill the industry rather than bothering to regulate it. I really hope that I've got the wrong end of the stick. I did find some coverage of the changes which indicated that SOMOs approach was allowed (don't have it to hand). It will also I think depend on the type of investment with regulated P2P possibly being less rigourous than unregulated lending like SOMO. I haven't been able to dig around in FCA handbook for clarity as yet. FCA have only just implemented their own rule changes, consumer duty etc, more tweaks due in Feb, so picture is very contradictory currently.
|
|
Greenwood2
Member of DD Central
Posts: 4,245
Likes: 2,688
|
Post by Greenwood2 on Dec 23, 2023 13:23:26 GMT
It does seem to be pretty explicit:
'New financial promotions made from 31 January 2024, even if made to individuals already promoted to under the current exemptions, will need to be made in accordance with the updated exemptions.'
I was hoping there would be some sort of Grandfather rights, but can't see anything like that.
|
|
|
|
Post by williamg on Dec 23, 2023 14:26:47 GMT
It does seem to be pretty explicit: 'New financial promotions made from 31 January 2024, even if made to individuals already promoted to under the current exemptions, will need to be made in accordance with the updated exemptions.' I was hoping there would be some sort of Grandfather rights, but can't see anything like that. I would be interested in a precise definition of what comprises 'net assets' - I had planned to move some funds out of P2P to an Octopus Inheritance ISA which I would guess this would diminish what might be counted as my 'net assets'. I have no doubt the FCA are determined to stamp out the P2P industry altogether, which will greatly hurt the economy, especially the housing sector if they are allowed to get away with it. The industry has had a painful shake-out of most of the bad boys, no thanks to FCA. FCA threats (or do they call them consultations?) have already bounced some high quality platforms to move to institutional funding only. I deeply regret that Archover (which I rated highly) has recently ceased to accept private funding, and there are others.
|
|
Greenwood2
Member of DD Central
Posts: 4,245
Likes: 2,688
|
Post by Greenwood2 on Dec 23, 2023 15:43:58 GMT
It does seem to be pretty explicit: 'New financial promotions made from 31 January 2024, even if made to individuals already promoted to under the current exemptions, will need to be made in accordance with the updated exemptions.' I was hoping there would be some sort of Grandfather rights, but can't see anything like that. I would be interested in a precise definition of what comprises 'net assets' - I had planned to move some funds out of P2P to an Octopus Inheritance ISA which I would guess this would diminish what might be counted as my 'net assets'. I have no doubt the FCA are determined to stamp out the P2P industry altogether, which will greatly hurt the economy, especially the housing sector if they are allowed to get away with it. The industry has had a painful shake-out of most of the bad boys, no thanks to FCA. FCA threats (or do they call them consultations?) have already bounced some high quality platforms to move to institutional funding only. I deeply regret that Archover (which I rated highly) has recently ceased to accept private funding, and there are others.
I thought it was just the value of your primary residence and pension pot that you can't include in your assets. No expert though.
|
|
