treeman
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Post by treeman on Mar 26, 2017 9:31:30 GMT
Another MT lender here, who would really appreciate some sort of bed & ISA facility for the safe transfer of my current loans into an IFISA, rather than trying to beat the bots on the SM. Even be quite happy to pay the platform a (small ) admin fee for the privilege. I don't think FSA rules allow this - you have to sell on an open market and buy back Wonder whether this kind of transfer could be possible with loan renewals ?
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elliotn
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Post by elliotn on Mar 26, 2017 10:23:57 GMT
I don't think FSA rules allow this - you have to sell on an open market and buy back Wonder whether this kind of transfer could be possible with loan renewals ? My guess would be you'd have to release your non-IFISA loan parts back to the pot and then re-bid on the open market with your IFISA option, so then at risk of losing or reducing your current investment.
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littonowl
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Post by littonowl on Mar 26, 2017 10:44:23 GMT
Another MT lender here, who would really appreciate some sort of bed & ISA facility for the safe transfer of my current loans into an IFISA, rather than trying to beat the bots on the SM. Even be quite happy to pay the platform a (small ) admin fee for the privilege. I don't think FSA rules allow this - you have to sell on an open market and buy back Not certain, but understood Abundance allowed the transfer of previously held non ISA debentures into IFISA's, without the need for releasing onto their bulletin board? I only started using Abu after their IFISA was launched, but maybe a longer-term Abu user can confirm?
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treeman
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Post by treeman on Mar 26, 2017 11:54:57 GMT
Wonder whether this kind of transfer could be possible with loan renewals ? My guess would be you'd have to release your non-IFISA loan parts back to the pot and then re-bid on the open market with your IFISA option, so then at risk of losing or reducing your current investment. Yeah, that's why it occured to me; because at renewal time your investment is technically released back into the pot - you get a Capital Repayment of the loan which is ending - then you get auto-allocated an investment in the 'new' loan ............ possibly could be able to choose to 'opt-in' to re-invest in your other (IFISA) account ?
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stevio
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Post by stevio on Mar 26, 2017 12:21:29 GMT
My guess would be you'd have to release your non-IFISA loan parts back to the pot and then re-bid on the open market with your IFISA option, so then at risk of losing or reducing your current investment. Yeah, that's why it occured to me; because at renewal time your investment is technically released back into the pot - you get a Capital Repayment of the loan which is ending - then you get auto-allocated an investment in the 'new' loan ............ possibly could be able to choose to 'opt-in' to re-invest in your other (IFISA) account ? If that was possible, they would be able to move all your investments, not just renewals
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nush
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Post by nush on Mar 26, 2017 12:25:42 GMT
My guess would be you'd have to release your non-IFISA loan parts back to the pot and then re-bid on the open market with your IFISA option, so then at risk of losing or reducing your current investment. Yeah, that's why it occured to me; because at renewal time your investment is technically released back into the pot - you get a Capital Repayment of the loan which is ending - then you get auto-allocated an investment in the 'new' loan ............ possibly could be able to choose to 'opt-in' to re-invest in your other (IFISA) account ? i wish they had but sadly they didnt, im not sure but i also think they made it difficult to buy off of yourself.
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mikeh
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Post by mikeh on Mar 26, 2017 12:33:46 GMT
Yeah, that's why it occured to me; because at renewal time your investment is technically released back into the pot - you get a Capital Repayment of the loan which is ending - then you get auto-allocated an investment in the 'new' loan ............ possibly could be able to choose to 'opt-in' to re-invest in your other (IFISA) account ? If that was possible, they would be able to move all your investments, not just renewals I think there is a difference. Technically the original loan is being redeemed. I don't see a problem with requesting the transfer of that money into an ISA account to be invested in the new loan. There is no trading involved.
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ilmoro
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'Wondering which of the bu***rs to blame, and watching for pigs on the wing.' - Pink Floyd
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Post by ilmoro on Mar 26, 2017 12:38:27 GMT
Here's the specific section from the Guidance for managers
9A.8 Peer-to-peer loans held outside of the ISA wrapper cannot be sold, and repurchased inside an innovative finance ISA except where the loans are sold and are made available for purchase (using cash held by the ISA manager), at the same price, by any lender in the open market. That is, the loans must be available for purchase by more than one prospective purchaser. It will not therefore usually be open to a platform to purchase a lender’s portfolio of loans and for the proceeds to be used to reacquire the same loans inside the ISA wrapper. Any purchase would need to be of loans made openly available to any prospective lender.
ISTM rollovers would not be transferable as they would not be 'available for purchase by more than one prospective purchaser' even if it is effectively a new loan as that part of the loan is never made available on the open market.
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mason
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Post by mason on Mar 26, 2017 12:47:24 GMT
I'm interested hear other's views, but it seems like no minimum length of time is specified for the loan parts to be made available on the SM before they can be repurchased. MT would need to seek guidance, but an automated service utilising the existing SM might be permissible.
Gather together everyone's bed & ISA requests, dump them all on the SM at the same unspecified moment, and some fractions of a second later process the purchases. Perhaps one or two might be lost to the bots, but I'd be willing to take that risk.
Or pair us up so we can trade with one another.
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mikeh
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Post by mikeh on Mar 26, 2017 13:11:09 GMT
Here's the specific section from the Guidance for managers 9A.8 Peer-to-peer loans held outside of the ISA wrapper cannot be sold, and repurchased inside an innovative finance ISA except where the loans are sold and are made available for purchase (using cash held by the ISA manager), at the same price, by any lender in the open market. That is, the loans must be available for purchase by more than one prospective purchaser. It will not therefore usually be open to a platform to purchase a lender’s portfolio of loans and for the proceeds to be used to reacquire the same loans inside the ISA wrapper. Any purchase would need to be of loans made openly available to any prospective lender.ISTM rollovers would not be transferable as they would not be 'available for purchase by more than one prospective purchaser' even if it is effectively a new loan as that part of the loan is never made available on the open market. I see it rather differently. 9A.8 clearly refers to trading. ie SM activity. Redemption and subscription are PM activities and as I see it no loan exists between redemption of the old loan and drawdown of the new one. (subject to appropriate small print of course). So I don't see how 9A.8 applies.
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stevio
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Post by stevio on Mar 26, 2017 13:24:55 GMT
I think the comments on this thread are asking a lot of MT, effectively asking them to jeopardize their approval on unproven technicalities and asking them to assist in either by passing or bending the rules
They don't write the guidance and then are perfectly happy for people to find ways round it - its there for a reason
We have become used to MT trying to meet customers demands when they can, but IMHO, whilst I too would like this to be the case, I can't see MT or any other IFISA supplier doing this, no matter how much you would like it to happen or scrutinize things to the enth degree
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mason
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Post by mason on Mar 26, 2017 13:32:47 GMT
I think the comments on this thread are asking a lot of MT, effectively asking them to jeopardize their approval on unproven technicalities and asking them to assist in either by passing or bending the rules They don't write the guidance and then are perfectly happy for people to find ways round it - its there for a reason We have become used to MT trying to meet customers demands when they can, but IMHO, whilst I too would like this to be the case, I can't see MT or any other IFISA supplier doing this, no matter how much you would like it to happen or scrutinize things to the enth degree I don't think anyone here wants or expects them to do anything that would not be permissible by the FCA. The only way to understand the limits of what is possible is to scrutinise the rules. I would not expect MT to do anything without seeking advice through the proper channels.
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ben
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Post by ben on Mar 26, 2017 14:03:50 GMT
Personally I think MT should make no efferts to put the current loans into an ISA. These loans are funded and even if was not agasint the rules, which I think some of the ideas on here are either agasint the rules or very near to be to have MT having to answer some questions. It will aslo cost them time and effert, admin etc and they may need a change to the terms and conditions.
MT need to use the ISA to attract new investors/money (obviously they also need to attract more borrorowers), if all they use it is to rehouse the current money on the platform it will not benefit a MT themselfs.
If you look at sites that have released an ISA the majority of them have either lowered rates since or are charging a fee. So for people like me an ISA on MT would not be a good thing as I probably will not use it but will have to accept the lower rates.
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ilmoro
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Post by ilmoro on Mar 26, 2017 14:15:49 GMT
Here's the specific section from the Guidance for managers 9A.8 Peer-to-peer loans held outside of the ISA wrapper cannot be sold, and repurchased inside an innovative finance ISA except where the loans are sold and are made available for purchase (using cash held by the ISA manager), at the same price, by any lender in the open market. That is, the loans must be available for purchase by more than one prospective purchaser. It will not therefore usually be open to a platform to purchase a lender’s portfolio of loans and for the proceeds to be used to reacquire the same loans inside the ISA wrapper. Any purchase would need to be of loans made openly available to any prospective lender.ISTM rollovers would not be transferable as they would not be 'available for purchase by more than one prospective purchaser' even if it is effectively a new loan as that part of the loan is never made available on the open market. I see it rather differently. 9A.8 clearly refers to trading. ie SM activity. Redemption and subscription are PM activities and as I see it no loan exists between redemption of the old loan and drawdown of the new one. (subject to appropriate small print of course). So I don't see how 9A.8 applies. The question of course is how HMRC see it. Recently people who think they have found clever ways to get round tax rules have been getting their figures burnt.
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SteveT
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Post by SteveT on Mar 26, 2017 14:16:23 GMT
I'm interested hear other's views, but it seems like no minimum length of time is specified for the loan parts to be made available on the SM before they can be repurchased. MT would need to seek guidance, but an automated service utilising the existing SM might be permissible. Gather together everyone's bed & ISA requests, dump them all on the SM at the same unspecified moment, and some fractions of a second later process the purchases. Perhaps one or two might be lost to the bots, but I'd be willing to take that risk. Or pair us up so we can trade with one another. In reality, it is not hard to sell a loan-part in one MT account and re-buy it in another, provided that you've both account windows open at the same loan and enter your buy instruction quickly. I've done it on quite a few occasions, for one reason or another, and have yet to lose anything to the mythical "bots".
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