archie
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Post by archie on Apr 26, 2017 13:24:18 GMT
Regarding time for reviewing documents and commercial sensitivity, as it requires a login, it should be possible to have 2 stages in the loan going live. At stage 1 everything except bidding would be enabled, lasting for a few hours or 24h to allow for review of documents and comments. Then stage 2, at a preset time bidding becomes enabled. Would that work? I cannot see any reason why the documents couldn't have gone online when the email was sent. Bidding buttons could be disabled until the launch time.
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Post by ladywhitenap on Apr 27, 2017 11:34:24 GMT
Magenta's post virtually echos my own thoughts that I was just about to post.
I'd like to add that the max allocation during the initial period should be at least 2% of the loan. On another platform we have recently had a limit set of 0.2% on a 100k loan in the first 24hrs following a famine there of new loans - this seems to be "fairness" going to extremes and not only excludes the BHs but the "MHs" too.
LW
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madpierre
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Post by madpierre on Apr 27, 2017 11:59:43 GMT
If ABL policy is FFF then I can live with it and have the choice whether to get involved in the frenzy or not, but I just want to know precisely what I'm FFFing for
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metoo
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Post by metoo on Apr 27, 2017 12:14:36 GMT
Magenta's post virtually echos my own thoughts that I was just about to post. I'd like to add that the max allocation during the initial period should be at least 2% of the loan. On another platform we have recently had a limit set of 0.2% on a 100k loan in the first 24hrs following a famine there of new loans - this seems to be "fairness" going to extremes and not only excludes the BHs but the "MHs" too. LW If the initial period is fairly short, say 1 - 2 hours, then the only consequence of a bid limit is that if enough people want the loan it will all be gone. eg a limit of 0.5% allows at least 200 people to have a bite. Much as we would each like a big slice of small loans, it may be binary: max bid limit or nothing at all. The lack of a limit excludes all but a few when the loan is small. If the bid limit is known, the right amount of funds can be in place ready to bid. Realistically for diversification it is reasonable to lend a small sum on a small loan. If that's too little for big or medium fish to bother with, they will have large sums on larger loans. The bigger the loan, the less of a restriction a bid limit places. The other platform you mention has brought out a bigger loan now which will allow all to get invested with decent amounts.
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blender
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Post by blender on Apr 27, 2017 12:18:13 GMT
If ABL policy is FFF then I can live with it and have the choice whether to get involved in the frenzy or not, but I just want to know precisely what I'm FFFing for Yes this is the real issue. Ablrate also need to be sure that you have had a good opportunity to find out what you are FFFing for. There could be regulatory implications if the platform does not facilitate that. So that concern is clearly shared by all and I am sure Ablrate will fix it. The 'fairness' issue is separate and lesser, but valid. The two issues need unbundling, imo.
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iren
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Post by iren on Apr 27, 2017 13:38:22 GMT
Yes. It's certainly non compliant to provide a warning that documents must be read before making a decision, while simultaneously providing a system that does not allow this to take place.
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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 Apr 27, 2017 13:57:22 GMT
Yes. It's certainly non compliant to provide a warning that documents must be read before making a decision, while simultaneously providing a system that does not allow this to take place. Is that strictly speaking true? Ablrate does provide the opportunity for investors to read the docs. It isnt Ablrate that tells investors to ignore the warning and engage in a mad stampede and tick the box to say they have read the docs when they havent. How compliant are autobid system where the lender definitely hasnt read the docs, or operates bots that buy any E loan on FC within nano seconds? Ablrate have acknowledge the issue and are taking steps to find a solution. That said doubt it will be a solition to the madness of crowds.
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iren
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Post by iren on Apr 27, 2017 14:07:14 GMT
I worked for many years as a Compliance Officer in financial services until 2014, and am still pretty au fait with developments. "Strictly speaking" is not a term you would use in discussion with the FCA, as regulation is primarily based on principles and outcomes rather than rules.
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ozboy
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Post by ozboy on Apr 27, 2017 14:19:59 GMT
I worked for many years as a Compliance Officer in financial services until 2014, and am still pretty au fait with developments. "Strictly speaking" is not a term you would use in discussion with the FCA, as regulation is primarily based on principles and outcomes rather than rules. So you're one of "them" iren?!! ........... or was. I'm a bit thick, can you elaborate on " regulation is primarily based on principles and outcomes rather than rules" please? Honestly, I don't understand what that means?
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ilmoro
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Post by ilmoro on Apr 27, 2017 14:34:15 GMT
I worked for many years as a Compliance Officer in financial services until 2014, and am still pretty au fait with developments. "Strictly speaking" is not a term you would use in discussion with the FCA, as regulation is primarily based on principles and outcomes rather than rules. So you're one of "them" iren?!! ........... or was. I'm a bit thick, can you elaborate on " regulation is primarily based on principles and outcomes rather than rules" please? Honestly, I don't understand what that means? FCA makes it up as it goes along!. If the regulations produce the wrong outcomes they change the rules and then youre in trouble for breaching the regulations
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ozboy
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Post by ozboy on Apr 27, 2017 14:36:13 GMT
Ahhhhh, I get it, "Catch 22"!!!!!
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iren
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Post by iren on Apr 27, 2017 15:26:02 GMT
So you're one of "them" iren?!! ........... or was. I'm a bit thick, can you elaborate on " regulation is primarily based on principles and outcomes rather than rules" please? Honestly, I don't understand what that means? FCA makes it up as it goes along!. If the regulations produce the wrong outcomes they change the rules and then youre in trouble for breaching the regulations Yes, FS companies do have to factor in as a risk that a negative investment outcome may result in prior decisions/practices being called into question as potentially non compliant. It means everything has to be watertight, or in P2P this will mean platform risk. In practice, the lack of a genuine opportunity to review documentation before an investment decision is made may be treated the same as the old insurance salesman who sold you an unsuitable product and told you you'd need to sign for it now, without a chance to go through the small print, if you wanted to get your money working, as they had to be away for another appointment.
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blender
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Post by blender on Apr 27, 2017 15:38:17 GMT
Let's not overdo it. In this case the secondary market helps, because those who bought without reading will have the opportunity to read post-bid, and if they do not like it they can sell it on the SM, probably without loss. Some philanthropic lenders may help out. Still needs fixing.
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