Consultation on Forum Incorporation and Development

transferring the domain into a LTD would also be a transfer of data - prohibited without data subject consent and subject to fine of up to £20m. Not sure if that is per user   

I'm going to generalise here as I don't know the actual CTR (click through rates) or advertising revenue, but typically the CTR is 0.5% and the advertising revenue around £1. It is possible for this to be several times higher or lower, but that is my experience of online advertising.  It may well be double this figure as ultimately it is page views will determine revenue rather than visitors, but the CTR is likely to be less.

This should be a high CPC vertical, but the forum doesn't really feel like it will be high-CTR as-is. People generally come here to find information about loans or something specific about a platform they're already invested in -- an ad is not going to be able to suggest an answer to those questions people want answering.

The money is from people coming here looking to (a) find out about P2P generally and (b) find new places for their money. They're the ones who will be keen to click on the big ticket ads. Optimising for ad revenue usually starts with the right content that escalates a users intent and the value of their clicks. This site doesn't really do that nor does it get many unique views which means it might be better suited to re-targeted (rather than contextual) ads since the audience is likely to be older and/or wealthier than average. But then GDPR becomes more of a hassle with externally called re-targeted advertising and you'd need consent before even making the ad call (i.e before the page loads under normal circumstances).

AFC CTRs can be double-digits for well designed sites, it would never be that high on a forum like this but swaying content to be more general and the kind of place people find from their Google search (rather than from a bookmark / the domain) would be a good place to start. It's mostly a game in escalation for new visitors (very long-tail Google search -> forum page a bit relevant -> exit to some high CPC finance ad).

dandy it is only €20 million so £17 million.

GDPR is crazy! Data portability anyone? I checked the slide to see if it was dated 1st April.

My thoughts are

1. Incorporation: This has pros and cons. This is a logical and positive step for the volunteers who mod the forum. It's hard to quantify the probability of a platform or borrowers going after the volunteers. Some argue it's high, others that it's overstated. That misses the point to me. The probability is above zero so the reality is there is some financial risk in being a mod, but the reward of being a mod is zero, so the risk-reward is shocking. So why would anyone do that? The downside, is that incorporation provides the platforms/borrowers with a discrete and clearcut target. So while it protect the volunteers, it will likely increase the probability of attack. So the lifetime of the P2PIF may well be reduced. 

2. Funding: I'm happy to remove the ad-blocker. I can do a donation. I don't see any real issue with a ring fenced referrals page. I'd try to avoid funding from specific platforms as this could be considered to violate the independence of the site. I'm deeply skeptical that mods would alter their view on a platform based on say £1k of funding. Given, however, that one platform tried to argue this was a price comparison site (is there something in the Leeds water?) then perhaps better to exhaust other avenues first.

3. KYC. Simply no. There is absolutely no way I would go through the loss of privacy and the rigmarole of identity checks for a forum. The only forums where I would consider that are private forums, typically associated with something that already requires KYC (the TC private forum is an example). I've never had to do that for a public forum and I wouldn't make an exception for the P2PIF. I might be ok with the current mods knowing who I am but in the future who would have that info? The somewhat bizarre offer of an unknown faceless Admin on the Frank forum to buy the P2PIF via an offshore entity is an example. It could be perfectly benign but who would know? Against that the reward of being able to post here is marginal. I would lose nothing really from being read-only since I don't even have access to the DD forum.

From my perspective, however, this sort of misses the real problem. For two years the forum's signal to noise ratio has been falling and, if anything, that is accelerating. I'm not sure the above changes would alter that to any significant degree. When this forum started it was about investment, now is seems more consumer/retail/"populist". Serious debate about actual investment is fairly rare and often receives abuse or is trolled. The DD forum, as far as I can tell from others who have access, is almost just one person doing DD. Note this is not a vote for the "Frank" alternative! That seems like it's going nowhere fast based on it's current lack of traction.

The staff are in a dream world with this KYC idea


Initially I thought it was user-baiting to pay us back communally for the perceived 'admin-baiting' they have mention of in the rules...

Stop circumventing the swear filter!

PS While I agree with what you say, under that legislation, could the forum not argue that it has a right to keep the data incase of legal action on the basis of what you wrote?