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Post by chris on Sept 20, 2014 10:17:19 GMT
westcountryfunder - The FCA are explicit that they mean funds physically received by the client money account. Confirmation of that a debit card transaction is guaranteed to go through is not enough, they require the transaction to show on the bank statement as received funds.
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Post by chris on Sept 20, 2014 10:19:41 GMT
I've done my bank transfer to cover W. London Prop. It will arrive in the client account Monday, then my account Tuesday, as will a lot of funds called in by AC's email Friday pm. As I see it, you cannot allow drawdown before Tuesday, when all those funds are actually in our "available to invest" accounts. The FCA rule don't require the funds to show in the system (well I think there's a 10 day rule), it's about when they're received in the CMA. If all funds are deposited in the CMA by Monday then the loan can be drawn down even though they don't show on the automatic import until the next day.
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Post by chris on Sept 20, 2014 10:26:22 GMT
Clearly AC knows this: what needs to be sharpened up is that day's delay. If we can get funds into the client account in around two hours or less by "faster payment", automatic allocation to our lending account should be equally fast (or even run every half hour, or quicker), not left until the next day. The client account bank should be capable of facilitating this. Why doesn't it? Until the beginning of this week the bank were telling us they couldn't facilitate this. They've now come back with a solution but have yet to let us know the costs involved. We have the option of changing bank to another that does have a solution, albeit one that costs several thousand pounds per month. We have the option of integrating directly into SWIFT, at a cost of £100+k per annum albeit with discounts able to be negotiated.
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Post by westcountryfunder on Sept 20, 2014 10:26:40 GMT
westcountryfunder - The FCA are explicit that they mean funds physically received by the client money account. Confirmation of that a debit card transaction is guaranteed to go through is not enough, they require the transaction to show on the bank statement as received funds. f that's the case then they need to be challenged to justify their policy. It is difficult to avoid the conclusion that the new brooms at the FCA are working with an excess of zeal, or maybe a lack of basic understanding.
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Post by chris on Sept 20, 2014 10:32:56 GMT
westcountryfunder - The FCA are explicit that they mean funds physically received by the client money account. Confirmation of that a debit card transaction is guaranteed to go through is not enough, they require the transaction to show on the bank statement as received funds. f that's the case then they need to be challenged to justify their policy. It is difficult to avoid the conclusion that the new brooms at the FCA are working with an excess of zeal, or maybe a lack of basic understanding. Our view is that they're thinking that there are edge case scenarios where even if a debit card is confirmed as being settled in 3 days time, for example, that this does not 100% guarantee the funds will be received. In a bankruptcy for example the transactions can be frozen in transit. But we're beyond the limits of my understanding of the regulations and the reasoning here. I get a nice summary of what work needs to be done in order to be compliant.
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oldgrumpy
Member of DD Central
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Post by oldgrumpy on Sept 20, 2014 10:48:22 GMT
I consider having a shadow bidding facility is a privilege which I try not to abuse. Most times an email calls in the bids a few days before drawdown actually occurs. I think up to a week is reasonable, as we are all trying to minimise "dormant money", and the shadow induced reduction from over two months (in some cases) to a few days is fine by me. Just once I was phoned (no email), so I presume drawdown had arrived very suddenly, and I transferred funds immediately as a result. Can't now. Now, those "emergency" phone calls are of no use whatever, because if AC phones me on a Friday morning when a drawdown is suddenly expected Friday afternoon (or even on Saturday), there is no way of me transferring cash which becomes available until the following Tuesday. Anyway, I think shadow bidding is going to be a much reduced activity now that most loans don't fill and underwritten units are available in profusion on the SM. Just a few small loans will attract shadow bids, to make sure a holding is secured. How about giving Chris the rest of his weekend off? Poor chap - taking flak on a Saturday. Banana time  |
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Post by bracknellboy on Sept 20, 2014 11:03:38 GMT
I signed up for shadow bids a few weks ago. The first I knew that you wanted the cash was when I scrolled down my account page and found a message (don't you send emails?) And you asked me to send cash to settle a shadow bid where the loan hasn't even filled yet. I thought the whoe idea was not to tie cas up on potentially unsuccesful loan requests (or is it this the FCA cleared funds regulation scuppering the shadow bid concept ?) Ignore the stuff on your account which says you have the following shadow bids which need settling. Its spurious.
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Post by batchoy on Sept 20, 2014 11:35:44 GMT
chris: Unless you have some info to back up your statement, you may wish to retract your comment about savingstream being in breach of the new rules. Especially as you seem to explain in your next paragraph how a platform with sufficient working capital could operate such a scheme within the rules. Perhaps what AC need is a loan to cover their working capital needs!  Or some cooperative underwriters. I should have been explicit that I was referring to Saving Stream's solution in the context of implementing it for our site. Yes it could be made to work if you have deep pockets. At our current size we'd need around £1m set aside that we could shuffle in part between our bank account and the client money account each day for us to implement their style of system. If that money didn't need to be sat in our account then it would be easy for us to cover, but that's not our interpretation of the regulations. The money has to be physically cleared into the CMA before it can be used on the platform. With the wider changes coming with the new platform that doesn't make as much sense for us. Savings Stream is a bad example because it is not a like for like comparison. With AC you are buying shares in a third party loan managed by AC and with SS you are lending to SS and SS are assigning part of asset they own (part of a loan they have already lent out). Whilst AC is a P2P lending platform, SS is lender seeking crowdfunding for is businesses.
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Post by Ton ⓉⓞⓃ on Sept 20, 2014 12:14:54 GMT
I signed up for shadow bids a few weks ago. The first I knew that you wanted the cash was when I scrolled down my account page and found a message (don't you send emails?) And you asked me to send cash to settle a shadow bid where the loan hasn't even filled yet. I thought the whoe idea was not to tie cas up on potentially unsuccesful loan requests (or is it this the FCA cleared funds regulation scuppering the shadow bid concept ?) I got caught by that same thing, I think everyone does when they first get the shad-bid facility. If I understand what you're saying, just ignore the blue button that demands, "Settle Now" Only start to settle when the email requesting it comes thru'. IN EDIT AFAIK those blue "Settle Now" buttons are waiting for the oft talked about & much fabled, 'NEW SYSTEM'. I think when it comes into full operation the New System will automatically tell you when to settle your Shad-bids. So just ignore them for NOW but be aware of the changes to come. But some think shad-bids maybe going altogether...
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pikestaff
Member of DD Central
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Post by pikestaff on Sept 20, 2014 15:39:48 GMT
I consider having a shadow bidding facility is a privilege which I try not to abuse. Most times an email calls in the bids a few days before drawdown actually occurs. I think up to a week is reasonable, as we are all trying to minimise "dormant money", and the shadow induced reduction from over two months (in some cases) to a few days is fine by me. Just once I was phoned (no email), so I presume drawdown had arrived very suddenly, and I transferred funds immediately as a result. Can't now. Now, those "emergency" phone calls are of no use whatever, because if AC phones me on a Friday morning when a drawdown is suddenly expected Friday afternoon (or even on Saturday), there is no way of me transferring cash which becomes available until the following Tuesday. Anyway, I think shadow bidding is going to be a much reduced activity now that most loans don't fill and underwritten units are available in profusion on the SM. Just a few small loans will attract shadow bids, to make sure a holding is secured. How about giving Chris the rest of his weekend off? Poor chap - taking flak on a Saturday. Banana time Couldn't agree more. Provided AC gives us enough notice (which may occasionally require saying no to borrowers who say they want it NOW), there is no problem. I've had 2 last minute phone calls out of 6-8 loans where my shadow bid has been called. For the first I don't think I ever got an email. The second was 2 hours after an email had been sent, and 15 minutes after I'd seen the email and settled.
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j
Member of DD Central
Penguins are very misunderstood!
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Post by j on Sept 20, 2014 16:38:59 GMT
Two issues with all of this:
1.If something crops up on AM whereby I have no AI mandate setup & I fancy it there & then, but no spare cash sitting idle in AC account, I will probably lose out if it's not one of the common AM loans always available & units will be snapped up by those who have the spare capacity or deeper pockets.
2.If I do have AI mandates setup with some spare cash in AC account, one or more loans that require shadow bids settling in the interim. A dilemma here as I have a choice of switching off AIs, which could be many, each time I have a shadow bid settlement nearing (laborious) or risk it. I could see how easily it could be - £500 in account for shadow bid to settle, AI buys £300 worth of loans, £200 shortfall & problems with AC ensue, even if I had cash available to transfer & cover deficit but no more instant transfer.
The whole thing, not AC's fault in any way, is going to have an impact on shadow bid usage & overall liquidity on the platforms with both live loans & AM transactions. What a $%^&*" bunch the FCA are.
How are other platforms going to or have tackled the issue? Do we know?
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mikes1531
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Post by mikes1531 on Sept 20, 2014 18:25:10 GMT
If something crops up on AM whereby I have no AI mandate setup & I fancy it there & then, but no spare cash sitting idle in AC account, I will probably lose out if it's not one of the common AM loans always available & units will be snapped up by those who have the spare capacity or deeper pockets. Even if you do have an AI mandate set up, if there's no spare money in your account you'll probably lose out. And deep pockets don't help because those folks still can't get cleared funds into the CMA instantly. So for now, lenders who want to be able to take advantage of Aftermarket offerings will have to leave idle funds in their account, diluting their actual return. Hobson's choice!
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unmadem
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Post by unmadem on Sept 20, 2014 18:48:14 GMT
So for now, lenders who want to be able to take advantage of Aftermarket offerings will have to leave idle funds in their account, diluting their actual return. Now that is irritating.
EDIT - quote was actually by mikes1531 and not J.
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mikes1531
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Post by mikes1531 on Sept 21, 2014 2:02:34 GMT
So for now, lenders who want to be able to take advantage of Aftermarket offerings will have to leave idle funds in their account, diluting their actual return. Now that is irritating. Almost as irritating as seeing my words put into j's mouth!
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spockie
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Post by spockie on Sept 21, 2014 7:30:51 GMT
Almost as irritating as seeing my words put into j's mouth! Penguins are very misunderstood...
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Or some cooperative underwriters.
