carolus
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Post by carolus on Jun 4, 2019 9:20:52 GMT
The FCA has announced new rules covering P2P lending. Platforms have until 9/12/2019 to implement these changes, except for the final bullet point which is immediate.
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carolus
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Post by carolus on Jun 4, 2019 9:46:12 GMT
Now fixed. Weirdly worked in preview but not in the actual post.
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hazellend
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Post by hazellend on Jun 4, 2019 9:54:08 GMT
What if you already have > 10% of assets in P2P.
Does that mean no more?
How do they account for spouses who are investing in the others account for tax efficiency?
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p2pmark
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Post by p2pmark on Jun 4, 2019 10:06:03 GMT
What if you already have > 10% of assets in P2P. Does that mean no more? From the full document: "Investors can re-classify as sophisticated investors (thereby removing the 10% investment limit) when they have more experience." 2Footnote 2: "Our rules allow for such investors to re-classify as sophisticated investors (removing the 10% investment limit) if they have made two or more P2P investments in the past two years." The cap seems to be applicable to new(ish) investors only. No idea how it will be enforced - maybe self-declaration.
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ilmoro
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Post by ilmoro on Jun 4, 2019 10:29:38 GMT
From the full document: "Investors can re-classify as sophisticated investors (thereby removing the 10% investment limit) when they have more experience." 2Footnote 2: "Our rules allow for such investors to re-classify as sophisticated investors (removing the 10% investment limit) if they have made two or more P2P investments in the past two years." The cap seems to be applicable to new(ish) investors only. No idea how it will be enforced - maybe self-declaration.
Sophisticated equals two investments in two years ? Jeez .... I have not read the document but I hope there's more to it than that ! 
You can't be seriously sophisticated if all you need to do is put a couple of minimum punts into a couple of minimum P2P offers.
Hopefully the rest of the broader regulations will make up for this omission !
Nothing new. Sophisticated currently equals more than one investment in an unlisted company ... so 2 x £10 invested on Crowdcube makes you sophisticated going forward. Counting P2P loans just makes it easier & cheaper. 2p on AC
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cb25
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Post by cb25 on Jun 4, 2019 10:34:17 GMT
If the 10% rule did apply to existing lenders, hard to see how those lenders could suddenly get out of the market when many are in 5 year loans.
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carolus
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Post by carolus on Jun 4, 2019 10:44:06 GMT
If the 10% rule did apply to existing lenders, hard to see how those lenders could suddenly get out of the market when many are in 5 year loans. I think it's pretty clear that this isn't the case - even the press release says it applies to "customers new to the sector"
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corto
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Post by corto on Jun 4, 2019 10:44:16 GMT
An interesting question is, will we be considered "sophisticated" automatically if we have more than two p2p or unlisted investments?
That should reduce our protection status in case of further law cases or platforms going down.
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archie
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Post by archie on Jun 4, 2019 10:46:05 GMT
I've always wanted to be sophisticated.  |
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Godanubis
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Post by Godanubis on Jun 4, 2019 10:46:51 GMT
As far as I can see the 10% applies to investors that have had professional advice only. They could not count the assets of an individual investor spread throughout various banks etc then moved to P2P.
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Godanubis
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Post by Godanubis on Jun 4, 2019 10:47:53 GMT
I've always wanted to be sophisticated. Too late 
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cb25
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Post by cb25 on Jun 4, 2019 11:33:32 GMT
From the full document: "Investors can re-classify as sophisticated investors (thereby removing the 10% investment limit) when they have more experience." 2Footnote 2: "Our rules allow for such investors to re-classify as sophisticated investors (removing the 10% investment limit) if they have made two or more P2P investments in the past two years." The cap seems to be applicable to new(ish) investors only. No idea how it will be enforced - maybe self-declaration.
Sophisticated equals two investments in two years ? Jeez .... I have not read the document but I hope there's more to it than that !
You can't be seriously sophisticated if all you need to do is put a couple of minimum punts into a couple of minimum P2P offers.
Hopefully the rest of the broader regulations will make up for this omission !
That may be the case as the new rules reference COBS 4.12.8 (“SELF-CERTIFIED SOPHISTICATED INVESTOR STATEMENT") which includes "I am a self-certified sophisticated investor because at least one of the following applies .. (b) I have made more than one investment in an unlisted company in the two years prior to the date below;" see this
COBS: Conduct of business obligations
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bigfoot12
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Post by bigfoot12 on Jun 4, 2019 11:49:20 GMT
Might be bad news for QAA - they have to reprice loans in default to reflect a 'fair' price.
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bigfoot12
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Post by bigfoot12 on Jun 4, 2019 11:56:42 GMT
As far as I can see the 10% applies to investors that have had professional advice only. Other way round. I think with advice you can invest as much as your adviser thinks is appropriate. How they enforce this is another issue.
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Godanubis
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Post by Godanubis on Jun 4, 2019 12:11:37 GMT
As far as I can see the 10% applies to investors that have had professional advice only. Other way round. I think with advice you can invest as much as your adviser thinks is appropriate. How they enforce this is another issue. Ok Thanks. As you say how do you Police it as totals will expand and contract on what could be a hourly basis. At 10% the bigger P2P loans would never get filled as people would easily use up their limits. There is no such restriction on some equally risky S&S investments.
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