Suggestions for Improvements

This is still the case. We won't be reintroducing any fees on the secondary market in the foreseeable future - the platform is intended to be free to use for our lenders.

We should have the facility to remove loan parts from sale, it's on our to do list but hasn't been seen as a priority. I'm also considering removing the expiry time from loan units that are listed for sale, it's currently trying to solve a problem we don't have.

without copying FC I would like to see a simple breakdown of earnings on the dashboard - if only just a box that says "total interest earned to date" paid or accrued or both.

The auto-split amount is currently set on a per loan basis by the admin team.  They're tending to set it to £100 at the moment, but for larger loans it can be set to a larger amount.

We could add a control to the bid screen to allow users to choose their own split amount but at present it's been omitted in the name of simplicity.

Splitting loan units would be straight forward enough from a technical point of view, bit of a pain but doable. However I don't think it's possible from a legal point of view - at least that's the advice we've had so far. We have to follow a set procedure during the sale of a loan unit at the moment and that includes flagging the old loan unit as having been sold and then creating a new loan unit with a new reference number for the new lender.

£50 isn't currently an option, as you say bids must be divisible by £20.  I'm actually thinking of dropping that requirement and maybe reducing the minimum to £10 and letting you bid anything you like above that.  The software will cope fine, we already have a large number of loan units per loan due to big bids being split automatically, and the only reason for the minimum is to reduce interest being rounded to whole pennies from being significant to the overall amount of interest earned (this is calculated to 20 decimal places over the life of the loan, but ultimately has to be rounded to a whole penny).

mikes1531 - This is most likely.  There are numerous things that some of the other platforms are doing that we have been advised are either illegal, make them a collective investment scheme (a big regulatory no no), or are in probable breach of other regulations.  I highly doubt that all those platforms failed to get proper advice or that they ignored the advice they've been given and if we were to talk to other advisors it's probable that we'd get conflicting advice.  Much of what these platforms do operates in current gray areas which are open to interpretation.

We currently employ a dedicated full time compliance officer with many many years experience in the finance industry and working with large banks (who reports directly to our chairman Paul Moore), and have a full time retained legal advisor who handles all of our loans and also provides compliance and legal advice for the business as a whole.  As such we like to think we have the best advice in the industry and are best prepared for the FCA's coming regulation, which as it currently stands has almost no impact on the way we're already doing things.  But that doesn't mean the opinions we receive are definitive and that others are genuinely doing it wrong - for example there may be something in the way Zopa structure their legal agreements or in the process used in the aftermarket that means that what they're doing is perfectly fine, and that we just haven't asked the right questions of our advisors or would need to restructure our lender / borrower contracts, etc.

If it's a genuinely needed facility then I can raise it again with my fellow directors and ask our advisors to work out how it can be done.  With auto-split and the amounts our most active lenders are investing I don't think it's currently a high priority for us.  One to keep an eye on for the future though, and if I face a barrage of people on here saying how important it is for them then naturally I'll bump it's priority up a little bit

Compliance is a hot potato and there are goodness knows how many companies that have set themselves up as self appointed experts in this field. It's all to do with interpretation of what is, IMO, some vaguely worded regulations. Those vaguely worded regulations have often been compiled by goodness knows how many contributing committees at the FCA (was FSA) and can be interpreted in several ways. It would help if the regulations were composed using normal English. But why use one word when you can spread it out over a whole page.

Consequently many of the regulations contradict each other. Section *.** contradicts section *.**. The whole thing needs to go back to square one but there's no chance of that happening. It's not helped of course by the simple fact that the shelf life of many of the staff at the FCA is not that long. So you have the new brooms etc.

'....It's well outside my area of expertise....'  - think it's outside of everyone's level of expertise apart from those being paid to lighten your wallet with their expert advice. There lies the problem though - you have to interpret the regulations. All depends on what way the wind is blowing on a particular day I suppose.

We were once told by the FSA that whilst there was nothing wrong with what we were doing we were not operating within the spirit of the regulations in one particular area. It was so important I've forgotten what it was. Nope, they (the FSA) couldn't suggest an alternative as they were apparently not permitted to do so. Nothing further happened, never even got a letter, etc. They just felt the need to find something that they didn't agree with. No doubt to justify the cost of their visit. Another of those go figure moments for me.