"As explained in CP 18/20 and PS 19/14, diverse business models in the P2P market mean that it is important that investors receive
ongoing disclosures to ensure that investors can access details of each P2P agreement they have entered into. These ongoing disclosures are detailed in COBS 18.12.31 R and include the price of the P2P agreement, its maturity, valuation, likely actual return, fees paid by the investor or the borrower, and whether a default by the borrower under a P2P agreement has occurred. These disclosures also apply to P2P agreements in a P2P portfolio".
(the bold emphasis was in the original)
ilmoro I may be misunderstanding this, or over-interpreting it, and, as ever, I'm happy to be corrected
. Anyway, to pick some specifics:-
1. Maturity - yes at origination, but I'm less confident that this is done where loans are overdue, extended, placed into forbearance, or defaulted. Even where the data is available you might have to dig for it, collate the overall picture yourself, and I'm not sure how easy that is if you're buying in a secondary market.
2. Valuation - yes at origination (at least in terms of the loan amount), but I'd argue that this definitely isn't the case in terms of a mark to market valuation of underlying security, or a current "value" of a particular loan.
3. Likely actual return - is this ever provided, in any context? I'm not talking about black box accounts, but individual loans purchased by investors eg whilst I might have my own view of the probability of a particular loan defaulting, and what loss might be taken, does a platform publish loan specific data, for that particular loan, during its life? What if I disagree with the platform? What if I disagree with other investors who've taken a different view? Beyond making / accepting, or not, a price in a secondary market where's the discovery?
To take a crude example. Loan X is taken out with security Y. Security Y is a house worth £100k. The arse falls out of the property market and security Y is now only worth £80k.
Does any platform present this change in the likely actual return during the lifetime of the loan, on an ongoing basis?
4. Fees paid by investor and borrower (additional emphasis in default situations) - I don't believe this is as clear as it could be, and there have been some pretty egregious examples where it definitely wasn't the case eg Lendy.
5. Whether a default has occurred - that old chestnut. I bet we can all think of examples of loans that we consider defaulted, even if a platform hasn't formally placed them in default.
6. Outcomes statement - If these are offered across all platforms I don't know where to find them (this could well be on me, I've been winding down my book for ages now so may not have been paying attention).