ablender
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ISA
Oct 13, 2015 18:08:53 GMT
Post by ablender on Oct 13, 2015 18:08:53 GMT
Does anyone know if there are plans for SS loans to be included in the new ISA as planned for next tax year?
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ablender
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ISA
Oct 14, 2015 10:42:12 GMT
Post by ablender on Oct 14, 2015 10:42:12 GMT
I see that there are no replies for this one. Can Saving Stream chip in with some insight?
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webwiz
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ISA
Oct 14, 2015 11:37:41 GMT
Post by webwiz on Oct 14, 2015 11:37:41 GMT
Everyone is waiting for details from the authorities. The issue is currently out for consultation and may still come to nothing so I would not hold your breath.
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ablender
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ISA
Oct 14, 2015 11:49:44 GMT
Post by ablender on Oct 14, 2015 11:49:44 GMT
OK. Thanks. I hope it will work out as I have some funds that I would like to move over to here.
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Post by savingstream on Oct 14, 2015 12:11:02 GMT
We are planning for it but there is currently very little detail from the Government.
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mv
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ISA
Oct 14, 2015 14:07:47 GMT
paulg likes this
Post by mv on Oct 14, 2015 14:07:47 GMT
The government doesn't like detail--like £8 billion pounds extra for the NHS, difficult to pin down when and where...
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ilmoro
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'Wondering which of the bu***rs to blame, and watching for pigs on the wing.' - Pink Floyd
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ISA
Oct 14, 2015 14:32:22 GMT
Post by ilmoro on Oct 14, 2015 14:32:22 GMT
The government doesn't like detail--like £8 billion pounds extra for the NHS, difficult to pin down when and where... No, the government loves detail, (though they're often not good at it) all sorts of things can hide in the detail, they just dont like detailing it to us as we might find the devil in it 
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james
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ISA
Oct 20, 2015 22:05:47 GMT
Post by james on Oct 20, 2015 22:05:47 GMT
Well, the first thing to establish is whether SavingStream is a 36H qualifying platform. That is the base requirement for the current proposals for both the ability to deduct bad debt losses from interest and the P2P ISA. SavingStream does not currently appear to be a 36H platform because SavingStream does the lending itself then borrows from lenders, with no contract between the ultimate borrower and the lenders. I do not guarantee it but I think that if SavingStream offered an original loan then resold that loan in pieces so that there is a direct contract between borrower and lenders that would make it qualify under 36H. The FCA is the judge for this. The key requirement is that direct contract between ultimate borrower and lenders. Alternatively SavingStream could try to get the law changed so that the SavingStream model is included within 36H. Some other platforms also appear to have this sort of problem and the treasury might be open to changing the law. |
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ablender
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ISA
Oct 20, 2015 22:18:30 GMT
Post by ablender on Oct 20, 2015 22:18:30 GMT
Hi James, What is 36H?
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Post by pepperpot on Oct 20, 2015 22:43:53 GMT
I won't tell you what eye-popping images came up when I just googled 36H.  Anyway, if you add 'article' before it and 'agreement' after it you get to... www.legislation.gov.uk/uksi/2013/1881/introduction/madeIt basically sets out the framework for loan agreements and is enshrined in law, maybe you fancy a little light reading before bed?
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ablender
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ISA
Oct 21, 2015 5:51:19 GMT
Post by ablender on Oct 21, 2015 5:51:19 GMT
Perhaps SS want to add something to this and shed some light. I looked at the article you quoted above. It is "too much of a light reading" for me to use before bedtime. |
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james
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ISA
Oct 21, 2015 11:21:50 GMT
Post by james on Oct 21, 2015 11:21:50 GMT
The key snippet from 36H: "(1) Where the condition in paragraph (2) is satisfied, operating an electronic system which enables the operator (“A”) to facilitate persons (“B” and “C”) becoming the lender and borrower under an article 36H agreement is a specified kind of activity." SavingStream is A, the typical consumer lenders are B and the borrowers are C. In the SavingStream case the lending agreements appear to be between A and C and hence not to be 36H agreements. I assume that SavingStream could adjust the business practices to become a 36H platform if not one already somehow. |
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james
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ISA
Oct 21, 2015 11:24:34 GMT
Post by james on Oct 21, 2015 11:24:34 GMT
We are planning for it but there is currently very little detail from the Government. What are your plans to become a 36H platform, as required by the current proposed rules for both deducting losses from interest and the ISA? Or are you planning to seek changes to the proposed rules that would include platforms that don't qualify as 36H because they don't have loan agreements directly between the borrower and lender? If so, how are your discussions with the Treasury in that regard going?
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indy
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Post by indy on Oct 21, 2015 12:29:01 GMT
Would the new loan structure that SS are putting in place not resolve this??
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james
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ISA
Oct 21, 2015 13:53:03 GMT
Post by james on Oct 21, 2015 13:53:03 GMT
Does the new structure have a loan contract between the borrower and lenders using the platform that specify things like the interest rate the borrower is paying?
If that is what happens then the current iteration of new may do the job. If it's still "platform lends then refinances" then presumably not, unless the refinancing is replacing the initial loan contract entered into between platform and borrower with new ones between lenders and borrower.
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