shimself
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Post by shimself on Jun 7, 2016 20:59:11 GMT
Ablrate today have said Some other platforms have closed comments down on loans citing regulatory concerns. We feel that with a few tweaks we can make that section more useful for each loan, while remaining compliant.
I find q&a absolutely vital; I am quite certain that my total investment in p2x would be much smaller if it hadn't been for discussion of loans on platforms, learning the things to look out for because someone wiser than me has asked a good question. Platforms without a q&a (on platform or here) don't get my custom.
Does anyone know the ins and outs of this concern, what's the problem?
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Post by mrclondon on Jun 7, 2016 22:12:41 GMT
There are several issues that platforms should be considering in relation to their use of social media:
In the February 2015 review of the p2p sector (para 51), the FCA raised this concern
"For people to share knowledge, platforms often allow investors to comment on investment opportunities. Some market intelligence suggests that negative comments are being deleted from these forums on some sites, which may lead to situations where relevant risks are overlooked"
For "forum" read both "forum and Q&A". The logical conclusion from that commentary by the FCA is that all social content hosted by platforms should have a full audit trail of edits such that complaints of over-zealous censorship can be independently adjudicated.
The second concern, that is probably more applicable to this forum that in-house ones, is that responses to lenders by platforms can come under the FCA Financial promotions regulations.
The third concern, and the most serious, is the potential for platforms (and loan introducers) to use anonymous accounts both on here and on in-house forum (and possibly Q&A) to ramp investment in loans on their own platform (aka shill marketing).
There have also been concerns raised that platforms could use anonymous accounts on here to undermine their competitors.
So to answer the thread title, to the best of my knowledge the FCA is not banning Q&A or forum interaction, but platforms can expect to be audited by the FCA on any aspect of their operations, including their use of social media, and will be expected to be conversant on all aspects of FCA guidance.
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blender
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Post by blender on Jun 7, 2016 22:39:30 GMT
Ablrate today have said Some other platforms have closed comments down on loans citing regulatory concerns. We feel that with a few tweaks we can make that section more useful for each loan, while remaining compliant.
I find q&a absolutely vital; I am quite certain that my total investment in p2x would be much smaller if it hadn't been for discussion of loans on platforms, learning the things to look out for because someone wiser than me has asked a good question. Platforms without a q&a (on platform or here) don't get my custom. Does anyone know the ins and outs of this concern, what's the problem? Where have Ablrate said that please?
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jjc
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Post by jjc on Jun 7, 2016 23:55:44 GMT
On an email sent out today at 16.45 announcing a new 14% 36M loan. The unusual placing of the comment being due to Abl informing lenders that the Comments section in their loans will be disactivated temporarily (as from this new loan) whilst they make some tweaks. Like shimself hope there's not more to it than that. Tbh the full 7 line para in the email does leave room for doubt. Suggests Abl weren't compliant before (though doesn't say why) mrclondon's "all social content hosted by platforms should have a full audit trail of edits such that complaints of over-zealous censorship can be independently adjudicated" raises an interesting question for platforms that censor/delete q's on Q&A (AC springs to mind). chris any thoughts? I'd like more platforms to have (& use) Q&A's. FS, MT (don't have them), SS (do but not used/replied to) just some examples.
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james
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Post by james on Jun 8, 2016 1:20:41 GMT
There are several issues that platforms should be considering in relation to their use of social media:
In the February 2015 review of the p2p sector (para 51), the FCA raised this concern
"For people to share knowledge, platforms often allow investors to comment on investment opportunities. Some market intelligence suggests that negative comments are being deleted from these forums on some sites, which may lead to situations where relevant risks are overlooked"
I'd add two more concerns. One is platforms barring public discussion that names a borrower or shares information present on a platform. So the discussions are restricted to often limited tools on the platform and also diligence by prospective customers is inhibited. The combination of a platform with no internal discussion and a ban on external disclosure is particularly toxic, effectively barring much useful investor discussion of risk issues. Another is this forum, that it is to some extent undermining proper due diligence by investors. The problem is the don't name the investor rule, which effectively bars investors sharing information and due diligence about loans and platforms here, complete with proper references. So if a group of investors wanted to do something like cooperating to share the results of say land registry searches on a property being used as security, the rules here prohibit it by banning the posting of the link or details of the borrower. Ditto for things like planning permission or press reports, all of which are useful diligence. In one specific recent case my due diligence about using a platform I was considering using was impaired here by the rule, which while barring naming the borrower also ended up barring checking the platforms own actions because the checks on the platform would have disclosed the borrower name. In some cases I've chosen to have discussions in places like MSE where that is permitted and where I know that MSE has a very favourable consumer protection first policy, complete with in-house lawyer.* Not something that this place can afford, for obvious reasons. I'm not sure what the solution is other than carrying out such cooperative checking and related discussions somewhere else. The don't name the borrower rule was originally implemented to protect consumers, where there was and is specific legislation relating to harassment and embarrassment of borrowers so I think it is still necessary in that context. I'm not aware of something similar for say a limited company, so permitting identifying companies via things like Companies House or Land Registry or press isn't something that I think would be harmful overall, except in a few specific cases. There is one partial solution in use here for one platform, a restricted membership board. A catch is that since you have to be a customer before you can read it, pre-customer diligence is inhibited and so is web searching. Still, it's a useful measure and I'm pleased to see it. There are things that this place is superb for but cooperative due diligence is not one of those things. *That isn't anything goes. For example, a person or two were unhappy with me mentioning a specific investment and complained to MSE then MSE's forum team asked me about it. i replied with a couple of messages explaining things and heard no more about it, having comprehensively addressed the potential issues.
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Post by chris on Jun 8, 2016 3:39:32 GMT
On an email sent out today at 16.45 announcing a new 14% 36M loan. The unusual placing of the comment being due to Abl informing lenders that the Comments section in their loans will be disactivated temporarily (as from this new loan) whilst they make some tweaks. Like shimself hope there's not more to it than that. Tbh the full 7 line para in the email does leave room for doubt. Suggests Abl weren't compliant before (though doesn't say why) mrclondon 's "all social content hosted by platforms should have a full audit trail of edits such that complaints of over-zealous censorship can be independently adjudicated" raises an interesting question for platforms that censor/delete q's on Q&A (AC springs to mind). chris any thoughts? I'd like more platforms to have (& use) Q&A's. FS, MT (don't have them), SS (do but not used/replied to) just some examples. I'm about to jump in the car for the wonderful drive to Stockport so this needs to be brief, but as far as I'm aware we have no issues with the Q&A and haven't been told anything specific by the FCA beyond the general guidance that mrclondon has kindly quoted. We have a clear Q&A policy that it is a system to ask questions about the loan not a facility for lenders to broadcast their feelings or opinions. As long as lender stay within the rules and ask clear and concise questions without colourful embellishments to try and get around the rules, then their questions remain unedited and visible to all, no matter how difficult a question it may be for us to answer. The Q&A is not a discussion forum for lenders and is explicit in its purpose. We keep a full audit trail so that the FCA or ombudsman can see the history as needed. I suspect that complaints about over-zealous censorship apply more to platform hosted forums which are for general discussion where negative comments and threads are heavily moderated. Edit: I'd also add that AC have, thus far uniquely, supported with the help of the moderators on this site the pink discussion pages where verified lenders can discuss the full details of loans within the rules of this forum and independently moderated.
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Post by mrclondon on Jun 8, 2016 11:05:06 GMT
I'm re-quoting this from a thread on the Ablrate board:
........, but of course most of the commenting is here. This is an independent forum and Ablrate have no editorial control, which is good for compliance because it is warts and all, totally honest and open, though that brings its own risks for Ablrate. The good news is virtually all platforms (including Ablrate) accept that they have no editorial control over the forum, and post positively and sensibly on here to reflect their beliefs and opinions just like any other poster (whilst hopefully remembering the financial promotions regulations).
However the forum mod team are distracted at regular intervals by just two platforms requesting we remove negative comments and opinions concerning their platform from the forum. I can't recall in any of these instances we have actually taken any action as none of the posts contravened the forum rules. If the comment is so demonstrably wrong, why not simply post in the thread a full explanation as to why it is wrong.
One of these two platforms has recently accused a forum poster of fabricating a screen grab of their platform by extracting the html code, inserting erroneous data, rendering it in a browser, and taking the screen grab. This was in reply to my earlier response to the platform that I could see no evidence that the screen grab had been "photoshopped". This same platform has recently suggested that they should be given moderation rights to their sub-board on this forum to remove posts they don't like .... don't panic that simply isn't going to happen.
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Post by ablrate on Jun 8, 2016 11:08:27 GMT
Hi
I responded on another thread, but to answer specific questions in relation to audit trails on comments.
We keep ALL comments on the admin section, providing a thorough audit trail.
We are just reveiwing how best to make the loan Q&A better.
As I said elewhere:
Here are a few of issues with the comments section:
1. Everyone gets a mail with the comment not in the email. People were searching for a link and accidentally unsubscribing. We made it more obvious, so that has stopped that.
2. We are looking for it to be 'opt-in' and 'opt-out'. I.e 'Would you like to receive updates on this loan?" The updates were annoying a lot of people. 3. There is a general concern about compliance with regulation, which has been something this forum has discussed. We are just taking a step back and assessing how the comments work, are they useful, and what impact do they have on compliance.
4. We had an outsourced solution on the old platform, with internal forums that only registered members could access - it was never used (admittedly we were very new then). This maybe a solution that works better for us now from a privacy point on specific loans. The system also provided us with a very good support ticketing system.
The forum here is awesome, and we wouldn't be withdrawing from here at all, however, all platforms are reviewing procedures on financial promotion rules etc as it is an obligation, one which we take very seriously.
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oldgrumpy
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Post by oldgrumpy on Jun 8, 2016 11:25:22 GMT
"... However the forum mod team are distracted at regular intervals by just two platforms requesting we remove negative comments and opinions concerning their platform from the forum..."Ooooh! I wonder which - couldn't be the one which caused the formation of this forum by any chance? Oh no, I may think that but you could not possibly comment, etc. The other one .... mmm!
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hendragon
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Post by hendragon on Jun 8, 2016 12:04:37 GMT
"... However the forum mod team are distracted at regular intervals by just two platforms requesting we remove negative comments and opinions concerning their platform from the forum..."Ooooh! I wonder which - couldn't be the one which caused the formation of this forum by any chance? Oh no, I may think that but you could not possibly comment, etc. The other one .... mmm! I vote (lets have a poll) that we send OG after these two platforms. I suggest he should be equipped with RPBs (rocket propelled bananas)
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shimself
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Post by shimself on Jun 8, 2016 12:30:03 GMT
...... Edit: I'd also add that AC have, thus far uniquely, supported with the help of the moderators on this site the pink discussion pages where verified lenders can discuss the full details of loans within the rules of this forum and independently moderated. AC have done a very good thing in founding this forum and adding the private pink pages, thanks TC have an equivalent forum, restricted to people who have invested. It isn't independently moderated; it might not be moderated at all and certainly very frank opinions are expressed, I have a niggling recollection that they did delete something once but perhaps I'm thinking of something else. They also have an onsite forum, which they do moderate a bit (?), and finally they have a q&a for every loan, well used, which, like AC, has a rule that it's for questions not for sounding off. Unlike AC they don't validate each question before allowing it to appear; I've had AC refuse to publish 1 or 2 questions of mine where I thought they were being unreasonable. In addition (and this isn't about my questions which AC didn't like) it seems reasonable to me to allow people to air criticisms of loans (to sound off), data needs interpreting to become information (I think I just coined that, I've impressed myself) I suspect a lot of AC lenders are not aware of p2pif, and personally I'd like to see a link on AC's website, labelled forum, which comes here. I'd also like to see a link on each voting email.
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Post by tybalt on Jun 8, 2016 12:58:50 GMT
There have been I believe been under 6 occasions over the last 3.5 years when ThinCats have removed threads and questions. The most recent was a sponsor who apparently wanted to offer bidding / underwriting incentives.
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Post by chris on Jun 8, 2016 14:34:48 GMT
shimself - I've offered this before but if anyone ever feels they've unfairly had a question removed from our Q&A then I'm happy for them to send the details to me and I'll investigate. Our lender team should not be hiding behind the Q&A rules nor censoring difficult questions. However I've had three people thus far take me up on this offer and in each case it was clear that the lender team were correct in their action. For the avoidance of doubt a question is something like "Can you explain why my hotel room curtains appear to be blue?". If someone posts something like "This is a blooming disgrace. I paid good money for this hotel room and they've given me blue curtains when the advert said they'd be navy. I expect my money back and compensation and everyone else staying at the hotel should know about this. So AC, why are the curtains blue?" It doesn't matter if your opinion is right or wrong, whether the platform is correct or someone has made a bit of a boo boo. The Q&A is expressly not a place for you to air your opinions or broadcast your thoughts to the other lenders. Clear, concise, constructive, polite, unique, a question, and nothing but a question. Tick all those boxes and the lender team shouldn't have any excuses for removing your post or hide it from the site and if they do then complain to me and I'll personally look into it.
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Greenwood2
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Post by Greenwood2 on Jun 8, 2016 19:44:49 GMT
There have been I believe been under 6 occasions over the last 3.5 years when ThinCats have removed threads and questions. The most recent was a sponsor who apparently wanted to offer bidding / underwriting incentives. TC don't moderate, But a few times there have been particularly anti TC posts on the TC forums that I would have liked to challenge, but there are definitely some trolls on there that you (or at least I) don't chose to confront (or feed). One of the hazards of forums.
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james
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Post by james on Jun 8, 2016 22:48:50 GMT
It doesn't matter if your opinion is right or wrong, whether the platform is correct or someone has made a bit of a boo boo. The Q&A is expressly not a place for you to air your opinions or broadcast your thoughts to the other lenders. Clear, concise, constructive, polite, unique, a question, and nothing but a question. Tick all those boxes and the lender team shouldn't have any excuses for removing your post or hide it from the site and if they do then complain to me and I'll personally look into it. So far as it goes that's helpful but it doesn't really fully address the FCA's concerns, which would require investors to be able to share their views on the facts in discussion with other prospective lenders. So Q&A is Q&A only is fine, but there is then a broader discussion need. Which the section here can partly address, aside from unavailability to non-customers doing platform due diligence. Of course some of the issues are tricky, not least because opinions can annoy a prospective borrower and turn them into a former prospective borrower. There are ways to say bargepole territory without quite saying exactly that.
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