littleoldlady
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Post by littleoldlady on May 7, 2017 16:45:29 GMT
It might help if the FCA asked providers to always offer a facility to "open" an account (in that it is new to this provider) which does not open a new ISA and which will reject any new subscriptions, existing only to accept transfers. Providers will clearly not do this unless pushed as they would like the applicant to subscribe. This may also be the reason why the instructions to the applicant often make it seem that the account being opened is the only one that can be opened in the current year. Cynical? Moi?
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pikestaff
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Post by pikestaff on May 8, 2017 6:06:24 GMT
It might help if the FCA asked providers to always offer a facility to "open" an account (in that it is new to this provider) which does not open a new ISA and which will reject any new subscriptions, existing only to accept transfers. Providers will clearly not do this unless pushed as they would like the applicant to subscribe. ... How much admin would the provider be expected to do? At one extreme (collect name and email only) this would just be a glorified mailing list of people who might one day, if they felt like it, transfer existing ISA funds to an ISA with that provider. At the other extreme (collect all personal data and give the person an account number) it would still really be just a glorified mailing list but it would run the risk of confusing the prospective investor and/or HMRC into thinking an ISA had been opened, which would be against the rules. Any provider that did this would have to be incredibly careful with their communications. I can't see any benefit and if I was the FCA I would strongly discourage it.
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littleoldlady
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Post by littleoldlady on May 8, 2017 10:37:09 GMT
It might help if the FCA asked providers to always offer a facility to "open" an account (in that it is new to this provider) which does not open a new ISA and which will reject any new subscriptions, existing only to accept transfers. Providers will clearly not do this unless pushed as they would like the applicant to subscribe. ... But that is exactly what happens now. The account opened can be used - against the rules - to make subscriptions when the investor already has another one. My idea is in fact to prevent that confusion and avoid any inadvertent breach.
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ilmoro
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Post by ilmoro on May 8, 2017 10:57:01 GMT
How much admin would the provider be expected to do? At one extreme (collect name and email only) this would just be a glorified mailing list of people who might one day, if they felt like it, transfer existing ISA funds to an ISA with that provider. At the other extreme (collect all personal data and give the person an account number) it would still really be just a glorified mailing list but it would run the risk of confusing the prospective investor and/or HMRC into thinking an ISA had been opened, which would be against the rules.Any provider that did this would have to be incredibly careful with their communications. I can't see any benefit and if I was the FCA I would strongly discourage it. But that is exactly what happens now. The account opened can be used - against the rules - to make subscriptions when the investor already has another one. My idea is in fact to prevent that confusion and avoid any inadvertent breach. Sometimes people have to take responsibility for themselves. If they subscribe to a second same type ISA in a financial year despite having signed two statements saying they havent already subscribed and havent subscribed more than the maximum then there isnt much excuse. Perhaps the providers could much it clear exactly what the terms means (most do) but I dont see why providers should be required to engage in extra unnecessary admin for what I suspect is quite a small error percentage (cost would just hit my pathertic interest rates) as most people dont even move their ISA let alone engage in complicated multiple transfers. All providers offer a way to open a non-instant subscription ISA that enables transfers, though it may not necessarily be the most convenient way eg cant open Nationwide online without subscribing so you have to do it in branch or by post.
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ozaz
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Post by ozaz on May 11, 2017 14:00:29 GMT
ozaz Best of luck getting the authoritative answer that you want. You will find this question in many threads (some by me) and the non-authoritative answer from very knowledgable people is always the same. But if you do get a clear answer from HMRC please post it here. I've now received a clear email answer from HMRC, which is in agreement with what others have said on this thread.
Q) What I'm unclear on are rules surrounding opening accounts without subscribing to them and instead funding by transferring existing ISA funds. What I would like to do is open multiple Innovative Finance ISA accounts (lets say five) but not subscribe to more than one of them. I would like to fund each of these via partial transfers from an existing cash ISA I already have (using ISA transfer authority forms). The cash ISA has not been subscribed to in the current tax year. Is this activity of opening multiple ISAs of the same type (whilst subscribing to no more than one of them) allowed?
A) You can open a new IFISA to subscribe to this year 2017-2018 and you can open as many as new IFISAs you like this year to receive transferred in previous years subscriptions from another ISA. If transferring previous years ISAs, the new ISA manager should arrange the transfer.
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littleoldlady
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Post by littleoldlady on May 11, 2017 14:38:53 GMT
I've now received a clear email answer from HMRC, which is in agreement with what others have said on this thread.
A) You can open a new IFISA to subscribe to this year 2017-2018 and you can open as many as new IFISAs you like this year to receive transferred in previous years subscriptions from another ISA. If transferring previous years ISAs, the new ISA manager should arrange the transfer. Good, as this is just what I have been doing. Shame that the FCA don't tackle the many/most providers who say that you cannot open more than one when they should say you cannot subscribe to more than one, and those that make it more difficult to open one without subscribing than with.
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IFISAcava
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Post by IFISAcava on May 11, 2017 15:12:57 GMT
I've now received a clear email answer from HMRC, which is in agreement with what others have said on this thread.
A) You can open a new IFISA to subscribe to this year 2017-2018 and you can open as many as new IFISAs you like this year to receive transferred in previous years subscriptions from another ISA. If transferring previous years ISAs, the new ISA manager should arrange the transfer. Good, as this is just what I have been doing. Shame that the FCA don't tackle the many/most providers who say that you cannot open more than one when they should say you cannot subscribe to more than one, and those that make it more difficult to open one without subscribing than with. My experience is that all 9 IFISAs I have opened were fine about opening without subscribing. I did however only open those that confirmed they would accept transfers of previous years ISAs.
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Post by robberbaron on May 11, 2017 18:48:34 GMT
Does this mean that if we want to spread our allowance across multiple p2p platforms then the best approach is to transfer 20k from other ISA(s) to new IFISAs accounts then pay 20k into the old ISA account(s)?
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littleoldlady
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Post by littleoldlady on May 11, 2017 18:59:10 GMT
Does this mean that if we want to spread our allowance across multiple p2p platforms then the best approach is to transfer 20k from other ISA(s) to new IFISAs accounts then pay 20k into the old ISA account(s)? I don't think that would work. You can only subscribe this year's £20k to a 2017/18 ISA (or more than one if different types). Previous year's ISAs can be transferred in part or in full to new accounts that you happen to open in this year, but they are still previous year's ISAs. I also would like to spread this year's allowance across several platforms. AFAIK the only way to do this would be if an ISA provider provided the facility. I don't know of one yet, but there is still time. They would not do it for free.
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Post by Jake Wombwell-Povey on May 11, 2017 19:27:31 GMT
NB - platform representative robberbaron 3 routes for multi-platform exposure: - Investment trusts, P2PGI - in a stocks & shares ISA - volatile!
- Transfer previous year ISAs - to different provider
- Invest via a multi-platform provider - not many long established
The key here, with all investment, is your aggregate asset allocation and diversification, or more importantly concentration. Over exposing to a single P2P platform is just as critical as allocating the appropriate amount to the asset class as a whole in light of your other holdings. Tax wrappers are important, but it should form part of our wider thinking around asset allocation and your appetite for risk.
Preach over - but good luck with selecting the right platforms / transferring the IFISAs.
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nush
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Post by nush on May 11, 2017 20:43:38 GMT
NB - platform representative robberbaron 3 routes for multi-platform exposure: - Investment trusts, P2PGI - in a stocks & shares ISA - volatile!
- Transfer previous year ISAs - to different provider
- Invest via a multi-platform provider - not many long established
The key here, with all investment, is your aggregate asset allocation and diversification, or more importantly concentration. Over exposing to a single P2P platform is just as critical as allocating the appropriate amount to the asset class as a whole in light of your other holdings. Tax wrappers are important, but it should form part of our wider thinking around asset allocation and your appetite for risk.
Preach over - but good luck with selecting the right platforms / transferring the IFISAs.
wouldn't using GOJI be adding another platform risk
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Post by Jake Wombwell-Povey on May 11, 2017 20:53:53 GMT
NB - platform representative robberbaron 3 routes for multi-platform exposure: - Investment trusts, P2PGI - in a stocks & shares ISA - volatile!
- Transfer previous year ISAs - to different provider
- Invest via a multi-platform provider - not many long established
The key here, with all investment, is your aggregate asset allocation and diversification, or more importantly concentration. Over exposing to a single P2P platform is just as critical as allocating the appropriate amount to the asset class as a whole in light of your other holdings. Tax wrappers are important, but it should form part of our wider thinking around asset allocation and your appetite for risk.
Preach over - but good luck with selecting the right platforms / transferring the IFISAs.
wouldn't using GOJI be adding another platform risk Absolutely...that is simple maths. But risk is multi-faceted. And to be clear, I am not intending to promote any particular platform over another here. Hence my objective stance. Platform-centric risk could be considered to include counter party risk (that I believe you are referring to), but also pricing risk (that a platform mis-prices a single loan or cohort or loans at a time point), regulatory risk (at a micro or macro level), operational risk (control weakness rather than corporate failure), macro-economic impacting upon the underlying credit sector a particular platform focuses on. Stating facts again, Goji's team has been involved in billions of pounds worth of credit transactions....we were never underwriters but DCM bankers, credit risk experts and direct lending diligence accountants (reviewing transactions at both the portfolio and corporate level). So whilst Goji does indeed present a certain type of platform risk, just like any other, our ability and experience (as credit managers, not underwriters) to diversify, allocate and manage portfolios in a single ISA (soon SIPP) wrapper 'may' be appealing to some investors and wealth managers based upon their own risk assessments.
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IFISAcava
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Post by IFISAcava on May 11, 2017 22:56:33 GMT
Does this mean that if we want to spread our allowance across multiple p2p platforms then the best approach is to transfer 20k from other ISA(s) to new IFISAs accounts then pay 20k into the old ISA account(s)? I don't think that would work. You can only subscribe this year's £20k to a 2017/18 ISA (or more than one if different types). Previous year's ISAs can be transferred in part or in full to new accounts that you happen to open in this year, but they are still previous year's ISAs. I also would like to spread this year's allowance across several platforms. AFAIK the only way to do this would be if an ISA provider provided the facility. I don't know of one yet, but there is still time. They would not do it for free. you could do that, but you'd have to invest £20 K in one ISA (or spread between the three types of ISA) this tax year, then on April 6 2018 request partial transfers to all the other platforms you want.
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Post by robberbaron on May 12, 2017 5:14:08 GMT
I don't think that would work. You can only subscribe this year's £20k to a 2017/18 ISA (or more than one if different types). Previous year's ISAs can be transferred in part or in full to new accounts that you happen to open in this year, but they are still previous year's ISAs. Not sure I understand why that wouldn't work. I was under the impression that you could pay your allowance into a previous year ISA and that transferring money from that ISA would not be considered as a subscription. Is it not possible to do both during the same tax year?
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ozaz
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Post by ozaz on May 12, 2017 6:53:21 GMT
Does this mean that if we want to spread our allowance across multiple p2p platforms then the best approach is to transfer 20k from other ISA(s) to new IFISAs accounts then pay 20k into the old ISA account(s)? During 17/18 my plan is to fund all my IFISAs and S&S ISAs with multiple partial transfers from previous year subscriptions held in my cash ISA. I plan to almost fully drain my cash ISA of its previous year subscriptions. Before the end of 17/18 I will subscribe as much as I can to my cash ISA and then early 18/19 again redistribute my previous years cash subscription (which will at that time include the 17/18 cash subscription) via partial transfer to multiple IFISAs and S&S ISAs. Will need to be careful I always have enough of a cash emergency fund as it will be distributed and dynamic rather than just parked long-term in a cash ISA as I have been doing in the past. This will include non-ISA accounts like my high interest current accounts and high interest regular savers maturing at various times during the year.
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