kaya
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Post by kaya on Mar 7, 2016 19:58:11 GMT
Dear Rebs, why do several loans now state that loan part trading is 'suspended'? Is this a change in policy, without notice or comment? May I suggest that, if micro-loan trading is suspended, then it should not be possible to view - and tick on 'buy' - the micro-loan list, and also that no value should be dislpayed on the main secondary market page. So has policy changed regarding late loans?
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Balder
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Post by Balder on Mar 8, 2016 9:55:49 GMT
I thought I'd give Rebs a go. Bought some of para. Auction finished 4/2/16 now 8/3/16 and trading still on hold. Comms generally poor, site slow. Model not for me - gave it a go but I'm off asap.
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Post by rebsrep on Mar 8, 2016 10:01:19 GMT
Dear Rebs, why do several loans now state that loan part trading is 'suspended'? Is this a change in policy, without notice or comment? May I suggest that, if micro-loan trading is suspended, then it should not be possible to view - and tick on 'buy' - the micro-loan list, and also that no value should be dislpayed on the main secondary market page. So has policy changed regarding late loans? There has not been any change in policy. ML trading is suspended when there are unknowns because we have a duty of care under FCA regs to the lenders. The ability to tick on buy when ML is suspended is a known issue and is on the list to fix. However when you do try and click Buy it won't let you actually buy when suspended.
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Post by rebsrep on Mar 8, 2016 10:11:12 GMT
I thought I'd give Rebs a go. Bought some of para. Auction finished 4/2/16 now 8/3/16 and trading still on hold. Comms generally poor, site slow. Model not for me - gave it a go but I'm off asap. You are accruing interest from the date the auction closes. Putting charges on assets does take time because you have to deal with banks and solicitors both of whom are not known for their speediness. With regards to other communication what else would you like, each loan has a "Subscribe for all" (admittedly the first post doesn't create an alert and is very high on the fix list) for all communications for that loan. There is also a regular newsletter (last one issued 3rd March) which contains updates on all completed but not yet tradeable loans. The extract for Paras is: "All that remains is to complete the legals related to the property charge for this loan. We expect to begin draw down next week."
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kaya
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Post by kaya on Mar 8, 2016 11:40:14 GMT
Dear Rebs, why do several loans now state that loan part trading is 'suspended'? Is this a change in policy, without notice or comment? May I suggest that, if micro-loan trading is suspended, then it should not be possible to view - and tick on 'buy' - the micro-loan list, and also that no value should be dislpayed on the main secondary market page. So has policy changed regarding late loans? There has not been any change in policy. ML trading is suspended when there are unknowns because we have a duty of care under FCA regs to the lenders. The ability to tick on buy when ML is suspended is a known issue and is on the list to fix. However when you do try and click Buy it won't let you actually buy when suspended. I entirely disagree that this is not a change in policy. Obviously something material has changed in policy, because for the first time, as far as I know, loans even less than 8 days late are now having trading suspended. So what is the new policy? At how many days late is trading to be suspended? A change such as this should be e-mailed to all investors before implementation.
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Post by rebsrep on Mar 8, 2016 12:49:59 GMT
There has not been any change in policy. ML trading is suspended when there are unknowns because we have a duty of care under FCA regs to the lenders. The ability to tick on buy when ML is suspended is a known issue and is on the list to fix. However when you do try and click Buy it won't let you actually buy when suspended. I entirely disagree that this is not a change in policy. Obviously something material has changed in policy, because for the first time, as far as I know, loans even less than 20 days late are now having trading suspended. So what is the new policy? At how many days late is trading to be suspended? A change such as this should be e-mailed to all investors before implementation. Kaya I will talk to Complaince and Legal officers and come back to you.
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Post by rebsrep on Mar 10, 2016 17:51:36 GMT
Hi rebsrep I often see loans fail to fill and get a time extension or get discarded. I find this incredibly annoying because it ties up lender funds without paying interest, thereby reducing the overall return, which by the way, doesn't get reflected in the dashboard rate of return. Can I suggest a pre-auction phase where lenders ask questions for say 10 days and an auction phase which lasts 48 hours. Then, if a loan failed to fill, and the borrower agrees, start a new 48 hour auction at a higher rate, with a lender option, allowing their existing bids to float up in line with the new higher rate. sqh We think this is a great idea and may be trialling it on an upcoming loan, if we can get the development work required done in time. The loan is an existing good payer that wants to borrow more but we'll need their permission to use a trial method. However it is a large loan with little security and hence we may not list it at all or pull it after the "discussion" period if there is little interest.
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Post by rebsrep on Mar 10, 2016 18:00:36 GMT
I entirely disagree that this is not a change in policy. Obviously something material has changed in policy, because for the first time, as far as I know, loans even less than 20 days late are now having trading suspended. So what is the new policy? At how many days late is trading to be suspended? A change such as this should be e-mailed to all investors before implementation. Kaya I will talk to Complaince and Legal officers and come back to you. We've identified this as an unintended consequence of a software update as we prepare for ISA and FCA regulation. This has been escalated to the Coding Team who will fix it asap. As you can see though suspending at 7 days does better protect any potential purchasers on loans who may accidentally buy a non-performing loan.
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Balder
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Post by Balder on Mar 10, 2016 18:05:39 GMT
Kaya I will talk to Complaince and Legal officers and come back to you. We've identified this as an unintended consequence of a software update as we prepare for ISA and FCA regulation. This has been escalated to the Coding Team who will fix it asap. As you can see though suspending at 7 days does better protect any potential purchasers on loans who may accidentally buy a non-performing loan. Hey Kaya send in your invoice for regression testing
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kaya
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Post by kaya on Mar 11, 2016 8:36:45 GMT
Thanks for reply, though it is still somewhat unclear what your intentions are - you say the problem will be fixed, but also suggest that suspending at '7 days' is a good idea. So what is it to be?
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Post by rebsrep on Mar 11, 2016 10:17:26 GMT
Thanks for reply, though it is still somewhat unclear what your intentions are - you say the problem will be fixed, but also suggest that suspending at '7 days' is a good idea. So what is it to be? Our intentions are to not just comply but to act in the spirit of full FCA regulation and where there are grey areas to err on the side of caution. We are talking to the FCA on a weekly basis and as the FCA learns about peer to peer and how it is going to regulate it they ask more questions. As part of these questions we often look into new features that will better protect lenders and hence better satisfy the FCA that we have the lenders interests at heart. On this occasion one of the developers was testing a feature that would automate microloan suspension (currently a manual process) and we decided that 7 days was a good period for testing purposes. Unfortunately after testing the 7 day trigger was left in the code. Automation is a consideration because if for example there is a sudden run/unusual pattern on a particular loan an algorithm would pick this up and suspend while we investigated why there was a run e.g. someone close to the business may be trying to offload because they know adverse news not yet in the public domain.
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shimself
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Post by shimself on Mar 11, 2016 12:54:53 GMT
I don't know if you are aware of this but when we get a loan update (which most often concerns a troubled loan) then it starts like this
Dear Lender,
I hope you are well and are having a good week.
I am writing with an update in regards to your loan with HATTON GARDEN SECURITIES...
It doesn't hit the right tone. a good week which I am just about to spoil is more like it
After that I personally am feeling properly informed, thanks. I have described REBS procedures to another platform as a good example of how to communicate to lenders and handle troubled loans
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jonno
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nil satis nisi optimum
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Post by jonno on Mar 11, 2016 12:59:44 GMT
Kaya I will talk to Complaince and Legal officers and come back to you. We've identified this as an unintended consequence of a software update as we prepare for ISA and FCA regulation. This has been escalated to the Coding Team who will fix it asap. As you can see though suspending at 7 days does better protect any potential purchasers on loans who may accidentally buy a non-performing loan. Eh? But I thought that was why we bung 'em on the SM
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Post by rebsrep on Mar 11, 2016 13:08:24 GMT
I don't know if you are aware of this but when we get a loan update (which most often concerns a troubled loan) then it starts like this Dear Lender,
I hope you are well and are having a good week.
I am writing with an update in regards to your loan with HATTON GARDEN SECURITIES...
It doesn't hit the right tone. a good week which I am just about to spoil is more like it
After that I personally am feeling properly informed, thanks. I have described REBS procedures to another platform as a good example of how to communicate to lenders and handle troubled loans
I had this discussion with Michael yesterday as it happens, and from next week no doubt you'll see a new start to these emails. Also thnk you for the positive comment on our communication we are working very hard to communicate as much as we can. I'll pass this back to Michael I'm sure he'll be delighted that his work has been noticed.
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kaya
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Post by kaya on Mar 25, 2016 9:59:20 GMT
I really do not see the point of the new 'maximum discount available' figures for the secondary market. Sometimes the micro loan in question does not even appear in the micro-loan page list, and so can not even be purchased ( should anyone be silly enough to want to), presumably because it is so far down the list! (only the top 100 by maximum rate are listed). At the moment, the secondary market is a dogs dinner of a mess, regarding discrepancies between suspended loans/ micro-loans/ and published maximum rates on the main secondary market page which do not exist because trading is suspended. Get it sorted! What is the policy to be going forward regarding the number of days late before trading is suspended?
You might want to consider having all micro-loans up for sale having a time-limit, in common with other places. It might help to free up the market a bit, as it is now all clogged up with micro-loans looking for increasingly rare buyers. There is nothing so unwanted in this world than poor Rebs micro-loans!
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