Credit Where It's Due

Having spent the past seven years banging on about the changes needed to democratise the financial system, it's only fitting that my last post for 2014 should give a little credit to the authorities for making some very significant changes this year.

The FCA published its rules to specifically regulate peer-to-peer lending in February, and its rules on crowd-investment in March. At the same time, the Chancellor announced the expansion of the ISA scheme to include peer-to-peer loans. In the Autumn Statement, he announced that consumers who lend to other consumers and sole traders through P2P platforms will be able to offset any losses against interest received. And there will be a consultation on expanding the ISA scheme to encourage crowd-investing in bonds and other debt securities.

We are still at the start of a long journey. The rules could be simpler and the EU could yet muddy the waters if the UK position is not well represented. But if you'd asked me in 2007 whether so much would be achieved by 2014 - particularly on the ISA front - I'd have been optimistic (naturally) but expecting the worst. Yet in 2015 we'll have both the regulatory 'blessing' and the incentives necessary to enable people with surplus cash to get it directly to creditworthy consumers and small businesses who needed it, instead of leaving the money tied up in low yield bank deposits or having it eaten away by fees in managed investment funds. 

Perhaps this is partly why 2014 also saw the bank bosses' swagger and bravado turn to panic. The trends which are combining to democratise the financial system have not only revealed that the stuffed shirts are powerless to stem the flow of fines for corrupt practices on virtually every front, but those trends have also produced competition from the banks' very own customers. 

Hell, even their auditors are finally coming under scrutiny!

But let's not get carried away. While crowdfunding is growing at over 150% a year, the crowd will probably produce 'only' about £5bn of funding in 2015, based on Nesta figures and assuming a boost from the ISA changes. 

So, while we've come along way since Bobby "Dazzler" Diamond infamously suggested that the time for bankers' remorse was over if the UK was to recover, we will still have a small business funding gap next year - eight years after the financial meltdown. In fact, in many ways the financial system is in worse shape now than in 2007, with less competition and appalling inefficiency in banking, vast public sector debt, a larger 'shadow banking' sector than every before (depending on how you measure it), and many key economies around the world suffering low/no growth. Events such as those in Russia, Greece and the Eurozone are applying further pressure to a system that is still broken. In these circumstances we remain terribly vulnerable to financial shocks. 

Still, the UK government deserves plenty of credit for the changes announced to date. Whether they have come early enough to help us through the next storm remains to be seen, but at least the national funding solution now lies substantially in our own hands. 

If we don't take the opportunity to crowdfund the recovery, we will only have ourselves to blame.

Good News For #FinTech And #Crowdfunding in Autumn Statement

The government has announced bad debt relief for lending through P2P platforms; a consultation on whether to extend ISA eligibility to crowd-investing in debt securities and an intention to review some rules that add unnecessary costs for institutional lending through P2P platforms.

Individuals lending through P2P platforms to offset any losses from loans which go bad against other P2P income. It will be effective from April 2016 and will allow individuals to make a self-assessment claim for relief on losses incurred from April 2015.

The government will also consult on the introduction of a withholding regime for personal income tax to apply across all P2P lending platforms from April 2017. This will help many individuals to resolve their tax liability without them having to file for Self Assessment.

The government will call for evidence on how APIs could be used in banking to enable financial technology companies to develop innovative solutions to allow customers compare banks and financial products.

From January 2015, the majority of card acquirers will offer a new service for small businesses to receive the funds from debit and credit card transactions much more quickly. Two acquirers will not meet this commitment, and the government will ask the Payment Systems Regulator (PSR) to examine whether small businesses are being disadvantaged as a result.

The government will allow gains that are eligible for Entrepreneurs’ Relief (ER) and deferred into investment under the Enterprise Investment Scheme (EIS) or Social Investment Tax Relief (SITR) to benefit from ER when the gain is realised. The government will also increase the annual investment limit for SITR to £5 million per annum, up to a total of £15 million per organisation, from April 2015 and will also consult further on a new relief for indirect investment in social enterprises.

To better target the tax reliefs, the government will exclude all companies substantially benefiting from other government support for the generation of renewable energy from also benefiting from tax-advantaged venture capital schemes, with the exception of community energy generation undertaken by qualifying organisations. The government will also make it easier for qualifying investors and companies to use the tax-advantaged venture capital schemes by launching a new digital process in 2016.

2013: Levelling The Financial Playing Field

Six years of financial crisis have finally produced some of the legal changes that will expose the cosy world of regulated financial services to innovation and competition. But there is plenty more to do.

During 2013 we've seen consumer credit move to the FCA, the regulation of peer-to-peer lending, and the FCA's proposed rules for how the 'crowd' can lend and invest. And this week the Banking Reform Act implemented the recommendations of the Independent Commission on Banking and key recommendations of the Parliamentary Commission on Banking Standards.

Some may see these changes as a magnificent display in closing the stable door. But I prefer to see it as an opening of the floodgates. 

After all, the European Commission is consulting on its own approach to regulating online financial marketplaces; and the US states are competing with the Securities Exchange Commission on the regulation of crowd-investing.

So 2014 will see a lot of focus on enabling the growth of alternative financial services, at the same time as the banks become even more preoccupied with solving their own problems at their customers expense.

That bodes well for a market that grew 91% in 2013.

But, like I said, there's still a lot of work to do.

 

Failure Is Key To The Success Of Equity CrowdInvesting

An odd article on page 20 of today's FT suggests that the failure of some ventures to raise money somehow puts 'crowdfunding' in doubt, while page 4 cites Nesta research to show that this alternative finance market is growing rapidly. 

What's going on?

Well, traditional financiers have been forced to take crowdfunding seriously now that the FCA is consulting on specific rules to govern certain types (peer-to-peer lending and crowdinvesting in equities and debt securities). Some see this as an opportunity, and want to help these alternative marketplaces grow, while others perceive a threat that must be contained.

Those who feel threatened typically overplay the benefits of 'traditional' investment models, and mistake the strengths of the crowd-based models for weaknesses. 

For instance, venture capitalists often claim that theirs is 'smart money' compared to equity-based crowdinvesting. In fact, one is quoted in today's FT article as saying that VC investment brings "partners, skills and support that will nurture the business through growth over the medium to long term." This is rubbish. Venture capitalists spend most of their time looking for deals, not managing the businesses in which they have invested - and most of those businesses will fail anyway. They are not looking to build a portfolio of steady performers, they are hoping a few stars from their stable will return 20 to 30 times their investment. Board meetings are infrequent events at which VCs study the numbers. The occasional insightful comment may emerge, but these pale to insignificance compared to the 360 degree, 24/7 feedback any business experiences in today's social media world. Ironically, most of the time is actually taken up by management explaining the business to the VC directors - and quite properly so. But any responsible director can fullfil this role, and a business that can raise VC money or other funding is equally likely to attract directors with real subject matter expertise (and/or genuine independence) in any event. VCs don't have a monopoly on introducing good directors.

Related to this is the issue of discretion. Few people may be aware a business is seeking VC investment, but nor could they be expected to care since they are excluded from the process. So the search for venture capital generates zero interest among potential customers or other supporters of the business. Nor is the venture process likely to be very efficient, let alone successful. Start-ups and early stage companies typically approach many VC firms in the hope of getting a commitment from 2 or 3. It's a gruelling 3 to 6 month process involving lengthy, repetitive due diligence sessions that come as a huge distraction from the day-to-day management of the business.

Crowdinvesting, on the other hand, enables the business to engage in a single process that tests the appetite of both investors and customers. Flaws may be visible to the world, but this transparency provides consumer and investor protection while giving the business a chance to adapt on both fronts at an early stage. This may not guarantee long term success any more than traditional venture funding does, but it helps everyone avoid wasting a whole lot of time and money.

It's a process that venture capitalists might grow to like.

Crowdfunding Regulatory Arbitrage - Updated

October is 'crowdfunding month' out there in the regulatory world. The European Commission is consulting. The SEC is consulting. Some US states are consulting. The French are consulting. And today, the FCA is consulting.

The European Commission is still in fact-finding mode, so should have the luxury of plucking all the good bits out of the US and UK approaches.

Ironically, the SEC's approach looks too much like small beer to enable fund-raisers to take on the entire US market, but enabling them to raise $1m every 12 months could be really helpful on an intra-state basis (and, indeed, possibly for many EU-based start-ups). On the other hand, it would probably be tough to market anywhere the investor limit of $2,000 or 5 percent of annual income or net worth, for those with annual income/net worth of less than $100,000.

On some ground the FCA's approach might look somewhat better, but in my view, the FCA has not struck the right balance in its proposals to regulated peer-to-peer lending and crowd-investment. 

Loan-based crowdfunding platforms should be regulated more like payment platforms rather than like investment firms, as the FCA proposes. As a result, it will be substantially more expensive to establish and operate a platform with no real change in how operational risks are managed. Businesses and institutions may also be put off, both by the need to be authorised just to invest in the loans, as well as uncertainty as to their compliance obligations given that their own systems aren't even involved. The good news here is that the FCA advocates 'secondary market' for loans. 

The good news for investment-based crowdfunding is that the FCA supports wider 'retail' participation than it has to date. But people will still be asked to certify that they will not invest more than 10% of their 'net investible portfolio' and face an 'appropriateness test' if they do not get advice. In other words, it will still be much easier to stick a tenner on a pony, where the bookmaker wins, rather than to back a local business in support of the economy. No one seems to take responsibility for these strange inconsistencies in the way we are allowed to use our money...

The French proposals have the benefit of adopting the approach, called for by the industry last December, of effectively regulating loan-based platforms as payment service providers. However, as Aurélie Daniel has pointed out the proposals also contain controversial "upper limits for loan-based crowdfunding... a maximum loan amount around €250 per individual per project and a global maximum loan amount around €300,000 per project." While this might not trouble consumer loan-based platforms, it would negatively impact platforms that facilitate loans to businesses and for the purchase or development of larger assets such as commercial property. Ironically, the French appear to have reserved such loans for banks, and in this respect the FCA's proposals are of course more helpful. The limits apparently do not apply in relation to investment-based crowdfunding.

At any rate, I guess entrepreneurs may be able to take their pick as to the most suitable fundraising regime.

We Need Let The Crowd into Financial Services

What a difference a year makes. At an industry event yesterday none other than Nicola Horlick, a well-known fund manager, confirmed her faith in crowdfunding as way of people putting money directly into the lifeblood of the economy, at a time when bank finance for small businesses is limited. Her own film finance vehicle raised £150,000 by issuing shares within weeks of an initial discussion with Seedrs CEO, Jeff Lynn, about how the crowd might help. A year ago, she wouldn't have given it a moment's thought. 

Of course, Nicola was referring to equity crowd-investing, which is the latest type of crowdfunding to burst into life. People have been donating to each other's projects via online marketplaces for nearly a decade and lending to each other online since 2005. Even the UK government is lending along side savers on peer-to-peer lending platforms. 

But these 'direct finance' marketplaces are no longer simply challenging a dozy bunch of retail banks. The addition of crowd-investing in shares and bonds is a direct assault on the sophisticated world of venture capital, private equity and boutique investment banking. 

Silicon Roundabout has launched a rocket attack on Mayfair.

This trend has raised a few bushy eyebrows down at Canary Wharf, where the paint is still wet on the signage at the hastily re-named Financial Services Conduct Authority. Not everyone at the FCA is excited by the prospect of just anyone being able to put a tenner into a business run by Nicola Horlick. In fact, the 'hawks' down there seem to believe that ordinary folk should content themselves with a low interest savings account, a lottery ticket and a flutter on the nags between visits to the nearest pub. If you can't afford to lose a grand, say the hawks, then you've hit the economic buffers. The banks can enjoy the use of your savings for free, while the government enjoys the betting taxes and the excise on your beer and cigarettes.

And we wonder why the poor get poorer.

You might also wonder, as I did yesterday, how 'the government' might explain to the same person who is banned from buying a share in the local bakery why he is still be free to blow £10 on a drug-fuelled quadruped at a racetrack, or donate it to a band that might go triple platinum and never have to share a penny of the upside with those who backed them.

But that's where you're reminded that the government never puts itself in the citizen's shoes; and there's really no such thing as 'the government' anyway. Just individual civil servants at separate desks in separate buildings, each looking at his or her own policy patch and waiting to be told what to do. Collaboration is not a creature common to Whitehall. In that world, no one at, say, the Treasury snatches up the phone to share a bold new vision for driving economic growth from the bottom-up with the folks over at Culture Media and Sport, or Business Innovation and Skills or Communities and Local Government. 

Or do they...?

At least those in Parliament, bless them, did collaborate in response to the ongoing financial shambles. Julia Groves of the UK Crowd Funding Association quoted some choice words on alternative finance from the report of the Parliamentary Commission on Banking Standards, and I've set out the full quote below (as I have previously). Julia also put it very nicely in her own words: "Wealth is not a skillset." We need to let the crowd into financial services, and we need to keep the 'crowd' in crowdfunding. Let's hope this time the following message permeates all the way to the remaining hawks at Canary Wharf.

"57. Peer-to-peer and crowdfunding platforms have the potential to improve the UK retail banking market as both a source of competition to mainstream banks as well as an alternative to them. Furthermore, it could bring important consumer benefits by increasing the range of asset classes to which consumers have access. This access should not be restricted to high net worth individuals but, subject to consumer protections, should be available to all. The emergence of such firms could increase competition and choice for lenders, borrowers, consumers and investors. (Paragraph 350)

58. Alternative providers such as peer-to-peer lenders are soon to come under FCA regulation, as could crowdfunding platforms. The industry has asked for such regulation and believes that it will increase confidence and trust in their products and services. The FCA has little expertise in this area and the FSA's track record towards unorthodox business models was a cause for concern. Regulation of alternative providers must be appropriate and proportionate and must not create regulatory barriers to entry or growth. The industry recognises that regulation can be of benefit to it, arguing for consumer protection based on transparency. This is a lower threshold than many other parts of the industry and should be accompanied by a clear statement of the risks to consumers and their responsibilities. (Paragraph 356)

59. The Commission recommends that the Treasury examine the tax arrangements and incentives in place for peer-to-peer lenders and crowdfunding firms compared with their competitors. A level playing field between mainstream banks and investment firms and alternative providers is required. (Paragraph 359)."

A Directory of Crowdfunding Directories?

Crowdfunding directories are becoming useful, given the wide variety of potential models, specific geographic and other constraints, and the rapidly increasing numbers of new platforms opening up new niches. 

Each directory seems to take a slightly different tack or favour certain types of platform, so it will be interesting to see which 'prevail' and why, and whether they represent a source of customers. 

For instance, Nesta recently launched Crowdingin.com, which aims to list information on platforms open to fundraising from individuals and businesses in the UK. 

Directories with a broader focus include AllStreet, Crowdfund Insider, and Crowdsourcing. The Canadian NCFA has its own nationally-oriented directory.  

Of course, trade body membership lists are also important, particularly where regulation is still evolving and the trade body has a published set of rules that members have committed to follow, e.g. the P2PFA, UKCFA.

By all means suggest any others you have found useful (and why)... At this rate, we'll need a directory of directories!

Image from gCodeLabs.

Labour Is Still Pushing Financial Capitalism

When Gordon Brown (remember him?) repeatedly proclaimed the "end of boom and bust" he was declaring his belief - along with that of his fellow group-thinkers - that capitalism had found a way to become sustainable. But his support for unbridled growth in everything from investment banking to the Private Finance Initiative eventually revealed he was hooked on financial capitalism, rather than the 'real' capitalism of employment and productivity. Look at how ISAs, for example, have become a drain on the 'real economy'.

Ed Milliband has been trying to repair Labour's image with some lipstick apologies here and there, but old habits die hard.

Recently, the party released "An Enterprising Nation", a report by its Small Business Taskforce. To be fair, there are some good insights into the problems faced by small business, as you would expect from the membership of the taskforce. But, surprisingly, the report contains no proposals for short term solutions, or even medium term solutions. One suspects that either the collective intelligence had already fed all those ideas into the government, or the left wing political establishment doesn't grasp the need to foster an environment in which new businesses can start and thrive today.

Academic as they may be, perhaps the worst of Labour's long term ideas is that of a US-style Small Business Administration. It's an idea I first heard from them in November 2011. And as I pointed out then, the SBA programme had already gained a somewhat unhealthy reputation through David Einhorn's book "Fooling Some of the People All of the Time." Heavy application of the Labour lipstick has now branded this idea the "Spark Umbrella" (a nod to the many local German savings banks, or sparkassen, to which this programme actually bears no resemblance).

Basically, the idea is to saddle the UK with 20 lending vehicles, or "Sparks", funded with £10m of public money (naturally) and £90m drawn, no doubt, from the traditional City suspects. Each Spark would fund its lending to local businesses by selling the loans to the "Spark Umbrella" which would in turn finance the loan purchases by issuing bonds to investors eager to package those bonds into  another set of bonds to sell to... anyone stupid game enough to buy them.

Sound familiar? 

The only way not to end up carrying the can for this, would be to emigrate.

But the UK already has an artificial, publicly subsidised channel for small business lending that limits innovation and competition in the retail financial markets. It's run by the UK's major banks. So we don't need another publicly guaranteed channel to crowd-out sustainable private alternatives. 

I mean, who would start a local lending business knowing that the government was about to launch a publicly funded competitor?

The government should foster an environment in which the private sector can generate alternative finance options, not simply create markets that are ultimately underwritten by the taxpayer.

The fundamental flaw in the Spark Umbrella is its reliance on securitisation (or vertical credit intermediation) to try to overcome the riskier nature of small business lending. That model is hugely expensive in terms of issuing and underwriting bonds that are prone to being mis-priced, particularly in riskier markets, as we have seen. It also creates huge scope for moral hazhard, and traditional financial institutions, intermediaries and speculators are likely to be the only potential winners - as Einhorn's book reveals. There is certainly no guarantee that the loans to small businesses will be competitive with other potential alternatives.

Anyone pointing to the US for solutions also has to understand that, like Germany, it enjoys a much more varied set of small business funding options than the UK, as Breedon reported. So it's possible that the SBA won't have crowded-out US private finance businesses in the way that Spark Umbrella would in our bank-dominated market. 

It's also worth noting that Spark Umbrella is purely debt focused, whereas only 3% of UK small businesses finance themselves by issuing shares.  

Of course, we already have a rapidly growing set of alternative financial services platforms that are beginning to solve the problems that the Spark Umbrella will not. Peer-to-peer lending and crowd-investing provide finance to borrowers and entrepreneurs in small amounts directly from many people at competitive rates from the outset, using both debt and equity finance. There is no need to create new markets for these platforms to grow. However, the government has been dragging its heels on the removal of regulatory barriers and perverse incentives, and that does represent an opportunity for opposition parties. 

True, the government has directed some of the Business Finance Partnership funds through peer-to-peer finance platforms. But that funding goes directly into the businesses who borrow - not through countless intermediaries in the financial markets. Labour needs to recognise the difference.

Horizontal vs vertical credit intermediation from Simon Deane-Johns

'Bank' of Dave Goes P2P

I've hugely enjoyed the documentary series tracing Dave Fishwick's valiant efforts to start a small community 'bank' in Burnley high street. 

I say 'bank' because, while it made for good television to say so, Dave didn't necessarily mean "bank" in regulatory terms. His goal was to enable local people to lend to other local people and businesses without profiting unduly. He rightly thought that's what banks are supposed to do, so he was determined to call himself a 'bank' to make the point. And his good-humoured, optimistic crusade has certainly rammed the point home.

While Dave also didn't necessarily set out to launch a peer-to-peer lending marketplace, his path to launch was eerily familiar to those who have done so. The FSA wouldn't speak to us either, prior to the launch of Zopa in March 2005, but was all too keen to discuss the detail afterwards. Fortunately we'd done our homework and didn't have to stop taking money. At least that made for good TV in Dave's case.

Since 2005 a dozen other management teams have also threaded their way through the regulatory maze to directly link savers and borrowers, or investors and entrepreneurs, via online 'P2P' lending or crowd-investing markeplaces. And it's good to see that Dave's journey has led him to adopt the peer-to-peer model on the high street. He may be facing the bricks-and-mortar problems that the online models solve, but at least he's shown there is very real demand for innovation amongst people who still manage their finances by walking around. And the benefits to the 200 local borrowers who are paying a net 5% to local savers are undeniable.

Unfortunately, there are still unnecessary difficulties in structuring these businesses, regardless of whether they facilitate loans or investments in shares or debt. The sources of that uncertainty were summarised here in January 2012, here in February 2012, here in June 2012 and here in July 2012. Industry CEOs and others met policy and regulatory officials to discuss these difficulties at a summit in December 2012, and again last month (as summarised here). The salient points were also explained again in my submission to the Parliamentary Commission on Banking Standards.

However, while it's clear there is plenty of shared frustration and many officials have been supportive in discussions, there is worryingly little sign of actual regulatory change.

We need a lot more war stories like Dave's.

My Legal Alter Ego Has Been At It Again

Image from Parliament.uk

This time he's made a submission 

To the Banking Standards Commission.

He's a poet and he didn't know it.

Kickstarter's Kick In The Butt For UK Banks

The news that Kickstarter, a US rewards-based crowdfunding operator, has opened a dedicated UK platform is hugely encouraging for anyone concerned about our banking problems.

No doubt Kickstarter is responding to demand from the UK-based entrepreneurs and their supporters who were already using the US platform. But it's also a big bet on the future of alternative finance in the UK, and Kickstarter's expansion will mean a lot of focus on the different ways that people can directly fund other people's personal finances, projects and businesses.

The term 'crowdfunding' first gained currency to describe US 'rewards-based' peer-to-peer platforms like ArtistShare and Kickstarter, and similar platforms already operate in the UK (e.g. Peoplefund.it, Crowdfunder and those mentioned here). These platforms are designed to raise money for small budget projects via the internet without infringing laws that control the offer of 'securities' to the public. Entrepreneurs can post 'pitches' seeking donations, and may offer a 'reward' of some kind in return.

Other peer-to-peer finance platforms enable markets for personal loans and small business loans - called 'person-to-person lending' or 'peer-to-peer lending'. Examples include Zopa, Ratesetter and Funding Circle in the UK, Comunitae in Spain and IsePankur in Estonia which just announced that anyone from the EEA and Switzerland can lend to Estonian borrowers.

The peer-to-peer model has also been adapted to fund charities or not-for-profit projects, which is known as 'social finance' (e.g. Buzzbnk); and to enable many people to fund tiny local businesses in developing countries - referred to as 'micro-finance' (e.g. Kiva, MyC4).

Finally, the peer-to-peer model is being developed to enable direct investments in return for shares and more complex loan arrangements (debentures). This has proved impossible to date in the US, where even Lending Club and Prosper have had to register their peer-to-peer lending platforms with the Securities Exchange Commission. But in the UK, Crowdcube and, more recently, Seedrs and BankToTheFuture appear to have found ways through the regulatory maze to enable the crowd to invest in the shares of start-up companies. Abundance Generation enables funding for alternative energy. Kantox enables people to switch foreign currency and Platform Black enables the sale of trade invoices. CrowdBnk, Trillion Fund and CrowdMission say they're coming soon.

There are signs that the regulatory maze will become much easier to navigate. Both the US and UK governments have recognised that more needs to be done to encourage the growth of these alternative forms of finance. 

The US passed the JOBS Act to provide ways to enable crowd investment in securities. And against a backdrop of proposed legislative changes in the UK, the government has praised self-regulation by the industry and set up a working group to assess the need for changes to the legal framework. That working group includes representatives from the Office of Fair Trading, the Department of Business Innovation and Skills, HM Treasury, the Financial Services Authority and the Cabinet Office. The Department for Culture Media and Sport is also interested in the potential for peer-to-peer finance to fund the development of arts and entertainment. 

The European Commission is also taking an interest in this field, and a regulatory summit is being planned in early December to introduce industry leaders and EU/UK policy-makers and regulatory officials to discuss proportionate regulation to encourage the responsible growth of peer-to-peer finance.

Kickstarter has made a pretty solid bet.

UK Takes Joined-up Regulatory Approach To P2P Finance

The UK government has announced a cross-departmental working group to support the sustainable development of peer-to-peer finance (aka 'crowdfunding'), as part of its latest response to the Red Tape Challenge. 

The composition of this working group is testimony to the broad policy implications and opportunities posed by this new form of financial model for consumers and small businesses. The list of members includes the Office of Fair Trading, the Department of Business Innovation and Skills, HM Treasury, the Financial Services Authority and the Cabinet Office. However, it is known that the Department for Culture Media and Sport is also very interested in the potential for peer-to-peer finance to fund the development of the arts and entertainment industry.  

Specifically, that working group will "monitor the appropriateness of the current regulatory regime for peer-to-peer platforms" and take the lead in engaging with the peer-to-peer finance industry.  In the meantime, the government wishes to encourage continued self-regulatory efforts by the Peer-to-Peer Finance Association to address common operational risks, and to engage with policy-makers and regulators.

Other aspects of the government's response to the 'disruptive business models' Challenger Businesses Red Tape Challenge are discussed here.

CrowdPosts

If you have a passion for the regulatory intricacies of alternative finance, you might check out my recent posts over on The Fine Print. The first involves 'unpacking' the term "crowdfunding", while the other is my take on the FSA's recent note on crowd investing.

The rest of you can stay put and stay tuned - it's time to write about some fun stuff ;-)

Image from Lattice Capital.