A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte

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A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte
 temporary phenomenon?
A
Marketplace lending
An analysis of the UK market
A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte
Marketplace lending | A temporary phenomenon?

Contents

Foreword                                                                  1
Executive summary                                                         2
1. What is marketplace lending?                                           4
2. Marketplace lending: a disruptive threat or a sustaining innovation?   8
3. The relative economics of marketplace lenders vs banks                 11
4. The user experience of marketplace lenders vs banks                    23
5. Marketplace lending as an asset class                                  24
6. The future of marketplace lending in the UK                            30
7. How should incumbents respond?                                         32
Conclusion                                                                35
Appendix                                                                  36
Endnotes                                                                  37
Contacts                                                                  40
A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte
Marketplace lending |
                                                                                                                     A temporary phenomenon?

                                                                                                                                                Foreword
Foreword
As explored in Deloitte’s Banking disrupted     All these are factors that add to the           Our findings suggest that MPLs in the UK
and Payments disrupted reports, and             average cost of a loan. Many commentators       are unlikely to pose a threat to banks in
Deloitte’s The Future of Financial Services     recognise the significant cost advantage        the mass market. In the medium term,
report, produced in collaboration with the      that this will give MPLs and are highlighting   however, MPLs are likely to find a series
World Economic Forum, a combination of          the resultant disruptive threat that MPLs       of profitable niches to exploit, such as
new technology and regulation is eroding        represent to the traditional banking            borrowing which falls outside banks’
many of the core competitive advantages         business model.                                 risk appetite and segments that value
that banks have over new market entrants.                                                       speed and convenience enough to pay a
These structural threats have arrived at        This report is our contribution to this         premium (for example SMEs, particularly
a time when interest rates are at historic      debate in respect of marketplace lending        in invoice financing, or high-risk retail
lows, and seem likely to remain ‘lower          in the UK. It is based on extensive research    borrowers). So while banks cannot afford
for longer’. Combined with an increase in       and analysis, including expert interviews       to be complacent, they probably have more
regulatory capital requirements, these          and a survey of consumers and small             to gain than to lose from implementing
changes are making the goal of generating       businesses in the UK, which aim to answer       a strategy of effective collaboration and
returns above the cost of (more) capital a      the following questions:                        partnering with MPLs.
continuing challenge.
                                                •• is marketplace lending a temporary
At the same time, customer expectations            phenomenon? Does it constitute a
are changing. Consumers’ experience                disruptive threat to banks’ core lending
of digital in industries such as retail,           and deposit-gathering businesses in the
accommodation and transport is                     UK market? Or is it, instead, a sustaining
heightening expectations for convenience           innovation, that does not fundamentally
and immediacy. And consumers are                   change the financial services landscape
increasingly willing to experiment with new        but may instead drive improved
providers, even for services where trust is        performance and pioneer the provision
required. This is creating ideal conditions        of credit into previously under-served
for technology-enabled entrants to                 segments?
challenge the integrated banking model.                                                         Neil Tomlinson
                                                •• what should (and can) banks do to react      Head of UK Banking
Marketplace lenders (MPLs) are leveraging          to the emergence of the MPL model?
all of these trends to attack one of the core
profit-generating activities of commercial
banks: lending. The MPL model is built
around modern technology that enables           Marketplace lenders (MPLs) are leveraging
highly-efficient customer acquisition,
approval and servicing activities within        all of these trends to attack one of
a relatively light-touch regulatory
environment. Most banks’ operating              the core profit-generating activities of
models, by contrast, include legacy IT
expenses, significant regulatory overheads      commercial banks: lending.
and the mature collections and recoveries
function that is needed to service an aged
book.

                                                                                                                                           1
A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte
Marketplace lending | A temporary phenomenon?
Executive summary

                    Executive summary
                    MPLs do not have a sufficiently material source of competitive advantage
                    to threaten banks’ mainstream retail and commercial lending and
                    deposit-gathering businesses in the UK market.

                    Marketplace lenders (MPLs) have recently                  Based on this research, Deloitte draws                     •• our research suggests that most people
                    gained prominence following rapid growth                  the conclusion that MPLs do not have a                        understand that lending money via an
                    in markets like the UK, the US and China.                 sufficiently material source of competitive                   MPL is not comparable to depositing
                    This growth, along with an apparent                       advantage to threaten banks’ mainstream                       money with a bank. This is largely due to
                    investor appetite to provide them with                    retail and commercial lending and deposit-                    the fact that MPL investments are not
                    equity funding and use them to channel                    gathering businesses in the UK market.                        covered by the government’s Financial
                    funds directly into consumer and SME                      Critically, banks should be able to deploy                    Services Compensation Scheme (FSCS)
                    lending, has led some to predict profound                 a structural cost of funds advantage to                       which protects the first £75,000 of
                    disruption of the traditional banking model.              sustainably under-price MPLs if it becomes                    deposits. There may be times in the cycle
                                                                              clear that the threat of lost volumes makes                   where supply constraints in the banking
                    Unlike banks, which take in deposits and                  this the value maximising strategy. Three                     sector make certain areas of marketplace
                    lend to consumers and businesses, MPLs                    key observations underpin this conclusion:                    lending a more attractive asset class. This
                    do not take deposits or lend themselves.                                                                                is unlikely to be an enduring advantage,
                    They take no risk onto their own balance                  •• any operating cost advantage that MPLs                     however, and the capital provided here
                    sheets, and they receive no interest                         may have is insufficient to offset the                     is more likely to be deflected from fixed-
                    income directly from borrowers. Rather,                      banking model’s material cost-of-funds                     income or equity investments rather than
                    they generate income from fees and                           advantage. It is our view that in today’s                  from bank deposits.
                    commissions generated by matching                            credit environment, the cost profiles
                    borrowers with lenders.                                      of banks and MPLs are roughly equal,
                                                                                 meaning neither has a material pricing
                    This paper looks at the potential for MPLs                   advantage. However, Deloitte also
                    to take material share from banks’ core                      believes that banks will have a structural
                    lending and deposit-taking businesses                        cost advantage over MPLs if and when
                    in the UK market. It tests the hypothesis                    the credit environment normalises
                    that, to be truly disruptive, MPLs would
                    need to possess competitive advantages                    •• although borrowers currently value
                    that create real customer value for both                     the benefits of speed and convenience
                    borrowers and lenders that incumbent                         offered by MPLs, these are likely to prove
                    banks cannot counter. As part of this                        temporary as banks replicate successful
                    research, Deloitte commissioned                              innovation in this area. In addition,
                    YouGov to conduct consumer and small-                        Deloitte believes that borrowers who
                    business research, and also spoke to                         are willing to pay a material premium to
                    several UK marketplace lenders, banks                        access loans quickly are in the minority
                    and investment managers. Deloitte
                    also developed a UK ‘MPL opportunity-
                    assessment model’, comparing the lending
                    costs of banks and MPLs, and forecasting
                    the future size of the MPL market.

                    In this publication, ‘we’ and ‘our’ refer to Deloitte LLP, the UK member firm of Deloitte Touche Tohmatsu Limited.

                    2
A temporary phenomenon? - Marketplace lending An analysis of the UK market - Deloitte
Marketplace lending |
                                                                                                                     A temporary phenomenon?

                                                                                                                                                Executive summary
We do not believe that the banking model       So what, if anything, should banks do?
in the UK will be fully disrupted by MPLs.     Our fundamental view is that MPLs do not
Based on our market sizing analysis, MPLs      present an existential threat to banks and,
will not be significant players in terms of    therefore, that banks should view MPLs
overall volume or market share in the UK.      as complementary to the core banking
However, we also do not believe that MPLs      model, not as mainstream competitors.
are a temporary phenomenon. They seem          We therefore believe that banks can, and
likely to become a permanent part of the       should, evaluate a wide range of options
landscape by performing at least two           for enhancing their overall customer
valuable functions:                            proposition by partnering with MPLs.
                                               Options might include:
•• they may provide supply into areas of the
   lending market where banks do not have      •• providing easy access to such platforms
   the risk appetite to participate, such as      for borrowing that is outside a bank’s risk
   high-risk retail borrowers                     appetite

•• while the likelihood of a significant       •• keeping an eye on evolving credit models
   outflow of deposits from the banking
   system does not seem strong, MPLs           •• leveraging MPL technology to enhance
   may offer a low-cost option for certain        the customer experience
   investors to gain direct exposure to new
   asset classes.                              •• utilising elements of the MPL model to
                                                  expand geographically without bearing
                                                  the distribution and regulatory costs of
                                                  the traditional bank model.

                                               We do not believe that the banking model
                                               in the UK will be fully disrupted by MPLs.
                                               However, we also do not believe that
                                               MPLs are a temporary phenomenon.

                                                                                                                                           3
Marketplace lending | A temporary phenomenon?
1. What is marketplace lending?

                                  1. What is marketplace lending?
                                  This section is designed as an introduction         Unlike banks, which take in deposits           This ‘embedded securitisation’ aims to
                                  to what marketplace lending (MPL) is and            and lend to consumers and businesses,          minimise the risk of default by spreading
                                  how the MPL model differs from the banks’           MPLs do not take deposits or lend              lenders’ investments across a large number
                                  traditional lending model. It also provides a       themselves. They therefore take no risk        of borrowers.
                                  snapshot of the state of the MPL market in          onto their balance sheets (see Figure 1).
                                  the US and continental Europe for                   Nor do they have an interest income, but       MPLs generally update the risk-model
                                  comparison with the UK.                             rather generate income from fees and           algorithms that underpin their credit-
                                                                                      commissions received from borrowers and        scoring approach more frequently than
                                  The world’s first MPL, Zopa, was founded            lenders/investors.                             banks do.1
                                  in the UK in 2005. The first MPL in the
                                  US, Prosper, was founded in 2006, and               Investors can select the return they require   In 2014, US$23.7 billion of loans were
                                  the first in China, Paipaidai, was launched         on their investment by specifying maturity     issued through marketplace lending
                                  in 2007. Initially, such platforms enabled          or risk profile (based on an assessment of     platforms globally, concentrated primarily
                                  retail borrowers and investors to contact           the credit risk represented by the platform)   in the US (51 per cent), China (38 per
                                  each other directly, or ‘peer-to-peer’ (P2P).       or through a combination of the two.           cent) and the UK (10 per cent). The total
                                  More recently, institutions have begun                                                             grew at a CAGR of around 120 per cent
                                  investing in bundles of loans, prompting            Most platforms split the money invested by     between 2010 and 2014.2 (Please see the
                                  the sector to be named more accurately as           lenders into smaller ‘tranches’ and lend it    US and European boxes below for more
                                  ‘marketplace lending.’                              on to several borrowers.                       information on the respective markets).

                                  Figure 1. Lending business models, banks vs MPLs

                                                     Traditional bank lending model                                              Marketplace lending (MPL)

                                                                                                                                             Loan
                                                      Saving(s)                    Loan(s)

                                                                                                                                            MPL

                                                     Interest on               Interest and
                                                      saving(s)             loan repayment(s)
                                                                    Bank                                                              (Fees/commissions)
                                      Depositor(s)                                              Borrower(s)     Lender(s)                                            Borrower(s)
                                                                                                                                       Loan repayments

                                      •• Banks act as an intermediary between savers and                       •• Marketplace lenders directly match lenders with borrowers
                                         borrowers. They pay interest on deposits and lend money                  via online platforms
                                         to consumers and businesses
                                                                                                               •• They do not lend themselves, so they do not earn interest
                                      •• They generate income by taking risk onto their balance                   and do not need to hold capital to absorb any losses
                                         sheets and managing spreads between the interest banks
                                         charge on loans and that paid on savings                              •• They make money from fees and commissions from
                                                                                                                  borrowers and lenders
                                      •• This risk-taking requires them to hold capital to absorb
                                         potential losses
                                                                                                               •• MPLs use traditional, bank-like, credit-scoring approaches,
                                      •• Depositors have limited control or visibility over how their             and publicise these credit risk scores
                                         money is used
                                                                                                               •• MPLs offer transparency and control to lenders, such as
                                      •• Banks engage in maturity transformation as the deposits                  through disclosure on recipients of funds lent out
                                         are typically shorter term than the loans, creating a need
                                         for a liquidity buffer.                                               •• Generally, by design, there is no maturity transformation
                                                                                                                  involved.

                                  Source: Deloitte analysis

                                  4
Marketplace lending |
                                                                                                                                A temporary phenomenon?

                                                                                                                                                           1. What is marketplace lending?
An overview of marketplace lending in the US
Current size of the market
It is estimated that marketplace lenders (MPLs) in the US accounted for loan originations worth approximately US$23 billion in 2015 (see
Figure 2). LendingClub, an unsecured consumer lending platform, is the largest MPL in the US and originated US$8.4 billion-worth of loans
in 2015.3 While LendingClub accounts for a significant share of the market, many other players in the US lending marketplace are focused
on a wide range of individual segments, such as student loans.

Figure 2. US MPL annual loan volumes, US$ million, 2011 – 2015*

$25,000                                                                                                                                    CAGR:
                                                                                                                           $22,732         163.3%

$20,000

$15,000

                                                                                                  $10,653
$10,000

                                                                            $4,114
 $5,000
                                                $1,529
                     $473
     $0
                     2011                        2012                        2013                   2014                     2015

   LendingClub       Prosper      SoFi     OnDeck        Avant      Other
Source: Direct Lending: Finding value/minimising risk, Liberum, 20 October 2015, p.6
See also: http://www.liberum.com/media/69233/Liberum-LendIt-Presentation.pdf; Deloitte analysis
* Figures are rounded to the nearest million

Notary model                                             (Since February 2016, WebBank has held an         Partnerships between banks and MPLs are
The widely adopted model for US                          interest in newly-issued loans sold via the       becoming increasingly common in the US.
marketplace lenders is the so-called                     LendingClub platform; in return, LendingClub      BBVA Compass bank, for example, partners
‘notary’ model,4 in which:                               pays a ‘trailing fee’ to the bank.)8              with OnDeck to originate small business
                                                                                                           loans through the platform by referring
•• borrowers apply for a loan on a                       Institutional investors                           customers for smaller loan amounts.12
   marketplace platform                                  Institutions, including hedge funds, private
                                                         equity firms and banks, provide the bulk
•• accepted loan applications are                        of lending through marketplace platforms
   then originated by a partner bank                     in the US.9 Such investors, which are able
   (LendingClub and Prosper use Utah-                    to use due-diligence services offered by
   based WebBank); the MPL performs the                  intermediaries such as Orchard,10 can also
   underwriting of the loans, using criteria             use their own risk models to ‘cherry-pick’
   agreed with the partner bank5                         under-priced loans on the platforms. (The
                                                         Peer-to-Peer Finance Association (P2PFA)
•• platforms purchase the loan from the                  has prohibited this practice to its members
   partner bank6                                         in the UK.)11

•• the platform issues a note to lenders,
   instead of a contract.7

                                                                                                                                                      5
Marketplace lending | A temporary phenomenon?
1. What is marketplace lending?

                                  Other bank partnerships focus on funding,        SEC-registration process, allowing retail      One MPL, SoFi, which offers loans to
                                  i.e. rather than simply referring the loan on    investment through these platforms.            creditworthy students at lower rates than
                                  to an MPL, the bank provides the funding         Securities regulations also prevent retail     the government or traditional lenders, was
                                  themselves. For example, LendingClub and         investors from investing in business loans     the first to receive a triple-A rating for a
                                  Citigroup announced a partnership in April       in the US.15                                   marketplace loan-backed securitisation.18
                                  2015 in which Citigroup provides borrowers                                                      Prosper, too, has securitised US$327
                                  on the platform with funding through the         Furthermore, some state regulations            million of its loans with the participation
                                  Varadero Capital hedge fund, which takes         prevent retail investors who do not meet       of the BlackRock investment management
                                  on the first loss risk. Such arrangements        certain eligibility requirements from          firm.19
                                  allow banks to provide funding to higher-        lending through the platforms. Some
                                  risk individuals or SMEs, while passing          states currently prevent retail investment     What lies ahead?
                                  much of the credit risk on to investors          altogether.16                                  The US market has already witnessed
                                  searching for yield.13                                                                          increased collaboration between banks
                                                                                   Securitisation                                 and marketplace lenders, and Deloitte
                                  Retail investors                                 The development of marketplace lending         expects stronger integration of this sort to
                                  The Securities and Exchange Commission           in the US has been so strong and rapid         take place in the future. Such partnerships
                                  (SEC) views promissory notes14 issued            that there is now demand for securities        will help marketplace lenders to increase
                                  by platforms as debt-backed securities.          backed by marketplace loans, as they have      awareness among borrowers and
                                  Securities regulations prevent retail            become an investment-worthy asset class        investors, gain scale and possibly lower
                                  investors from investing in unregistered         in their own right. This has added liquidity   their customer acquisition costs.
                                  securities, meaning that retail investors        to the market, and may help to lower the
                                  may lend only via platforms that have            cost of funding. There were approximately
                                  registered their promissory notes as             40 MPL securitisations up until Q4 2015,17
                                  securities with the SEC. Both LendingClub        and the market has also seen its first rated
                                  and Prosper have gone through the                securitisations.

                                  The US market has already witnessed
                                  increased collaboration between banks
                                  and marketplace lenders, and Deloitte
                                  expects stronger integration of this sort
                                  to take place in the future.

                                  6
Marketplace lending |
                                                                                                                                  A temporary phenomenon?

                                                                                                                                                              1. What is marketplace lending?
An overview of marketplace lending in                     than in the UK may also have constrained           Germany and France are the largest
continental Europe                                        growth.20 This may explain why MPLs in             MPL markets in Europe after the UK.22
MPLs in continental European markets                      continental Europe originated just €669            In continental Europe, the consumer
have not benefitted from the same                         million in loans in 2015 (see Figure 3),           lending market accounts for the bulk of
government support or regulatory                          while UK marketplace lenders originated            marketplace loans (see Figure 3). The
approach as their counterparts in the UK.                 £2,739 million (€3,513 million21)                  situation is different in the UK, where
A deeper-rooted cultural aversion to risk                 (see Figure 4).                                    both the consumer and business lending
                                                                                                             markets are well developed (see Figure 4).

Figure 3. European MPL annual loan volumes (excluding the UK), € million, 2010 – 2015*

                                                                                                                                             CAGR:
                                                                                                                            €669             87.3%

                                                                                                                                             CAGR:
                                                                                                      €338                  €543             88.2%

                                                                          €165      €174
                                                                                                      €284
                                                                                                 €9
                                                            €65        €3
  €23      €29        €6 €26       €32      €6 €62                                                                                           CAGR:
                                                                                                                            €126
                                                                                                      €54                                    83.8%

          2010                     2011                     2012                     2013             2014                   2015

   MPL business lending        MPL consumer lending
Source: Liberum AltFi Volume Index Continental Europe, AltFi Data, data as of 22 February 2016
See also: http://www.altfi.com/charts/charts/eur-volume_chart.php; Deloitte analysis
*MPL business lending includes invoice trading, figures are rounded to the nearest million

Recent developments in the market                         For example, French consumer MPL Prêt              Aegon, the Dutch insurer, also announced
Currently, there is no pan-European                       D’Union, the largest player in the French          plans in October 2015 to lend €150
regulation that specifically covers                       market, has raised €31 million primarily           million to borrowers through the German
marketplace lending. MPLs are subject                     to expand into Italy.24 UK MPLs are also           consumer MPL, Auxmoney.27
to regulation at a national level. While                  expanding into continental Europe: Funding
many countries do not have MPL-specific                   Circle, for example, has acquired German           As the market gains traction, we believe
regulation in place, some member                          MPL Zencap and launched operations in              that the unclear implications associated
states, including France, have introduced                 Spain and the Netherlands.25                       with the currently limited regulation may
specific regulation covering aspects                                                                         lead to concerns about MPLs potentially
such as disclosure, due diligence and                     The continental European market is also            looking to gain scale through imprudent
the assessment of creditworthiness.23                     following the lead of better-established           business practices and the improper use
Furthermore, the European Commission’s                    markets with the growing involvement of            of client monies. In October 2015, for
Capital Markets Union initiative emphasises               mainstream financial institutions. There           example, the Swedish marketplace lender
the role that MPLs could play in helping                  is an emerging trend for MPLs to partner           TrustBuddy declared bankruptcy28 after the
SMEs diversify their sources of funding.                  with banks. This includes the recent               platform uncovered alleged misconduct
                                                          joint partnership between Sparda-Bank              within the organisation, including misuse
Despite such differences between national                 Berlin and Zencap (now Funding Circle              of lender capital.29 Such developments
regulatory frameworks in Europe, a                        Germany)26 in which the bank provides its          have fed existing fears that the failure or
number of MPLs have sought to expand or                   clients with the MPL platform’s business           impropriety of one platform may tarnish
consolidate across borders in an attempt                  loans as an investment option.                     the entire industry at this early stage of
to achieve the volume required to scale                                                                      development.
their businesses.

                                                                                                                                                          7
Marketplace lending | A temporary phenomenon?
2. Marketplace lending: a disruptive threat or a sustaining innovation?

                                                                          2. M
                                                                              arketplace lending: a disruptive
                                                                             threat or a sustaining innovation?
                                                                          On the surface, marketplace lending looks                  It would appear to position MPLs well to                     According to Deutsche Bank, capital
                                                                          like a quintessential disruptive force, as it              provide a wider base of borrowers with                       markets accounted for more than 80 per
                                                                          embraces such structural effects of the                    faster, more convenient access to credit at                  cent of debt financing for businesses in the
                                                                          digital economy as:                                        a lower price point than is achievable by                    US in Q4 2013, compared to just 20 per
                                                                                                                                     banks, which remain hamstrung by legacy                      cent in Europe.30
                                                                          •• the trend towards growing trust in online               IT infrastructure and an outdated and
                                                                             transactions                                            expensive physical distribution network.                     That is the core of the argument stating
                                                                                                                                                                                                  that the traditional bank lending model
                                                                          •• increasing consumer expectations of                     At the same time, by offering investors                      faces profound disruption, and there is
                                                                             immediacy                                               access to profitable asset classes that had                  some evidence to support it. MPL-based
                                                                                                                                     hitherto been the exclusive preserve of the                  consumer lending in the UK grew at a
                                                                          •• the proliferation of public data (for risk              banks, MPLs appear capable of threatening                    CAGR of 81.2 per cent between 2010
                                                                             scoring).                                               the core deposit-funding base of the banks                   and 2015. SME lending (including invoice
                                                                                                                                     if deposit customers can be attracted to                     trading) via MPLs experienced even faster
                                                                          MPLs appear set to overcome structural                     the higher yields and easy, transparent                      growth, growing at a CAGR of 171.6 per
                                                                          barriers to entry such as banks’ extensive                 access they offer.                                           cent during the same period (see Figure
                                                                          branch networks and privileged access                                                                                   4). Furthermore, the total number of
                                                                          to customers and their data. The use of                    In many ways the situation appears                           active borrowers using UK MPL platforms
                                                                          digital channels, streamlined processing                   analogous to the rapid growth of the                         almost doubled in 2015 alone, rising year-
                                                                          and innovative risk scoring, combined with                 securities markets in the US. This witnessed                 on-year from approximately 140,000 to
                                                                          a model without the compliance costs of                    a dramatic reshaping of financial services                   approximately 275,000, as of Q4 2015.31
                                                                          highly-regulated bank intermediation, is                   as loans and deposits left the core banking
                                                                          certainly advantageous.                                    system, attracted to the solutions offered by
                                                                                                                                     the new ‘technology’ of the capital markets.

                                                                          Figure 4. UK MPL annual loan volumes, £ million, 2010 – 2015*
                                                                                                                                                                                                                                 CAGR:
                                                                                                                                                                                                                £2,739           109.4%

                                                                                                                                                                                                                                 CAGR:
                                                                                                                                                                                                                £1,114           81.2%

                                                                                                                                                                                       £1,534

                                                                                                                                                                                         £568
                                                                                                                                                                                                                                 CAGR:
                                                                                                                                                                £648                                            £1,625           171.6%
                                                                                                                              £125                 £80          £284                     £966
                                                                          £57                  £11 £57                  £34           £205
                                                                                     £68                     £91                                                £364
                                                                                    2010                     2011                      2012                     2013                     2014                     2015

                                                                                   0.05%                                                                                                                          0.96%

                                                                                   0.003%                                                                                                                         0.51%

                                                                              MPL business lending       MPL consumer lending            MPL share of total consumer lending           MPL share of total business lending
                                                                          Source: Liberum AltFi Volume Index, AltFi Data, data as of 26 February 2016
                                                                          See also: http://www.altfi.com/charts/charts/uk-volume_chart.php, Office for Budget Responsibility, Deloitte analysis
                                                                          *MPL business lending includes real estate loans and invoice trading, figures are rounded to the nearest million

                                                                          8
Marketplace lending |
                                                                                                                                                             A temporary phenomenon?

                                                                                                                                                                                                                             2. Marketplace lending: a disruptive threat or a sustaining innovation?
In addition, the amount of direct equity investment in MPL platforms (UK MPLs raised more than US$220 million in equity capital in
201532), and the amount of institutional money being channelled through MPLs into consumer and SME lending, suggest that sophisticated
players are backing this sector to grow significantly.

Figure 5. Estimated aggregate institutional participation in loans originated by Funding Circle, Zopa and RateSetter

                   120                                                                                                                                                     30%
                                                  Loans originated (monthly, £ million) and share of institutionally funded loans (%)                    110.6     111.8
                                                                                                                                         103.4
                                                                                                                                                  98.4

                                                                                                                                                                                 Share of institutionally funded loans
                   100                                                                                                                                                     25%
                                                                                                               88.5              86.1
                                                                                                     84.0                85.9
                    80                                                                                                                                                     20%
Loans originated

                                                                                  71.0      68.4
                                              62.1                       62.7                                                                             84.1     81.2
                                                       57.8     59.1                                                                      80.6
                    60     52.2      53.4                                                                                                                                  15%
                                                                                                                                                  76.9
                                                                                                               71.5      65.5    70.1
                    40
                                                                                                     70.4                                                                  10%
                                              61.9                       56.1     64.5      61.1
                                     53.3              57.4     57.5
                           52.1
                    20                                                                                                                                             30.6    5%
                                                                                                                                          22.8    21.5    26.5
                                                                                                               17.0      20.4
                                                                                                                                 16.0
                            0.1      0.1      0.2       0.4     1.6                         7.3      13.6
                                                                         6.6      6.5
                     0                                                                                                                                                     0%
                           Jan-14 Feb-14 Mar-14 Apr-14 May-14 Jun-14             Jul-14    Aug-14 Sep-14 Oct-14 Nov-14 Dec-14             Jan-15 Feb-15 Mar-15 Apr-15

                   Loans funded by institutions         Loans funded by retail investors           % of loans institutionally funded
Source: Is ‘P2P’ Lending a thing of the past?, AltFi Data, 19 May 2015
See also: http://www.altfi.com/article/1055_is_p2p_lending_a_thing_of_the_past, Deloitte analysis

Finally, any search for a personal loan on key aggregator sites shows the increasing pervasiveness of MPLs. Overall, MPLs look highly
price‑competitive, particularly for lower-value loans (see Figure 6).

Figure 6. UK personal loan annual percentage rates (APRs) for three-year duration loans, MPLs and banks

 35%                                                                                 APRs (%) by loan value

 30%

 25%

 20%

 15%

 10%

        5%

        0%
                                     £1,000                                 £5,000                                    £10,000                            £25,000

                   MPLs      Banks
Source: MPL and bank websites, Uswitch.com, Deloitte analysis. Data as of 23 February 2016

                                                                                                                                                                                                                         9
Marketplace lending | A temporary phenomenon?
2. Marketplace lending: a disruptive threat or a sustaining innovation?

                                                                               The key question is whether the momentum we are currently witnessing could progress to cause a profound disruption
                                                                               of banking (and possibly some elements of asset management), or whether MPLs will turn out instead to be a ‘sustaining
                                                                               innovation’: one that forces incumbents to up their game in core markets and that may pioneer the provision of credit into
                                                                               previously under-served segments, but that does not fundamentally change the financial services landscape.

                                                                          Given that the market-penetration achieved by MPLs is to date still well below one per cent, and that the ability to lead the market for
                                                                          pricing on loans does not necessarily indicate superior or sustainable risk management or cost control, it is worth investigating such broad
                                                                          assertions in detail. Essentially, the case for MPL disruption is built on four potential sources of sustainable competitive advantage:

                                                                                        a fundamentally lower-cost operating model

                                                                                        an ability to use public data to (safely) overcome incumbents’ data advantage in scoring risk, potentially going on to
                                                                                        achieve better risk-pricing by taking a more agile ‘Big Data’-based approach

                                                                                        a superior customer (borrower) experience, driven by speed and convenience

                                                                                        an ability to better absorb and diversify risk by matching the appetite of borrowers and investors for both risk and
                                                                                        duration.

                                                                          The next three sections review these factors to understand whether MPLs constitute a truly disruptive threat to banks. We then use our
                                                                          findings to determine our view on the potential market size of marketplace lending in the UK.

                                                                          10
Marketplace lending |
                                                                                                                                    A temporary phenomenon?

                                                                                                                                                                 3. The relative economics of marketplace lenders vs banks
3. T
    he relative economics of
   marketplace lenders vs banks
Banking has a reputation as an expensive                 Mid-market/SME banking in general has                We have examined the costs incurred in
form of financial intermediation. After all,             proven to be an asset class where the cost           originating and servicing a loan through the
if banks provide the most efficient way to               of securitisation outweighs its value, leaving       traditional bank model with an equivalent
borrow, why would so many of the world’s                 banks as the main source of funding.                 loan originated and serviced through an
largest borrowers rely instead on the                                                                         MPL. This analysis does not compare the
capital markets?                                         So, have MPLs found ways to overcome                 total costs of operating a bank to the total
                                                         these cost barriers and provide a lower              costs of operating an MPL.
However, there have historically been                    potential price-point than the banks at
limits to the scope and reach of the capital             these lower loan values? Below we look
markets. Borrowers need to be of sufficient              at the relative costs of various loan types
scale to justify the investment required                 offered by the traditional bank lending
to gain a credit rating, and must also be                model and the MPL model.33
prepared to disclose the information
necessary for securities to be issued.

Figure 7. Cost economics of illustrative bank and MPL loans
Bank loans, % of loan amount (bps)

                                                   +200 bps              -85 bps
                                                                                         800 bps
                                                                                                                                             720 bps
                                    +200 bps

                    +270 bps                                                                                     460 bps

   +215 bps

Loan operating      Deposits         Funding           Loan             Fees,    Total – Unsecured            Total – Retail            Total – Unsecured
   expenses        operating          costs           losses        commissions personal loan              buy-to-let mortgage              SME loan
                   expenses                                       and other income

MPL loans, % of loan amount (bps)

                                                               +45 bps             815 bps
                                        +500 bps
                                                                                                                                            715 bps

                                                                                                             500 bps

                        +90 bps
    +180 bps

    Operating Operating expenses Loan funding             Platform         Total – Unsecured              Total – Retail               Total – Unsecured
     expenses     attributable to costs (ie. return     funding costs        personal loan                 buy-to-let                      SME loan
  attributable to     lenders       to lenders)                                                            mortgage
    borrowers

Source: Deloitte analysis

                                                                                                                                                            11
Marketplace lending | A temporary phenomenon?
3. The relative economics of marketplace lenders vs banks

                                                            Whether or not MPLs have a pricing                         The costs of loan-making include the direct       It will also incur marketing costs, lender-
                                                            advantage over banks depends primarily                     costs of funding and liquidity (such as the       processing and servicing costs and other
                                                            on three factors: the cost of funds;                       interest rates, yields and returns payable        non-interest expenses. In addition, the
                                                            operating expenses; and how they price                     on these funding sources). Furthermore,           platform itself must be funded, and the
                                                            risk. While operating expenses of MPLs                     attracting and retaining deposits involves        MPL must be able to pay a return to its own
                                                            are most commonly compared with                            more than just paying interest: banks must        investors. Unlike a bank, however, an MPL
                                                            those of banks, we believe that a holistic                 also provide payment and processing               does not need to incur the costs associated
                                                            comparison including funding costs is                      services; most must also run a branch             with offering current accounts, such as
                                                            necessary to reach an accurate assessment                  network; and they will incur significant          providing payment services and running a
                                                            of the two models’ relative economics.                     regulatory and marketing costs and other          branch network.
                                                                                                                       non-interest expenses. The true cost of
                                                            Cost of funds                                              attracting the funds to the bank must take        In Figure 8, we examine these ‘fully-
                                                            For banks and MPLs alike, funding costs                    account of these non interest-based costs         loaded’ costs, comparing the total costs
                                                            are a major component of a loan’s total                    of gathering deposits.34                          of attracting funds into banks versus the
                                                            cost profile. To make a true comparison                                                                      costs faced by MPLs. Two observations are
                                                            between the expenses incurred by each                      However, borrowing via a bank may give            key. First, the total funding costs for banks
                                                            type of institution, we have examined the                  the borrower access to a wider range of           are lower than for MPLs. Second, the non-
                                                            respective costs of attracting the funds                   services, such as international payment           interest component of an MPL’s funding
                                                            they require to participate in the loan-                   systems, which are not part of the MPL            profile is proportionately lower than it
                                                            making process.                                            service offering. Banks may be able to            is for a bank. We therefore believe that
                                                                                                                       generate income from these services and           MPLs’ costs will rise by more than banks’
                                                            For a bank to make a loan, it must first                   the borrower may see value in “one-stop-          as the credit environment normalises and
                                                            attract deposits, wholesale funding and                    shopping”.                                        interest rates increase. Figure 8 illustrates
                                                            equity onto its balance sheet and must                                                                       this point, using a scenario where base
                                                            maintain liquidity reserves to meet the                    For an MPL to make a loan, it must attract        rates have returned to 200 bps, and credit
                                                            needs of its customers.                                    lenders. Clearly this involves offering           spreads are at pre-crisis levels, to show the
                                                                                                                       returns that outweigh the risks that lenders      estimated increase in these ‘fully-loaded’
                                                                                                                       are prepared to take on.                          funding costs.

                                                            Figure 8. Costs of funding an unsecured personal loan: banks and MPLs, current and normalised credit environments
                                                            Bank loan, % of loan amount (bps)                                                  MPL loan, % of loan amount (bps)
                                                                                                                                                                                                      Total cost of
                                                                                                                                                                                                    attracting funds:
                                                                                                                                                                               total increase:           795 bps
                                                                                                                                                       Total cost of                25%
                                                                                                                                                     attracting funds:                                   90 bps
                                                                                                                       Total cost of
                                                                                                                     attracting funds:                    635 bps                                        55 bps
                                                                       Total cost of
                                                                     attracting funds:       total increase:              530 bps                                               not interest
                                                                                                  13%                                                       90 bps             rate sensitive
                                                                          470 bps
                                                                                                                                                            45 bps
                                                                                               not interest
                                                                                                                         270 bps
                                                                                              rate sensitive
                                                                           270 bps                                                                                              interest rate            650 bps
                                                                                                                                                                                  sensitive
                                                                                                                         70 bps                            500 bps
                                                                            50 bps                                       65 bps
                                                                                              interest rate
                                                                            60 bps              sensitive
                                                                            90 bps                                       125 bps

                                                                       Current credit                            Normalised credit                      Current credit                             Normalised credit
                                                                       environment                                 environment                          environment                                  environment

                                                                          Equity         Wholesale                                                        Returns to lenders        Returns to platform investors
                                                                          Deposits       Deposits processing costs                                        Operating expenses attributed to lenders

                                                            Source: Deloitte analysis

                                                            12
Marketplace lending |
                                                                                                                                                                                                                                                                                                                                       A temporary phenomenon?

                                                                                                                                                                                                                                                                                                                                                                                                                                                         3. The relative economics of marketplace lenders vs banks
To look at this another way, consider
that banks are able to borrow very
                                                                                                                                                      a significant proportion of their balance
                                                                                                                                                      sheets by taking current-account deposits                                                                                                                   For these reasons,
cheaply – taking deposits gives them
inexpensive access to funding. This is a
                                                                                                                                                      that are inherently less sensitive to changes
                                                                                                                                                      in base rates than other sources of funding,                                                                                                                we believe that banks
structural benefit enabled both by their
unique regulatory position (with deposits
                                                                                                                                                      such as term deposits (see Figure 9). For
                                                                                                                                                      these reasons, we believe that banks will                                                                                                                   will have a structural
underwritten by the protection scheme/
government) and by their ownership of
                                                                                                                                                      have a structural cost advantage over
                                                                                                                                                      MPLs if and when the credit environment                                                                                                                     cost advantage over
the payments infrastructure. Banks fund                                                                                                               normalises.
                                                                                                                                                                                                                                                                                                                  MPLs if and when the
                                                                                                                                                                                                                                                                                                                  credit environment
Figure 9. Bank deposit interest rates in a normal credit environment, percentages
                                                                                                                                                                                                                                                                                                                  normalises.
8%

7%

6%

5%

4%

3%

2%

1%

0%
                                                                                                                                                                                                                                                                                                                                                                                                                   1-Jan-07
      1-Jan-95

                                                                                                                                                                                                                                                                    1-Sep-02
                                                                                                                                                                                                                                                                               1-Jan-03
                                                                                                                                                                                                                                                                                          1-May-03
                                                                                                                                                                                                                                                                                                     1-Sep-03
                                                                                                                                                                                                                                                                                                                1-Jan-04
                                                                                                                                                                                                                                                                                                                           1-May-04
                                                                                                                                                                                                                                                                                                                                      1-Sep-04
                                                                                                                                                                                                                                                                                                                                                 1-Jan-05
                                                                                                                                                                                                                                                                                                                                                            1-May-05
                                                                                                                                                                                                                                                                                                                                                                       1-Sep-05
                                                                                                                                                                                                                                                                                                                                                                                  1-Jan-06
                                                                                                                                                                                                                                                                                                                                                                                             1-May-06
                                                                                                                                                                                                                                                                                                                                                                                                        1-Sep-06

                                                                                                                                                                                                                                                                                                                                                                                                                              1-May-07
                                                                                                                                                                                                                                                                                                                                                                                                                                         1-Sep-07
                 1-May-95
                            1-Sep-95
                                       1-Jan-96
                                                  1-May-96
                                                             1-Sep-96
                                                                        1-Jan-97
                                                                                   1-May-97
                                                                                              1-Sep-97
                                                                                                          1-Jan-98
                                                                                                                     1-May-98
                                                                                                                                1-Sep-98
                                                                                                                                           1-Jan-99
                                                                                                                                                      1-May-99
                                                                                                                                                                 1-Sep-99
                                                                                                                                                                            1-Jan-00
                                                                                                                                                                                       1-May-00
                                                                                                                                                                                                  1-Sep-00
                                                                                                                                                                                                             1-Jan-01
                                                                                                                                                                                                                        1-May-01
                                                                                                                                                                                                                                   1-Sep-01
                                                                                                                                                                                                                                              1-Jan-02
                                                                                                                                                                                                                                                         1-May-02

     Base rate                               Term deposits                                               Instant access deposits                                                        Current accounts
Source: Bank of England, Deloitte analysis

Operating expenses                                                                                                                                    Figure 10. Operating expenses of an unsecured personal loan, banks and MPLs
In this section, we compare the operating
                                                                                                                                                                                                                                                             Unsecured personal loan, % of loan amount (bps)
costs incurred by banks and MPLs by
examining the structural advantages for
                                                                                                                                                                                                                 215 bps
each model in making and servicing loans
(considering the operating costs associated                                                                                                                                                                                                                                                                                                                 180 bps
                                                                                                                                                                                                                   50 bps
with lending activities alone).35
                                                                                                                                                                                                                                                                                                                                                            40 bps

                                                                                                                                                                                                                                                                                                                                                            45 bps
                                                                                                                                                                                                                 115 bps

                                                                                                                                                                                                                                                                                                                                                            95 bps
                                                                                                                                                                                                                   50 bps

                                                                                                                                                                                                                        Bank                                                                                                                                  MPL

                                                                                                                                                                 Loan acquisition costs                                                   Loan processing and servicing costs                                                                               Loan collections and recovery costs
                                                                                                                                                      Source: Deloitte analysis

                                                                                                                                                                                                                                                                                                                                                                                                                                                    13
Marketplace lending | A temporary phenomenon?
3. The relative economics of marketplace lenders vs banks

                                                            Customer awareness of marketplace                        One in 25 retail consumers who are aware      MPLs are now aiming to leverage these
                                                            lenders in the UK                                        of MPLs, meanwhile, has borrowed from         high awareness figures to improve their
                                                            According to the survey we commissioned                  one. Similarly, one in 20 retail consumers    conversion rates. One way of achieving
                                                            as part of this research, there is a                     who are aware of MPLs has lent through        this is to form industry bodies to educate
                                                            reasonable awareness of MPLs among                       one (see Figure 11).                          consumers. UK MPLs have formed the
                                                            retail consumers and SMEs in Britain. Just                                                             P2PFA, representing the majority of the
                                                            over half of consumers and three-quarters                Among SMEs, one in 25 that are aware of       UK MPL market across all segments,36 to
                                                            of SMEs are aware of MPLs.                               MPLs has borrowed from an MPL and around      promote their nascent industry.
                                                                                                                     one in 30 that have heard of MPLs has lent
                                                                                                                     through such a platform (see Figure 12).

                                                            Figure 11. Awareness and usage of MPLs, retail consumers

                                                                                                            Aware?                       Aware of specific MPLs?                       Used?

                                                                                                              53%                                                                       4%
                                                                                                             aware                                                                   borrowed

                                                                                                                                                  53%
                                                                                                                                                 aware
                                                                                                                                                                                         5%
                                                                                                                                                                                        lent
                                                                 MPLs

                                                                                                                                                 47%
                                                                                                                                               not aware
                                                                                                                                                                                        91%
                                                                                                                                                                                      not used

                                                                                                            47%
                                                                                                          not aware

                                                            Source: YouGov plc 2016 © All rights reserved, Deloitte analysis
                                                            Base: All GB adults (nationally representative), 2,090
                                                            See appendix for survey questions

                                                            14
Marketplace lending |
                                                                                                                                    A temporary phenomenon?

                                                                                                                                                                    3. The relative economics of marketplace lenders vs banks
Figure 12. Awareness and usage of MPLs, SMEs

                                                Aware?                            Aware of specific MPLs?                           Used?

                                                  76%                                                                                4%
                                                 aware                                                                            borrowed

                                                                                            61%
                                                                                           aware
                                                                                                                                      3%
                                                                                                                                     lent
    MPLs

                                                                                           39%
                                                                                         not aware
                                                                                                                                    94%
                                                                                                                                  not used

                                                 24%
                                               not aware

Source: YouGov plc 2016 © All rights reserved, Deloitte analysis
Base: All SME senior decision makers (nationally representative), 1,609
See appendix for survey questions

MPLs have used a wide variety of marketing methods to drive awareness. As MPLs are innovative, digital platforms, it is interesting to
note that traditional media (TV and radio advertising in particular) represent by far the greatest source of awareness. And while early
growth in the industry is often attributed to word-of-mouth, such recommendations are not a key source of awareness at this stage
(see Figure 13).

Figure 13. Sources of awareness of MPLs, retail consumers

                                                                                                                          Traditional media
Traditional media                       29%                                   17%                    10%      4%   60%       Television or radio advertising
                                                                                                                             Magazine/newspaper article
                                                                                                                             Television or radio programme
    Digital media          11%            8%          7%       26%                                                           (not including advertising)
                                                                                                                             Print advertising

Recommendation        5%    3% 8%                                                                                         Digital media
                                                                                                                             Online advertising
      Don't know                                                                                                             (excluding social media)
      /can’t recall          16%                                                                                             Social media
                                                                                                                             Online blog

            Other       9%
                                                                                                                          Recommendation
                                                                                                                             Recommendation from
                                                                                                                             a friend/colleague
                                                                                                                             Recommendation from
                                                                                                                             a financial advisor/bank
Source: YouGov plc 2016 © All rights reserved, Deloitte analysis
Base: All GB adults aware of one or more of the above peer-to-peer lenders (nationally representative), 588
See appendix for survey questions
                                                                                                                                                               15
Marketplace lending | A temporary phenomenon?
3. The relative economics of marketplace lenders vs banks

                                                            Acquisition                                       Such search terms, in fact, make up 11         Processing/servicing
                                                            Unlike MPLs, banks tend to have large             of the top 20 most expensive Google            Unlike in the customer-acquisition area,
                                                            existing customer bases and the ability           AdWords in the UK.39 As MPLs seek to           MPLs have a potential advantage in
                                                            to drive awareness via above-the-line             compete both with the banks and with one       processing/servicing thanks to their ability
                                                            advertising across a wide product portfolio.      another in mainstream lending, it therefore    to design from scratch purely online
                                                            While it seems likely that these attributes       appears likely that search engines or price-   channels to handle the loans on-boarding
                                                            give them a material advantage in                 comparison sites will end up with much of      and servicing processes.
                                                            acquiring new personal and SME loans, our         the value.
                                                            research in this area suggests that MPLs                                                         A fully automated process for processing
                                                            already have a surprisingly good level of         The other analogy is with the credit card      and underwriting loans allows MPLs to
                                                            awareness: one in two retail consumers (53        market, where over the last 25 years or        avoid the material costs that banks have to
                                                            per cent) and three in four SMEs (76 per          so banks have faced intense competition        deal with as a result of their legacy systems
                                                            cent) are aware that they exist37 (see the        from non-bank monolines seeking to break       and multiple channels. This also holds true
                                                            ‘customer awareness’ box). Conversion is          the relationship between the primary           for servicing where a surprising number
                                                            currently relatively low: only one in 25 retail   current account and credit products. While     of banks have, for example, no automated
                                                            consumers who are aware of MPLs has               these credit specialists have had some         scoring systems for SME overdrafts –
                                                            actually borrowed from one. However, the          success, even after this period of sustained   this results in a significant proportion of
                                                            ability of MPLs to spread their message via       competition around a third of active           relationship managers’ time being taken up
                                                            new digital channels, to use their speedy         credit card holders in the UK still have a     in renewing overdrafts.
                                                            processes to encourage purchase, and              current account with the same bank that
                                                            to leverage their structurally-advantaged         issued their card.40 The task facing MPLs      As highly regulated entities, banks also
                                                            risk appetite (see ‘credit risk’ below) points    is therefore significant, particularly given   incur significant costs, both in ensuring
                                                            to the potential they have to negate the          that the relationship between the primary      compliance and in redressing any breaches.
                                                            banks’ advantages. Two analogies, however,        current account and loans is even tighter.     For the time being at least, MPLs can avoid
                                                            provide a counterpoint to this optimistic         (For example, almost 90 per cent of SME        much of this burden (see the ‘Regulation –
                                                            view of MPL’s acquisition costs.                  loans are extended to existing holders of      friend or foe?’ box on page 18).
                                                                                                              business current accounts.) 41
                                                            The first is the escalation of acquisition
                                                            costs among online price-comparison sites
                                                            in the UK. Here, a marketing ‘arms race’ has
                                                            pushed above-the-line advertising spend
                                                            to a remarkable level, with the largest four
                                                            UK price comparison sites spending more
                                                            than £100 million a year.38 Similarly, the
                                                            competition among these sites has pushed
                                                            the price of financial services-related
                                                            keywords to levels where loans sourced
                                                            through these channels are believed to be
                                                            breakeven at best.

                                                            16
3. The relative economics of marketplace lenders vs banks

                                                            17
Marketplace lending | A temporary phenomenon?
3. The relative economics of marketplace lenders vs banks

                                                            Regulation – friend or foe?                      •• dispute resolution rules – investors have     1. Investor funds are not guaranteed
                                                            Before 2013, MPLs were subject to little            the right to complain, firstly to the MPL     MPL investors do not have access to the
                                                            or no regulation, with none at all being            and, if the dispute remains unresolved, to    Financial Services Compensation Scheme
                                                            tailored to the MPL model. The UK Financial         the Financial Ombudsman Service.              (FSCS), which protects the first £75,000 of
                                                            Conduct Authority (FCA) had the stated              “The rules for dispute resolution do not      deposits; this is because the money lent is
                                                            aim of providing “adequate consumer                 mandate specific processes, so long           not classified as a ‘deposit’.
                                                            protections that do not create too many             as complaints are dealt with fairly and
                                                            barriers to entry or significant regulatory         promptly”45                                   Second, some MPL platforms have
                                                            burdens for firms”.42 The FCA operates                                                            established their own ‘provision funds’ to
                                                            a disclosure-based regime, designed                                                               help investors recover lost monies in the
                                                                                                             •• if an MPL goes out of business, it must
                                                            to advance its objectives of supporting                                                           event of borrower default. However, no
                                                                                                                take “reasonable steps … to ensure loan
                                                            effective competition and an appropriate                                                          MPL platform guarantees that a provision
                                                                                                                agreements facilitated on the platform
                                                            degree of protection for consumers.                                                               fund will make investors ‘whole’ (enable
                                                                                                                will continue to be managed and
                                                                                                                                                              them to receive all their money) after
                                                                                                                administered with the contract terms, if
                                                            The current FCA MPL regulation consists of:                                                       borrowers have defaulted. There is a risk
                                                                                                                the firm ceases to carry on the regulated
                                                                                                                                                              that investors will misunderstand such
                                                            •• capital requirements – before 1 April            activity in relation to lending”46
                                                                                                                                                              funds as a guarantee that their investment
                                                               2017, marketplace lenders with FCA
                                                                                                                                                              is safe, when their role is simply to mitigate
                                                               authorisation must hold the following in
                                                                                                             •• conduct – MPLs must “ensure that              possible losses.
                                                               regulatory capital:
                                                                                                                investors have the information they need
                                                             –– a minimum of £20,000                            to be able to make informed investment        2. Liquidity risk
                                                                                                                decisions and that all communications         Investors on MPL platforms may not realise
                                                             –– 0.2 per cent of the first £50 million of
                                                                                                                are fair, clear and not misleading.”47 (For   that they are usually ‘locked in’ to their
                                                                total loans outstanding, 0.15 per cent
                                                                                                                further information, see conduct risk         investments until they mature. (While some
                                                                of the next £200 million, 0.1 per cent of
                                                                                                                section below.)                               MPLs have a secondary market in which
                                                                the next £250 million, 0.05 per cent of
                                                                                                                                                              investors can cash in their investments
                                                                the remaining balance.
                                                                                                             Conduct risk                                     before maturity, such markets are currently
                                                                                                             The FCA has defined conduct risk as “the         underdeveloped.)
                                                            This will increase from 1 April 2017 to
                                                                                                             risk that firm behaviour will result in poor
                                                            whichever is the higher of:
                                                                                                             outcomes for customers.”48

                                                             –– a minimum of £50,000
                                                                                                             The FCA expects MPLs to manage conduct
                                                             –– 0.3 per cent of the first £50 million,       risk by looking at their business models
                                                                0.2 per cent of the next £450 million,       and strategic plans to ensure that they are
                                                                and 0.1 per cent of all money lent above     identifying, mitigating and monitoring all
                                                                £500 million.43                              the risks to consumers arising from them.
                                                                                                             The FCA is clear that all firms, including
                                                            •• client money protection rules – MPLs
                                                                                                             MPLs, need to accord equal significance
                                                               holding client money are subject to Client
                                                                                                             to customer outcomes as to commercial
                                                               Assets Sourcebook (CASS) rules requiring
                                                                                                             objectives.
                                                               firms “to ensure adequate protection of
                                                               client money when the firm is responsible
                                                                                                             Deloitte believes that five key conduct risk
                                                               for it”44
                                                                                                             considerations relate equally to lenders/
                                                                                                             investors and borrowers:

                                                            18
Marketplace lending |
                                                                                                                                           A temporary phenomenon?

                                                                                                                                                                       3. The relative economics of marketplace lenders vs banks
3. Investor understanding                                  4. Credit risk and the potential for                       UK regulation – outlook
Deloitte’s consumer survey shows that                      financial loss                                             MPLs have a favourable view of the
the general population has a good                          Most MPLs assign a credit risk score or                    current size and scope of regulation.
understanding of the risks involved                        particular pricing to a loan. Investors face               They believe the regulation is not overly
in lending through MPLs. However, a                        the risk that such scoring is inaccurate or                onerous, particularly in terms of capital
significant minority (see Figure 14) believes              that such pricing does not truly reflect the               requirements, allowing them to maintain
that savings accounts and government                       credit risk exposure.                                      one of their key competitive advantages
bonds are riskier than investing through                                                                              over banks. This light-touch regime also
MPLs.                                                      5. Treatment of borrowers                                  allows MPLs to concentrate on growth
                                                           Borrowers participating in marketplace                     and innovation rather than regulatory
This suggests that the industry has                        lending are also exposed to conduct risks,                 compliance.
not yet attained the levels of customer                    which principally include loan affordability,
understanding that the FCA is looking for.                 treatment of customers in financial                        However, as MPLs grow and become
                                                           difficulty and clarity of information before,              more important to the financial system,
Firms that fail to comply with the                         during and after the point of sale.                        they are likely to become more tightly
FCA’s disclosure regime are at risk of                                                                                regulated, with higher capital-adequacy
enforcement action by the FCA, but this is a                                                                          ratios, limitations to business models and
punitive tool after the event, rather than                                                                            more prescriptive disclosure requirements.
a preventative one.                                                                                                   This could erode the favourable regulatory
                                                                                                                      arbitrage MPLs currently have over banks,
                                                                                                                      and cause them to refocus their efforts less
                                                                                                                      single-mindedly on growth and innovation.

Figure 14. Risk of lending through an MPL platform compared to other savings/investment options, retail consumers

     Savings account                                 63%                                     8%      10%           19%

 Government bonds                               54%                                    11%    9%                26%

    Corporate bonds                     40%                               18%           9%                  34%

               Stocks                 34%                              25%                   19%                  22%

       Other securities
                                    27%                       23%                 13%                      36%
(e.g. futures, options)

   MPLs are more risky        About the same        MPLs are less risky       Don’t know
Source: YouGov plc 2016 © All rights reserved, Deloitte analysis
Base: All GB adults aware of peer-to-peer lenders (nationally representative), 1,168
See appendix for survey questions
Approximately one in five retail consumers believes lending through MPLs is as risky or less risky than savings account or
government bonds

                                                                                                                                                                  19
Marketplace lending | A temporary phenomenon?
3. The relative economics of marketplace lenders vs banks

                                                            There are questions over the sustainability
                                                            of MPLs’ advantage in the area of
                                                                                                                   Credit risk
                                                                                                                   Overall, our research gives us limited          Overall, our
                                                            operating costs. Banks do appear to be
                                                            disadvantaged for the time being, however,
                                                                                                                   grounds to believe that MPLs will
                                                                                                                   systematically price risk better in areas       research gives us
                                                            and their ability to address this in the near
                                                            future is hamstrung by a series of factors,
                                                                                                                   where banks have an appetite to play.
                                                                                                                                                                   limited grounds to
                                                            which also constrain their ability to improve
                                                            customer experience. Factors include:
                                                                                                                   Supporters of MPLs point to a number
                                                                                                                   of potential areas of advantage over the        believe that MPLs
                                                            •• their ability to attract the right talent
                                                                                                                   traditional bank model, including:
                                                                                                                                                                   will systematically
                                                            •• their ability to prioritise investment in an
                                                                                                                   •• a willingness (in part born of necessity)
                                                                                                                      to experiment with a wider set of data       price risk better in
                                                               environment that is still dominated by
                                                               post-crisis regulatory change
                                                                                                                      sources for risk scoring
                                                                                                                                                                   areas where banks
                                                            •• an understandably cautious culture.
                                                                                                                   •• a more agile approach to developing and
                                                                                                                      evolving a more agile core risk-scoring      have an appetite
                                                            Collections and recoveries
                                                                                                                      algorithm.
                                                                                                                                                                   to play.
                                                            Our research suggests that at maturity,                As further evidence that innovative
                                                            when MPLs’ loan portfolios are likely to               approaches are working and will improve
                                                            more closely resemble those of the market              over time, these supporters also point to
                                                            as a whole, MPLs will have no material                 the current quoted loss rates of MPLs,
                                                            source of cost advantage over banks                    which look no worse than typical bank loss
                                                            relating to collections and recoveries.                rates (see Figure 15). However, the majority
                                                            And while MPLs may pass the costs of                   of UK MPLs are yet to go through a credit
                                                            collections and recoveries on to lenders,              cycle, and it therefore remains to be seen if
                                                            this will over time simply increase the                there will be an increase in default rates in
                                                            required return and the cost of funds.                 the event of an economic downturn.

                                                            Figure 15. MPL default rates, 2010-2015*

                                                              6%

                                                              5%

                                                              4%

                                                              3%

                                                              2%

                                                              1%

                                                              0%
                                                                          2010                2011               2012              2013              2014          2015E

                                                                 Funding Circle      RateSetter       Zopa       MarketInvoice     Sector average
                                                            Source: MPL websites, Deloitte analysis
                                                            *2015 figures are estimated default rates from MPL websites

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Marketplace lending |
                                                                                                                     A temporary phenomenon?

                                                                                                                                                3. The relative economics of marketplace lenders vs banks
However, while some of the risk
professionals and other market
                                               Relative economics of MPLs vs banks:
                                               our conclusion                                   Our analysis
participants we interviewed acknowledged
that a better risk-scoring algorithm might
                                               Our analysis shows that banks have a
                                               structural cost advantage over MPLs.             shows that banks
be developed outside the banking system,
all cautioned that it is too early to tell
                                               While MPLs may enjoy slightly lower
                                               operating costs, a bank’s broad cost             have a structural
whether or not this has happened. And,
if it is does happen, the consensus was
                                               profile is less sensitive to changing interest
                                               rates than that of an equivalent MPL. This       cost advantage
that this was unlikely to be the result of a
systematic advantage of the MPL model;
                                               advantage is not particularly evident in
                                               the current credit environment, with rates       over MPLs.
rather, it would be a specific, model-         at historically low levels. However, if and
agnostic, innovation. In other words,          when the credit environment normalises
banks could exploit the same algorithmic       and rates and spreads return to pre-crisis
innovations. All also commented on the         levels, we expect that the costs incurred
fact that, in the short-term at least, MPLs    in MPL credit transmission will increase by
cannot replicate banks’ core advantage         more than those of bank lending.
of having access to customers’ historical
transactional data.                            For these reasons, we do not believe that
                                               MPLs pose a disruptive threat to banks
That said, provided that loans behave          in terms of relative economics. Banks
broadly as predicted over time, the ability    currently have a pricing parity with MPLs;
to use the brokerage model to match            this will become a pricing advantage in
borrowers and lenders by risk appetite,        a normalised interest rate environment.
coupled with the diversification achieved by   Our market-sizing assessment, therefore,
pooling invested money and lending it out      does not foresee a shift in lending from
to several borrowers, does seem likely to      banks to MPLs owing to a structural pricing
support an inherently wider risk appetite.     advantage.
In turn, the resulting wider coverage of
businesses or individuals eligible for loans   For MPLs to be a disruptive threat, they
may potentially deliver higher acceptance      would need to achieve at least one of the
rates and so reduce the effective cost of      following:
customer acquisition.
                                               •• offer a superior customer experience,
                                                  potentially by expanding their offering
                                                  to include ancillary services such as
                                                  cashflow tools and business advice, for
                                                  which customers would be willing to pay
                                                  a premium

                                               •• undermine banks’ funding advantage by
                                                  drawing funds away from deposits into
                                                  marketplace lending.

                                                                                                                                          21
Marketplace lending | A temporary phenomenon?

MPLs have been
able to differentiate
themselves by offering
an attractive customer
experience.

22
Marketplace lending |
                                                                                                                                     A temporary phenomenon?

                                                                                                                                                                  4. The user experience of marketplace lenders vs banks
4. T
    he user experience of marketplace
   lenders vs banks
As part of our research, Deloitte conducted a YouGov survey of retail consumers and SMEs. The results provide strong evidence
that MPLs have been able to differentiate themselves by offering an attractive customer experience at acceptable lending rates
(see Figure 16 below).49

Figure 16. Drivers behind usage of MPLs to borrow money, retail consumers

                Easy/quick application process                                                                  81%
                          Fast decision-making                                                          72%
                Convenience of online platform                                                          72%
                             Competitive rates                                                         69%
                          Repayment flexibility                                             55%
                 Little documentation required                                             53%
             Trying out a new way of borrowing                               39%
                   Less personal data required                             35%
           Couldn't get a loan/credit elsewhere                          30%
       Recommendation from friend/colleague                     22%
                              Distrust of banks               18%
Recommendation from banker/financial advisor               12%

Source: YouGov plc 2016 © All rights reserved, Deloitte analysis
Base: All GB adults who have borrowed via a peer-to-peer lending platform (non-nationally representative), 89
See appendix for survey questions

This is backed up by the views expressed                 2. if banks choose to flex the pricing                 •• a relatively risk-averse approach to
by the UK MPLs, banks and investment                        advantage we believe they have, how                    innovation
managers we interviewed as part of the                      many customers will be willing to trade
research. According to our interviewees,                    UX against price?                                   •• a limited appetite for investment,
borrowers are primarily drawn to MPLs                                                                              particularly given the competing claims
due to:                                                  It is clear that replicating this experience, or          on such funds.
                                                         even substantially closing the gap, requires
•• the certainty of outcome for a loan                   more than just overlaying a slick digital              As a result, Deloitte believes that this
   application enabled by a fast decision-               interface onto existing processes.                     non‑cost advantage is likely to endure for
   making process                                                                                               some time.
                                                         It ultimately requires taking a far more
•• the small amount of documentation that                customer-centric approach to product                   Turning to the second question, our work
   borrowers need to provide as part of a                and proposition innovation, accordingly                in the sector suggests that while there are
   loan application.                                     re-engineering and automating processes                cases where time is critical, a customer’s
                                                         deep in the bank’s operating model.                    willingness to trade off UX against rate
These advantages largely arise from MPLs’                Deloitte’s work with major institutions trying         ultimately (and unsurprisingly) tends to
customer-driven focus on user experience                 to do this has given us a healthy respect for          correlate with the absolute difference in
(UX) as a source of differentiation. Two                 just how hard it is for most banks to achieve          interest cost between the two alternatives.
questions arise:                                         this level of change. In our experience, a             We have reflected this in arriving at our
                                                         number of factors may prevent banks from               assessment of where and to what extent
1.    ow sustainable is this UX advantage?
     h                                                   quickly doing so, including:                           MPLs will win in the market.
     (Surely banks can easily copy user
     journeys that are seen to work and                  •• cultural and capability limitations
     then leverage their broader customer
     relationships and data to deliver a                 •• the current regulatory environment
     distinctive experience that trumps
     what MPLs have to offer?)

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