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The Investment Lawyer Covering Legal and Regulatory Issues of Asset Management The Investment Lawyer Covering Legal and Regulatory Issues of Asset Management VOL. 23, NO. 5 • MAY 2016 Considerations for Investment Managers Considering Acquiring Portfolios of Online or Marketplace Loans By Edward T. Dartley and Anthony R. G. Nolan arketplace and online lending has a small operational expenses associated with traditional but growing share of the US and global bank loans to consumers, such as the cost of main- Mlending market. Online loans to consumers taining and staffi ng physical branches. Cost reduc- and small businesses represent a growing asset class tion, in turn, makes relatively minor loans to small for investment managers seeking non-correlated businesses and individuals economically feasible for high returns in a low-yield environment. all parties involved. Online lending marketplace Th is article will provide an overview of impor- platforms use proprietary algorithms and models to tant considerations for investment advisers and assign a risk grade to the proposed borrowers and investment fund managers seeking to understand set an interest rate corresponding to the assigned how marketplace loans as an asset class can fi t into risk grade and the tenor of the loan. an investment strategy and which issues must be Marketplace lending (or online lending) is classi- considered when investing in marketplace loans, cally regarded as the process of connecting borrowers including regulatory compliance and disclosure and lenders without using banks. Th e classic concept risks. is being stretched as the online lending industry con- tinues to evolve and mature. One example of this Overview of the Online and development can be seen in the evolution of fund- Marketplace Lending Industry ing sources. Having started with a business model derived from crowdfunding, many online lending What is Marketplace Lending? platforms have increasingly come to rely on balance Th e US Treasury Department defi nes “mar- sheet funding in addition to marketplace funding ketplace lending” as “the segment of the fi nancial techniques. Additionally, the classic peer-to-peer services industry that uses investment capital and model of marketplace funding has been supplanted data-driven online platforms to lend to small busi- by fl ow purchases of assets in bulk as institutional nesses and consumers[.]”1 Online lending market- investors have become more prominent—so much places use technology to drive a simple and speedy so that the industry has shifted away from call- matching of borrowers and lenders. Th ese internet- ing itself “peer-to-peer” to “marketplace lending,” based platforms reduce costs by eliminating many “online lending,” or “direct lending.” Copyright © 2016 by CCH Incorporated. All Rights Reserved. 2 THE INVESTMENT LAWYER Th e impact of regulation is another area where institutions and credit funds accessing fi nancial the classic defi nition is subject to change. Emerging assets through fl ow purchase agreements with online as a largely-unregulated lending source that would lending marketplaces. compete with banks by relying on big data analy- Securitization of marketplace loans provides sis more than classic credit underwriting, the online investors with liquidity, diversifi ed funding and lending industry has seen growing convergence with interest rate arbitrage opportunities. Securitized more traditional lending. One such area of con- marketplace loans have the attributes of a fi xed- vergence is seen in the growing sensitivity to clas- income security with a relatively low default risk. sic consumer fi nancial services regulation and other Marketplace loans are both suitable and desirable types of regulation, such as anti-money laundering for securitizations for a number of reasons. Th ey are considerations. a highly homogenous asset class with low borrower Another area of convergence between online concentration and a steady fl ow of new originations. lending and traditional fi nance is seen in the growth Th ey have relatively high risk-adjusted interest rates of partnerships between online lending platforms and have thus far enjoyed relatively low default rates. and deposit-taking institutions. Th ese have taken Th ey pay a predictable stream of principal and inter- many forms, including acquisitions of platforms by est payments over a relatively short three- or fi ve-year banks, white label arrangements, and targeted invest- time horizon. Also, a marketplace loan securitization ments by banks through funding vehicles, either for does not raise particularly complex tax issues (unless regulatory compliance purposes or with strategic it is backed by mortgage loans). goals in mind. Th is convergence may be acceler- ated as online lending platforms seek to enhance the Online Loan Origination role of originating banks in underwriting and servic- and Monetization Processes ing loans in order to obtain the benefi ts of federal While there are variations, online loan genera- preemption of certain state laws such as those gov- tion typically follows a similar process. An online erning usury. lending marketplace will host its own website on which prospective borrowers can apply for loans. Why Invest in Marketplace Loans? In some cases the website might be maintained in Online lending marketplaces provide individual conjunction with a bank that partners with the lend- and institutional investors an opportunity to earn ing platform. When a prospective borrower requests attractive risk-adjusted returns through equal access a loan he or she will complete a loan application, to standard program loans off ered through the online the information from which is used by the market- lending marketplace. Th e platform typically permits place platform to obtain a credit report and evaluate investors to tailor or modify their own portfolios by whether the prospective borrower meets the under- utilizing specifi c investment criteria, such as credit writing criteria established in conjunction with the attributes, fi nancial data and loan characteristics. entity originating and funding the loan. Th e platforms use proprietary credit algorithms to Th e marketplace sponsor will use its own credit approve loans and help investors construct loan algorithms to assign a risk grade to the prospective portfolios and model targeted returns. Th e busi- borrower and proposed loan to determine whether ness model began as a peer-to-peer marketplace that such prospective borrower and proposed loan meet permitted borrowers to use a web-based platform the lending standards of the online lending market- to borrow money from other platform users. More place or platform. If a borrower qualifi es, the online recently marketplace lending has become a more lending marketplace will approve the loan on a institutional market, with a wide variety of fi nancial preliminary basis and will disseminate information Copyright © 2016 by CCH Incorporated. All Rights Reserved. VOL. 23, NO. 5 • MAY 2016 3 about the loan to potential investors, each of whom lending marketplace’s fi nancial suitability require- may determine to fund all or part of the loan. ments and the eligibility requirements under the If there is suffi cient investor interest in funding Securities Act of 1933 (the Securities Act) and that a marketplace loan, the marketplace platform spon- have established an account with the platform. When sor either originates the loan directly or through an the marketplace sponsor issues and sells Marketplace affi liated licensed lending company or bank, or alter- Platform Notes to an investor, the notes are registered natively sends the loan application to a third-party in the name of the investor on the marketplace spon- bank with which it has a relationship. Th at bank sor’s books and records. Th e Marketplace Platform then acts as the lender of record, originating the loan Notes are special, limited obligations of the online and selling and assigning the promissory notes evi- lending marketplace issuer and pay through obliga- dencing the loans to the online lending marketplace tions that are dependent on payments received by sponsor. the marketplace platform on the underlying loans. Th e relationship between the lending platform Th e issuer’s obligation to make payments on a and the originating bank is typically governed by a Marketplace Platform Note is limited to an amount loan account program agreement. Th is document equal to the note holder’s pro rata share of amounts it sets forth the framework under which the market- receives with respect to the corresponding borrower place sponsor manages the operations of the lend- loan, net of servicing fees. Marketplace Platform ing marketplace that relate to the submission of Notes typically bear interest from the date of issu- loan applications, as well as the originating and ance, have a fi xed rate, are payable monthly, and funding of loans by the bank in exchange for a fee have an initial maturity of three or fi ve years from equal to the origination fee charged by the bank. issuance. A note holder’s recourse is generally very Additionally, the marketplace lending platform will limited in the event that borrower information is enter into a loan sale agreement, under which the inaccurate for any reason, or if the borrower defaults. bank sells and assigns the promissory notes evidenc- Investors in Marketplace Platform Notes are also ing the loans to the marketplace sponsor. As consid- subject to ongoing credit and insolvency risk of the eration for the bank’s agreement to sell and assign platform, including
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