TERMS AND CONDITIONS

(Effective from and including 16 January 2018)

1. ABOUT THIS AGREEMENT 1.1 About us:

this agreement is made by Shelbourne Financial Solutions Limited, a company registered in Northern Ireland under NI633778 and whose registered office is at 67-69 Hill Street, Newry, Co Down, BT34 1DG (“Shelbourne Financial Solutions”, “we”, “us”, “our”). 1.2 Regulatory information: We have the following authorisations and registrations: 1.2.1 authorised and regulated by the Financial Conduct Authority under the Payment Services Regulations 2009 for the provision of payment services with reference number 757069; 1.2.2 a registered money services business with HM Revenue and Customs No. 12841161. 1.3 Our Services: We provide foreign exchange and international payment services (“Services”) to our corporate and personal clients (“Client”, “you”, “your”). 1.4 About these terms: These terms and conditions (“Terms”) explain how you can place an Order for our Services and set out the terms and conditions which will apply to any Contract that is made between us as a result of our acceptance of your Order.

Your attention is particularly drawn to the following:

● The key information and risks of using our Services (see clause 3).

● Cancellation rights (see clause 8).

● We have limitations on our liability to you (see clause 16).

● You are liable to us for any breach of these terms and conditions (see clause 17).

● Our obligations and liability to you under the Payment Services Regulations (if applicable) (see clause 19).

● Your right to take any complaint you may have to the Financial Ombudsman (see clause 20). 1.5 When you place an Order, you will be required to read, and accept these Terms. You agree that if you use our Services you will be taken to have agreed to these Terms. If you do not agree to these Terms, you should not place an Order with us. We recommend that 1 you print a copy of them for your future reference. Capitalised terms are defined in clause 23. 1.6 These Terms will apply to all Contracts between you and us however you access our Services (including through our Website or through any mobile device application).

2. CHANGES TO THESE TERMS 2.1

Changes to these Terms: We may need to change these Terms from time to time to: 2.1.1 comply with law or regulations; 2.1.2 reflect changing market conditions; or 2.1.3 meet our changing business requirements. 2.2 Notice of changes: We will give you advanced notice of such changes and will post them on our Website so that you can view them when you next log in. 2.3 Changes required by law: We may make changes without your specific agreement only where those changes are required to comply with law or regulations. 2.4 Date changes are effective: Changes will only apply to Contracts entered into on or after the date upon which the changes become effective. However, the changes will also apply to Contracts entered into before such date if required by law or regulatory requirements. 2.5 Your agreement to the changes: By placing an Order after the new terms are effective, you agree to be bound by the new terms. If you object to the changes, you should not place any further Orders with us. 2.6 Changes requested by the Client: Changes to these Terms requested by a Client will only be effective if agreed to by us in writing.

3. KEY INFORMATION AND RISKS 3.1

No financial advice: In providing our Services, we do not provide you with any investment advice including any guidance on the merits of a particular Order or its likely implications, nor can we advise on or recommend to the Client any investment products. To the extent that we provide you with any advice, it will relate only to the mechanics of the transaction you are proposing to enter into or to publicly available information. 3.2 No liability for currency fluctuation: The foreign currency market is volatile and outside of our control. We will not be liable to you for any loss or damage which arises as a result of any currency fluctuation between the Deal Confirmation and the Value Date. You agree that in placing an Order, you have relied purely on your own judgement and you have not relied on anything not expressly contained within these Terms.

4. PRIVACY POLICY 4.1

Your information: We understand that the privacy of your personal information (and that of your Authorised Persons) is important and we will not share it with anyone else for their use in any marketing or promotional campaign. 4.2 Our privacy policy: Any personal information you provide to us (in any capacity) via our Website, over the telephone or otherwise may be collected, stored, processed and used in accordance with our Privacy Policy. By continuing to use our Services you consent to such use of your personal information. 5. REGISTRATION AND ELIGIBILITY

5.1 Registration:

Before Shelbourne Financial Solutions can provide any Services to you, you must register for an account on our Website or you can complete a paper registration form available from us on request. You are permitted to open one Personal and one Business account only. 5.2 Proof of ID: We mwill carry out an electronic verification of your identity. You may also need to provide us with evidence of your identity and proof of address so that we can complete our anti-money laundering process, together with any other information we may request. 5.3 Re-registration: If you do not use our Services for 12 months, you may need to re-register before we can perform any further Services for you. 5.4 Eligibility: To be eligible to register for and use our Services, you (or in the case of a corporate Client, your Authorised Persons) must: 5.4.1 be 18 years of age; and 5.4.2 not be suffering from any disability or impairment which may affect your capacity to enter into a Contract (or the Authorised Person’s capacity to enter into a Contract on the Client’s behalf). 5.5 Accuracy of your information: You are solely responsible for ensuring that the information you give to us is and remains true and accurate. You agree to inform us of any changes to such information either by changing your Client Profile online or by written notice to us. 5.6 Password security: It is your responsibility to keep safe and secure any passwords or other security devices used to access our Website or Services. You must notify us immediately of any actual or suspected loss or compromise of any of them.

6. PLACING AN ORDER 6.1

Placing orders: Once registered, you can place an Order by telephone, email, or through our Website. However, we may require written confirmation of any Order (or other Client instruction) at any time. An Order received from an email address in your Client Profile or through your account on our Website will be deemed to have been sent by you. The Contract will become binding in accordance with clause 7. 6.2 Non-reliance: You agree that in placing an Order, you have relied purely on your own judgement and you have not relied on anything not expressly contained within these Terms. 6.3 Own account: Orders will only be accepted from a Client acting on its own account and not from a person acting for or on behalf of, or as agent for, a third party (except Authorised Persons).

7. ACCEPTANCE OF AN ORDER 7.1

Online: If you place an Order through our Website, the following process applies: An acknowledgment will appear on screen and sent via email at the time the order is placed online, which confirms that we have received your request to place an order. Deal confirmation will be sent via email once the order has been processed. The Contract will be legally binding on you when we provide you with the Deal Confirmation. 7.2 Email: If you place an Order by email, the Contract will be binding on you when we process your email. You acknowledge that, if you place an Order by email, it may not be processed immediately. When we process your Order, we will send you a Deal Confirmation by email. 7.3 Telephone: If you place an Order by telephone, the Contract will be legally binding at the conclusion of the telephone call. We will send you a Deal Confirmation by email. If there is any discrepancy between the Deal Confirmation and the details of the Contract that have already been agreed in the telephone conversation, you must contact us within 24 hours of receipt of the Deal Confirmation, failing which the details in the Deal Confirmation will be deemed to be correct. In the event of any dispute, the transcript of our telephone conversation may be used as evidence as to the terms of the Contract that was entered into. 7.4 Separate Contracts: Each Deal Confirmation issued by us to you will amount to a separate Contract for an individual payment transaction between us which is subject to these Terms. 7.5 No obligation to accept Orders: While we will endeavour to comply with your requests for Services, there may be circumstances in which we are unable to do so. Therefore, we always reserve the right to refuse to accept your Orders and to do so without giving you any reasons and without incurring any liability to you for any resulting loss or damages incurred by you or any other party. 7.6 Out-of-Market Quotes: If we quote you a rate or Purchase Price that is clearly a mistake on our part as the result of a technical or human error, it is not binding on us. You must notify us as soon as the mistake comes to your attention and we will re-quote as soon as possible 8.

CANCELLING AN ORDER OR CONTRACT 8.1

Cancellation before acceptance: You are free to cancel an Order at any time before we have accepted it and it becomes legally binding. 8.2 Cancellation after acceptance: Once an Order has been accepted and becomes legally binding you do not have the right to cancel or terminate a Contract except in accordance with clause 8.3 below. 8.3 Payment: failure to make payment for an accepted order within five working days could lead to a cancellation of the contract, potentially causing cancellation

fees to be payable, and your account being Suspended until the cancellation fee is paid 8.4 Cancellation at our discretion: We may at our discretion accept cancellation requests. However, this may be subject to cancellation fees which will be communicated to you before cancellation is accepted. 8.5 Refund: If we accept your cancellation of an Order, we will refund you the funds transferred to us for the purposes of the Order less any applicable cancellation or administration fees applicable at the time the refund is made. 8.6 Cancellation rights at law: Additional cancellation rights may apply to Contracts which are subject to the Payment Services Regulations (see clause 19 for further details). 9.

AUTHORISED PERSONS 9.1

Individual Clients: For private individual Clients, we will only accept Orders placed or instructions given by the Client, unless the Client has a Joint Account with us, in which case the provisions relating to Joint Accounts at clause 10 will apply. The following provisions of this clause 9 will apply to corporate Clients only. 9.2 Corporate Clients: For corporate Clients, we will only accept Orders placed or instructions given by an Authorised Person. 9.3 Authorised Persons: At the time of registration, you are required to supply us with the name and contact details of all personnel within your business whom have authority to act on your behalf in connection with our Services. Such personnel will become Authorised Persons when they have been accepted as Authorised Persons by us. 9.4 Authority of an Authorised Person: We will treat each Authorised Person as having authority from the Client to instruct us in respect of all matters relating to the Services unless you notify us that an Authorised Person is to have a more limited scope of authority. 9.5 Removal of an Authorised Person: You may remove an Authorised Person or change the registered contact details or scope of authority of an existing Authorised Person by updating your Client Profile or sending written notice of the change to us.

10. JOINT ACCOUNTS 10.1

Responsibility of joint account holders: A registration may be made by two private individuals jointly (“Joint Account”). Each Joint Account holder will be (both together and separately) responsible for the performance of all obligations of the Client under these Terms and each Contract. 10.2 Joint account holders under these Terms: All references in these Terms to “the Client”, “you” or “your” shall be to both Joint Account holders except that: 10.2.1 each individual Joint Account holder has authority to place Orders, enter into Contracts and provide instructions to us on behalf of both Joint Account holders; and 10.2.2 any notice or other communication which we are required to give pursuant to these Terms will be treated as properly given if it is given to only one of the Joint Account holders.

11. FORWARD CONTRACTS 11.1

Forward Contract: If we accept an Order from you where the Value Date is later than two Business Days after the date of the Order, this Order will become a Forward Contract. 11.2 Margin: A deposit, which is calculated as a percentage of the Purchase Price, will be agreed at the point of placing the Order and confirmed in the Deal Confirmation (“Margin”). You will immediately pay the Margin into Our Account on the date of the Deal Confirmation. You will pay any outstanding balance of the Purchase Price into Our Account no later than one Business Day before the Value Date. 11.3 Margin Call: We have the right to request further deposits from you in the event of exchange rate fluctuations at any time prior to full settlement of the Forward Contract (“Margin Call”). If we make a Margin Call, you must pay the additional deposit to us within 24 hours. 11.4 Termination of Forward Contract: You agree that the Margin and any Margin Call may be retained by us if the Forward Contract is terminated for reasons attributable to you. You also agree that we will not return any profits made as a result of terminating the contract

12. YOUR OBLIGATIONS 12.1

You agree to: 12.1.1 provide complete and accurate sort code and account number information or for international payments IBAN number for the Recipient of the funds and you acknowledge that the funds will be transmitted to the account details submitted by you; 12.1.2 examine all confirmations and communications sent by us within a reasonable time after receiving them and to promptly advise us of any mistake or discrepancy; 12.1.3 on request, supply us with all the information and documentation necessary to enable us to comply with all applicable laws and regulations, including the Money Laundering Regulations 2007. For corporate Clients, this might include proof of your registered office, principal business address, confirmation of beneficial ownership, access to corporate documentation (such as Memorandum and Articles of Association) and proof of identity of any director and/or Authorised Person. For private individuals this might include proof of identity and residential address; 12.1.4 on request, supply us with complete and accurate details about the Recipient (if different from the Client) including, as applicable, date of birth, name and address details, passport number and any other information required by our banking partners; 12.1.5 promptly update us about any changes to your details held by us; 12.1.6 not use, and to procure that your Authorised Persons do not use, our Services for any speculative purpose or to try to profit from exchange rate fluctuations; and 12.1.7 transfer the Purchase Price to Our Account promptly on or after receipt of the Deal Confirmation. We will send you one or more reminder emails if we have not received the Purchase Price to Our Account within two Business Days. If we receive no response or payment from you within five Business Days from the date the order was approved, then we may terminate the Contract in accordance with clause 15.

If you fail to honour an order by not transferring your payment in full to our bank account, you could be charged a cancellation fee and your account will be locked until the cancellation fee is paid.

13. FEES 13.1

You may be required to pay service, transaction and/or administration fees for our Services (“Fee”). If a Fee is payable, we will notify you of the Fee as follows: 13.1.1 Online: if you place an Order through our Website, on the screen; 13.1.2 Email Orders: by email prior to us processing your Order; 13.1.3 Telephone Orders: during the telephone call. You will be given the opportunity to confirm your Order after we have notified you of the Fee and prior to the Contract becoming binding on you.

14. PAYMENT 14.1

Spot Contracts: You will pay the Purchase Price under a Spot Contract in full into Our Account on such date or dates as we may direct, but no later than by 12 midnight on the second Business Day after the date of the Deal Confirmation. 14.2 Payments: All payments due from you to us pursuant to a Contract must be made into Our Account in the currency specified in the Deal Confirmation without set-off, counterclaim or deduction whatsoever. We will not accept cash or cheques. 14.3 Cut-off times: Banks have specified cut-off times for the receipt and dispatch of electronic payments. You acknowledge and agree that any delay in onward payment attributable to the cut-off times of the designated bank shall be a Disruption Event. 14.4 Use of funds: All funds provided by you (whether as security or otherwise) to us may be used by us to settle any liability incurred on your behalf or exposure to an increased market risk (as we may decide in our sole discretion in respect of any Contract) or in the event that you are unable to pay your debts or you fail to comply with these Terms or any provision of a Contract. 14.5 Dishonoured payments: If your payment is dishonoured or stopped for whatever reason, we shall charge an administration fee. The administration fee will be payable by the Client in addition to the amount due under the Contract. The administration fee will reflect any additional costs or fees incurred by Shelbourne Financial Solutions. 14.6 Bank charges: You will be solely responsible for any charges applied by your bank or the Recipient’s bank resulting from the receipt of funds into Your Nominated Bank Account. 14.7 Interest on outstanding balance: If you fail to make a payment in full or in part, the outstanding balance shall bear interest from the Value Date at the rate of 4 per cent per annum above the base rate of the Bank of England. Such interest / charges will accrue from the due date until Shelbourne Financial Solutions are in receipt of settlement in full, in clear funds by the Client. 14.8 No interest payable on funds held by us: You acknowledge and agree that we will not pay to you any interest on any funds held by us whether by way of deposit or otherwise.

15. TERMINATION OF A CONTRACT 15.1

Our right to terminate: We may terminate all or part of any Contract without giving prior notice or any liability to you at any time after the occurrence of any of the following events: 15.1.1 the Client fails to comply with any of its obligations under these Terms or a Contract (including its obligation to pay the Purchase Price, Margin or any other sums to us); 15.1.2 the Client fails to provide any information or documentation requested by us as part of our regulatory obligations; 15.1.3 where the Client is an individual, the death of the Client; 15.1.4 it becomes or may become unlawful for us to provide our Services to you under the Contract; 15.1.5 we are requested to terminate the Contract (or any part thereof) by any regulatory authority, whether or not the request is legally binding; 15.1.6 you are unable to pay your debts as they become due or you have a bankruptcy position presented against you, or you propose a form of composition or

arrangement to your creditors, or if you cease or threaten to cease to carry on all or a part of your business; or 15.1.7 where any of the events specified above, or anything analogous there to, occurs under the laws of any applicable jurisdiction. 15.2 Notice of an event: If you become aware of the occurrence of any event referred to in this clause 15, you must give us immediate written notice of such event. 15.3 No Payment of Profit: We will not pay you any profit arising from terminating a Contract in any circumstances. 15.4 Your right to terminate You will have the right to terminate all or part of any Contract without giving prior notice or any liability to us at any time if we commit a serious breach of our obligations under these Terms or a Contract or we are unable to pay our debts as they become due or we have a bankruptcy position presented against us, or we propose a form of composition or arrangement to our creditors, or if we cease or threaten to cease to carry on all or a part of our business.

16. OUR LIABILITY TO YOU 16.1

No liability for delays: You acknowledge that delays in the transmission and receipt of payments may occur. In particular, you acknowledge that we operate an online dealing platform that could be subject to technical, or other, problems, the nature and duration of which may be beyond our control. Our Services also involve the use of intermediaries who are outside our control. Accordingly, while we do everything in our power to ensure the timely transmission of funds, we cannot guarantee that transfers of funds will always be made on time and cannot accept any liability to you for any loss suffered by you or any other person as a result of any delays in the transmission of funds. 16.2 Exclusions of certain types of loss: We are not liable, whether in contract, tort (including negligence) or otherwise in connection with these Terms or any Contract for any: 16.2.1 indirect or consequential loss or damage; 16.2.2 loss of business, loss of opportunity, loss of profits or contracts or loss of interest on funds; 16.2.3 loss of damage caused as a result of inaccurate or misleading information provided to us by the Client or an Authorised Person; 16.2.4 loss or damage caused by an Authorised Person providing us with instructions which are against the Client’s interests or outside of the scope of the Client’s actual authority; or 16.2.5 loss or damage caused by our refusal to accept an Order. 16.3 Maximum liability: Our total liability in connection with our performance or contemplated performance of the Contract is limited to the amount of the Purchase Price. 16.4 Liability not excluded: Nothing in these Terms shall exclude or limit our liability for death or personal injury or fraud or fraudulent misrepresentation.

17. YOUR LIABILITY TO US 17.1

You shall be liable to us and repay us for any loss or damage suffered by us as a result of your (or an Authorised Person’s) breach of these Terms or any Contract, or fraudulent use of our Services. This includes any legal costs that we may incur in order to enforce our rights or recover any amounts you owe us.

18. DISRUPTION EVENT 18.1

No liability in case of the Disruption Event: Neither party will breach these Terms or any Contract nor be liable for delay in performing or failure to perform any of its obligations under any Contract if such delay or failure results from a Disruption Event for the period of time during which the Disruption Event continues. We will if necessary contact you as soon as reasonably possible to notify you of a Disruption Event which has resulted in our delay or failure to perform any of our obligations under a Contract. 18.2 Right of termination for long term Disruption Event: If the period of delay or non-performance continues for twenty-eight Business Days then you or we may terminate any Contract made between us by giving five Business Days written notice to the other party.

19. THE PAYMENT SERVICES REGULATIONS 2009 19.1

Where the Payments Services Regulations apply: This clause 19 is relevant and applicable to any Contract in respect of which: 19.1.1 the destination of the funds and the Recipient are located within the EEA; and 19.1.2 the funds transferred are either in Euro, Sterling or a currency of another European Economic Area (“EEA”) state that has not adopted the Euro as its currency.

The EEA comprises all member states of the European Union, together with Norway, Iceland and Lichtenstein. 19.2 If there is any conflict between any provision of this clause 19 and any other provision of these Terms, the provision of this clause 19 will prevail and apply. 19.3 More information on the Payment Services Regulations can be found on the website of the Financial Conduct Authority (FCA).

19.4 Provision of Information: We will provide certain information to the Client prior to entering into a Contract which we are required to provide under the Regulations. For example, we will provide our address and contact details, information regarding our payment services and how they are provided and details of our charges and exchange rates.

19.5 We will communicate this information either over the phone or in writing (through our online ordering process, by letter or by email). If we communicate this information over the phone, we will confirm it by email. We will also provide the information to you in paper or in a downloadable format, if you request it. 19.6 Receipt of an order and time for payment: Pursuant to a Contract, we will agree with you that execution of the payment is to take place either: 19.6.1 on a specific day;

19.6.2 on the last day of a certain period; or 19.6.3 the day on which the payer puts funds at your disposal, and the time of receipt of your payment order is deemed to be that day or the next Business Day if this falls on a non-Business Day. This date is referred to in these Terms as the Value Date. 19.7 Once an Order is completed, we will not retain the proceeds unduly and will send them to the Recipient, Your Nominated Account or otherwise return them to you.

19.8 The payment will be credited to the Recipient’s bank account on or before: 19.8.1 the end of the Business Day following the Value Date for payment transactions except those initiated-on paper; and 19.8.2 the end of the second Business Day following the Value Date for payment transactions initiated on paper.

19.9 For further protection, Shelbourne Financial Solutions may also take steps to safeguard Client monies consistent with our obligations under the Regulations. Further information on the steps Shelbourne Financial Solutions take can be found by contacting us by email to info@shelbourne financial.com or writing to Chief Operating Officer at Shelbourne Financial Solutions.

19.10 Placing an Order: By placing an Order through the order process described in these Terms, you acknowledge that you are authorising us to make the payment in accordance with the terms of the Contract that is formed.

19.11 Cancellation: If you have placed an Order under a Spot Contract, Forward Contract, Limit Order or our Regular Payments Service which has been accepted, you may cancel or terminate the Contract at any point up to the end of the Business Day preceding the Value Date by notifying us by telephone, post, email, or through our Website and no charges will apply.

19.12 Refusal to accept an Order: If we refuse to accept an Order or to complete a payment under a Contract, we will notify you of the refusal and, if possible, the reasons for such refusal together with the procedure for rectifying any factual errors that led to the refusal by the end of the Business Day following the day that we received the Order.

19.13 Regular Payments Service: In a Contract for our Regular Payments Service unless it is otherwise unlawful, we can only refuse to make one or more of the payments required under such Contract where the following conditions are met: 19.13.1 one of the grounds for terminating the Contract specified at clause 15.1 has arisen; or 19.13.2 if there is a Disruption Event.

19.14 Our liability for incorrect, unauthorised or defective payments: You must notify us without undue delay (and in any event within 13 months of the payment date) if we make any unauthorised or incorrect payment of your funds.

19.15 We will then immediately investigate your claim and notify you of the outcome. If, following our investigation, we reasonably consider that the payment was in fact authorised and made correctly, we will provide evidence of this to you.

19.16 However, if we discover that the payment was not authorised and/or was made incorrectly, we will immediately refund the amount of the unauthorised or incorrect payment to you and reimburse you for any charges or interest for which you become liable as a result of the unauthorised or incorrect payment provided that we will not be liable if you notify us of the error more than 13 months of the payment date.

19.17 If you notify us that a payment which is due has not been correctly made, we will make immediate efforts to trace the payment transaction and notify you of the outcome. If we are unable to prove that the payment has been made to the Recipient within the timeframe specified in the Contract, we will repay you the Purchase Price (or the part of the Purchase Price if the payment is only partially defective) and reimburse you for any charges or interest for which you become liable as a result of the defective payment. 19.18 We will not be liable to you for an allegedly incorrect, unauthorised or defective payment if you provide us with incorrect or incomplete: 19.18.1 Sort code and/or account number for payments to a UK bank account;

or 19.18.2 The IBAN number for international payments, however, we will make reasonable efforts to recover the funds provided that you pay any costs we reasonably incur in doing so.

19.19 We will not be liable to you for any (allegedly or actual) incorrect, unauthorised or defective payment or for any other failure under Part 6 of the Payment Services Regulations where this is attributable to: 19.19.1 abnormal and unforeseeable circumstances beyond our control, the consequences of which would have been unavoidable despite all efforts to the contrary; or 19.19.2 our other legal obligations imposed by national or EU law, and clause 18 shall not apply to such failure.

19.20 Your liability: You are liable to us: 19.20.1 up to a maximum of £50 for each instance of fraud; and 19.20.2 for all unauthorised transactions if you act fraudulently.

19.21 Changes to Contracts: If your Contract is for our Regular Payments Service: 19.21.1 we will notify you in writing (either by email or post) of any proposed changes to these Terms and the Contract at least two months before the changes are to take effect. However, we may apply a change in exchange rate that is based on a change to a reference exchange rate or is more favourable to the customer immediately and without notice provided that this change is applied in a non-discriminatory manner;

19.21.2 such changes will come into effect provided you do not notify us that you are opposed to the change before the date specified; 19.21.3 you will be deemed to have accepted the changes, unless you notify us otherwise; and 19.21.4 you and we have the right to terminate the Contract immediately, and without charge, before the proposed date of the change.

19.22 Termination of Contracts: In addition to the termination rights set out at clause 15, if your Contract is for our Regular Payments Service: 19.22.1 you may terminate the Contract by giving one month’s notice to us provided that you will be liable to pay and costs incurred by us which result from your termination; and 19.22.2 we may terminate the Contract by giving two months’ notice to you.

20. COMPLAINTS 20.1

We aim to provide the highest level of customer service possible.

If you do experience a problem, we will always seek to resolve this as quickly and efficiently as possible. You can request a copy of our complaints procedure by emailing support@shelbournefinancial.com or by writing to Shelbourne Financial at 67-69 Hill Street, Newry, Co Down, BT34 1DG. 20.2 In the unlikely event that you are dissatisfied with any of our Services, in the first instance, in accordance with our complaint procedures, you should inform us of the complaint as soon as you can in writing.

Where the initial complaint is verbal it must be followed up immediately with a written complaint to the Complaints Manager at at 67-69 Hill Street, Newry, Co Down, BT34 1DG. 20.3 If you are dissatisfied with our response you may refer the matter to the Financial Ombudsman Service situated at South Quay, 183 Marsh Wall, London, E14 9SR.

21. NOTICES 21.1

Where any notice is required by our Terms to be given in writing, it must be written in the English language and: 21.1.1 where it is to be given by the Client, it must be sent by email to info@shelbournefinancial.com or by post to 67-69 Hill Street, Newry, Co Down, BT34 1DG; or 21.1.2 where it is to be given by Shelbourne Financial Solutions, it must be sent by email to your registered email address or by post to you registered postal address. 21.2 Any notice sent by email will be treated as being received on the first Business Day after the day on which it was sent and any notice sent by post will be treated as being received on the second Business Day after the day on which it was posted.

22. GENERAL 22.1

Interpretation: Any words following the terms including, include, in particular, for example or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

22.2 Third party rights: No third party has the right to any benefit under or to enforce any Contract. The Contract (Rights of Third Parties) Act 1999 shall not apply to the agreement.

22.3 Relationship: Nothing in these Terms and no Contract will create a partnership, joint venture or agency relationship between the parties.

22.4 Continuance after termination: Clauses 15 (Our Liability to You), 16 (Your Liability to Us), 18 (Payment Services Regulations 2009) and 21 (General) will continue to be valid upon termination of any Order or Contract.

22.5 Entire agreement: The Deal Confirmation of a Contract and these Terms form the entire agreement and understanding between us and you concerning that Contract. No other discussions, telephone conversations, email communications, documents or materials form part of the Contract.

22.6 Severance: Should any of our Terms be deemed unenforceable or illegal, the remaining terms and conditions will nevertheless continue in full force and effect.

22.7 Assignment: You may not assign or otherwise transfer the benefit of any Contract without our express written consent. We may assign our rights and obligations under any Contract to any third party.

22.8 Conflict: Should any of our Terms conflict with the Deal Confirmation, the Deal Confirmation will take precedence and apply.

22.9 Language: These Terms, and any Contract between us, are only in the English language.

22.10 Governing law: These Terms and the Contract will be governed and construed in accordance with English Law and the courts of England and Wales will have exclusive jurisdiction to determine any dispute arising in relation to them.

23. DEFINITIONS

Authorised Person means an individual who is authorised by you and accepted by us to place Orders and provide instructions on your behalf. Business Day means 8am to 6pm Monday to Friday excluding Bank Holidays and Public Holidays in England (please note that this is different to our office hours, details of which are published on our Website). Client means the customer, being the private individual or company, which registers for our Services and/or with whom we enter a Contract.

Client Profile means the personal and other information provided by you when registering for an account with us, including your contact details which may be updated by logging in to your account through our Website. Contract means the contract between the Client and Shelbourne Financial Solutions for the performance of an Order.

Deal Confirmation means a written document which sets out the details of the contract between Shelbourne Financial Solutions and the Client. Disruption Event means any circumstances outside of a party’s control including any interruptions or failures relating to Service Providers or other third parties, internet service providers, internet signal, connections, electricity providers, failure of banks or banking systems, configurations of computers, any acts of god, flood, drought, earthquake or other natural disaster, any collapse of buildings, fire, explosion or accident, any act of terrorism, civil war or commotion, riots or any law or any action taken by a government or public authority, including failing to grant a necessary licence or consent.

Forward Contract means a Contract for a currency transaction where the Value Date is later than two Business Days after the Order date. Joint Account means a registration made by two private individuals jointly. Limit Order means a Contract comprising the buying or selling of a currency at a predetermined exchange rate which is above or below the current currency exchange rate. Margin has the meaning given to it at clause 11.2. Margin Call has the meaning given to it at clause 11.3.

Order means your verbal or written request for us to perform Services on your behalf. Our Account means the bank account specified in the Deal Confirmation into which you must pay any sums due to us under a Contract. Payment Services Regulations means the Payment Services Regulations 2009 (SI 2009 No. 209). Purchase Price means the sums payable by you to us for the currency purchased under a Contract together with any fees and costs payable under the Contract.

Recipient means the beneficiary of the money transfer specified in the Deal Confirmation, which may be the Client or a third party. Regular Payments Service means an arrangement where the Client instructs us to carry out a series of separate Spot Contracts or Forward Contracts on their behalf, for example where the Client wishes to set up regular monthly payments.

Services means our services which comprise of (i) entering into contracts for the purchase and sale of currency on behalf of our Clients; and (ii) our money transmission service. Service Provider means a bank, cash pick up office, money exchange house or other third party providing cash or electronic funds transfer or electronic payment to a Recipient.

Spot Contract means a Contract for a currency transaction where the Value Date is two Business Days after the date of the Deal Confirmation. Terms means these terms and conditions. Value Date means the date on which the currency is due to be transferred to the Recipient. Website means Shelbourne Financial Solutions ’s website at www.shelbournefinancial.com. Shelbourne Financial Solutions, we, us, our means Shelbourne Financial Solutions Limited, a company registered in Northern Ireland under NI633778 and whose registered office is at 67-69 Hill Street, Newry, Co Down, BT34 1DG. Your Nominated Account means the Recipient’s bank account details as specified in your Order and confirmed in the Deal Confirmation.

PPI mis-selling checklist

If you can answer ‘no’ to one or more of the following questions, then you may have been mis-sold PPI.

If the insurance was optional, was that made clear to you?

Did the adviser tell you about any significant exclusions under the policy – for example, the exclusion that says you won’t be covered for any pre-existing medical condition?

If you took out a loan or finance agreement, did the adviser make it clear that you would have to pay for the insurance up front in one single payment?

If you had to pay for the PPI as a single payment, did the adviser make it clear that the insurance cost would be added to the loan and you would be paying interest on it?

Single premium PPI insurance normally only lasts for five years. If your loan or finance agreement was for longer than this, did the adviser make it clear that the insurance would run out before you had finished paying for your loan or finance agreement? The adviser should also have told you that you would continue to pay interest on the insurance premium, even after the insurance expired.

If you bought PPI after 14 January 2005 did the adviser try to persuade you to take it out by saying something like ‘we strongly recommend that you consider taking out PPI’? If so, the sale counts as an ‘advised’ sale and they should have issued a ‘demands and needs statement’ to show why a particular policy has been recommended and why it is suitable for you. If they didn’t, this is grounds for complaint.

If you can answer ‘No’ to one or more of the following you may have a case for compensation. Call Neil on 028 302 57000 for a consultation.

London can breathe easy – it will continue to be the financial lungs of Europe, according to Barclays chief executive Jes Staley.

While he admits the bank may have to move some activities to bases in Dublin or Germany, he believes that most of their European banking business can continue to be done from the UK. “I don’t believe that the financial centre of Europe will leave the city of London. There are all sorts of reasons why I think the UK will continue to be the financial lungs for Europe”

He admitted that other European capitals had been heavily courting the bank to move operations their way. “It’s very interesting that one minute no-one wants bankers in their back yard, the next they are inviting you over to a barbecue.” His commitment to the UK will be welcomed by the Prime Minister, Theresa May, and the Chancellor, Philip Hammond, who will address delegates at Davos today.

It comes 24 hours after HSBC said it would move 1,000 jobs to Paris and UBS said it would shift up to 1,000 jobs to Europe after the government resolved it would be leaving the European single market. Theresa May will be meeting big Wall Street bosses while here today, including Lloyd Blankfein of Goldman Sachs and Larry Fink of giant asset manager Blackrock – both card carrying members of the “global elite” she has been so scathing about.

Barclays is the world’s biggest underwriter of European government bonds and it seemed to many watchers that it might be difficult to continue that activity outside the European single market. Mr Staley said he believed that changes in the legal structure of the bank – by opening a German branch of its Dublin operations for example – would be enough to satisfy European and UK regulators and be in the interests of European governments.

He was upbeat about the prospects for banks in general. saying that the prospect of stronger economic growth in the US under Donald Trump and an associated rise in interest rates would boost bank profitability. The bank still has an unfinished battle with US legal authorities after it balked at demands from the Department of Justice to pay what it considered unreasonable fines for its role in the subprime mortgage crisis.

It is choosing instead to fight the US government in court. Mr Staley insisted that the change in administration (and a new attorney general) in the US was not part of their strategy. “We will still be facing the same prosecutors but we believe in the US justice system to deliver a fair outcome.” You don’t take the US government to court unless you think they are being very, very unreasonable.

What are Debt Based Securities? Lenders receive a non– collateralized debt obligation typically paid back over an extended period of time. Similar in structure to purchasing a bond, but with different rights and obligations.

The debt–based securities market grew by 63 per cent in 2014 Online debt–based securities in renewable energy projects grew by 63 per cent in 2014 to £4.4 million in total financing. The average deal size for debt–based securities is £730,000. On average, it takes 587 investors to fund a renewable energy project through debt–based securities with an average investment amount of £1,243.

The survey of 384 investors in debt–based securities shows that they in general invest relatively large amounts. Sixty– two per cent had invested more than £500 with 21 per cent having invested more than £5,000. They tended to invest in single or very few projects with a third having made only one investment and half less than three investments.

This finding however must be reconciled by the fact that debt–based securities is a relatively new model of alternative finance and only a small amount of deals have been offered and funded to date. The focus on renewable energy matters to investors, being local doesn’t Looking at motivations for investing in debt–based securities, the important or very important factor for investors was the opportunity to back green/renewable energy products (92 per cent) and to make a positive social impact (86 per cent).

They cared less about whether the business behind the project was local or not. When asked what they would otherwise have done with the money they invested, a pretty even split responded that they would have either invested it elsewhere (62 per cent) or saved it (55 per cent). Investing in debt–based securities on renewable projects was generally perceived to be a low risk investment option.

When presented with a number of different investment options such as P2P lending, investing in start–ups or the stock markets, only bonds were perceived to be less risky by investors. Funders found their way to investing in renewable projects through a number of channels. The most common of which was online advertising, which brought in a third of survey respondents, with offline advertising and word of mouth also proving important.

Forty–five per cent plan to invest more in 2015 Looking forward, 45 per cent of surveyed investors plan to put more funds through this model in the coming year with 37 per cent planning on investing a similar amount.

What is Reward-Based Crowdfunding?

Individuals donate towards a specific project with the expectation of receiving a tangible (but non–financial) reward or product at a later date in exchange for their contribution.

The reward–based crowdfunding market grew to £26 million in 2014 Reward–based crowdfunding is probably the model that has really captured the public’s imagination and media’s attention, and it is the type of alternative finance that registered the highest usage rate (eight per cent) in our national consumer poll among all surveyed models.

Reward–based crowdfunding has seen a steady increase of 17 per cent in 2014 from £20.5 million in 2013 to over £26 million in 2014. Analysis of transactional data worth over £30 million between 2010 and the first quarter of 2014 shows that the average size of the reward–based fundraising campaign is £3,766 with approximately 77 backers per campaign and an average donation of £48.92.

The average crowdfunding success rate across seven surveyed reward–based crowdfunding platforms is around 35 per cent. On average, a successful campaign took 28 days to reach their funding target. From the survey of 191 fundraisers and 1,128 backers who have used reward–based crowdfunding, it is clear that those seeking to fundraise in the UK through this model are predominantly those in the social sector or creative industries.

They tend to be small operations, often individuals with little trading history and modest if any turnover. They had chosen reward–based crowdfunding as a potential source of finance to have more control over the project (important or very important for 78 per cent of respondents), raise funds on their own terms (66 per cent), to access the non–financial benefits that crowdfunding can provide (71 per cent) and for the transparency (71 per cent) and speed (68 per cent) of the funding process.

Most backers use reward–based crowdfunding to fund people they know When choosing which campaigns to back, more than 60 per cent of backers valued the quality of the idea, the team and knowing their money was making a difference. Funders were also quite influenced by personal recommendations from people they knew. Backers reported that the money they used to fund projects would otherwise have gone towards day–to–day spending, rather than savings or investment.

Very few backers (less than 10 per cent of those surveyed) viewed their support as an investment, but rather as a chance to support worthwhile projects. Aside from contributing funds, 70 per cent of backers also gave non–financial support, usually by promoting the crowdfunding campaign. Eighty per cent of backers would recommend reward–based crowdfunding or a specific crowdfunding campaign to someone they knew.

Many of them (39 per cent) have also used other alternative finance platforms, usually other reward–based crowdfunding sites. Funders tended to have contributed small amounts ( 61 per cent of respondents had in total contributed less than £50 to projects) to projects and had backed only a single project.

Those on reward–based crowdfunding platforms that focused on funding creativity tended to have contributed more and backed more projects. They generally found out about the campaign through social media or direct mailing. In many cases they also had some connection to, or knowledge of, the fundraiser prior to the crowdfunding campaign.

Most backers gave funds to someone they knew at least by reputation, and only 28 per cent had backed someone they didn’t know. Social media and social networks are key to fundraising success The principle difficulties fundraisers faced when sourcing funds were finding backers and developing campaign material.

Corresponding to how backers reported finding out about fundraising campaigns, fundraisers listed social media and their existing social networks as the most effective routes to reaching potential backers, with offline promotion the least effective. Just over half of fundraisers stated they would have been ‘unlikely’ or ‘very unlikely’ to raise funds without crowdfunding, a further 21 per cent did not know if they would have been able to do so or not.

Three in four unsuccessful fundraisers would try it again Those who failed to reach their crowdfunding target put their lack of success down to not getting their community or network sufficiently engaged with the project(rated an ‘important’ or ‘very important’ factor in their lack of success by 80 per cent of respondents), not generating enough momentum in the campaign’s early stages (74 per cent) and trying to raise too much money (50 per cent).

Despite this, three quarters of surveyed fundraisers would try it again or recommend this model to someone else seeking funds. Twenty–nine per cent of fundraisers increased employment after raising finance through reward–based crowdfunding Looking at the impact, 29 per cent of the fundraisers reported an increase in employment, 49 per cent an increase in turnover and 37 per cent a growth in profits since obtaining finance through reward–based crowdfunding.

Two–thirds also reported having completed their project or launched a new product or service and getting more engagement from supporters. Related to this, three–quarters of fundraisers reported that they benefited from accessing the networks of their funders and around the same proportion said their backers provided assistance with marketing and advocacy of the project. Ninety–two per cent of fundraisers would recommend the model to someone else seeking funds The majority (70 per cent) of the successful fundraisers used the model for the first time since the beginning of 2013, providing further evidence to this being a very young market, with lots of people raising money for the first time in recent years. Successful fundraisers viewed reward– based crowdfunding quite positively and 92 per cent would recommend the model to someone else seeking funds. 81 per cent of them would approach reward–based crowdfunding again in the future should they need more finance.

What is Pension-Led Funding?

Mainly allows SME owners/directors to use their accumulated pension funds in order to invest in their own businesses. Intellectual properties are often used as collateral.

Pension led funding is now a £25 million market.

Pension–led funding (PLF) offers SME owners and directors the opportunity to re–channel, and re–invest their pension funds back into their own ventures and companies mostly as working or expansion capital through SIPP or SASS instruments.13 PLF has supplied more than £25 million of finance to SMEs in 2014.

Analysis of data from PLF providers show that the average amount raised through PLF is £70,257. Pension Led Funding is used primarily by small mature businesses Seventy–four businesses responded to our survey of PLF users. The businesses seeking PLF came from a range of sectors with retail, construction, technology and manufacturing among the most prevalent. They are almost entirely small businesses. Seven per cent were sole traders with 60 per cent having five or fewer employees.

Though small, many are not young. Almost half have been trading for more than 10 years with just eight per cent trading for less than three years. Three–quarters had begun using PLF in the last three years. Users of PLF believed it was easier to access funds through the model than through traditional financing channels.

They also value being able to utilise their pension funds (an ‘important’ or ‘very important’ factor in choosing PLF for 66 per cent of respondents) and having more control over their finances (73 per cent). More than half had approached a bank for funding before securing funds through PLF, with less than a third of those receiving an offer of funding from the bank.

When asked how they found out about PLF, the most common responses were professional advisor (40 per cent) and offline advertising (35 per cent). Whilst some respondents found it difficult to find the PLF provider (11 per cent) and to transfer their existing pension across (13 per cent), in general, most of the survey respondents found that PLF was easy to use.

Sixty–two per cent of businesses have seen their profit grow after securing finance through PLF Just over half of the businesses surveyed believed it would have been ‘unlikely’ or ‘very unlikely’ that they would have secured the funds they needed from other sources, had they been unable to use PLF. Since obtaining funding, 62 per cent have seen their profit grow, 59 per cent have increased turnover and 43 per cent have employed more people.

Other reported impacts since securing PLF include improved cash flow (53 per cent) and the launching of a new product or service (47 per cent). Respondents’ view of PLF was generally positive. 81 per cent say they would be ‘likely’ or ‘very likely’ to recommend PLF to a business they know. 79 per cent are ‘likely’ or ‘very likely’ to approach PLF for funds in the future with 66 per cent inclined to do so, even if a bank offered funds on similar terms.

What is equity crowdfunding?

Sale of a stake in a business to a number of investors in return for investment, predominantly used by early–stage firms. Equity–based crowdfunding grew by 201 per cent in 2014 Equity–based crowdfunding, whereby investors can diversify their portfolio and invest in both early–stage (e.g. pre–seed, seed and start–up) ventures as well as growth–stage companies, continues its rapid expansion with a 201 per cent year–on–year growth rate and facilitated £84 milion in predicted total transaction volume for 2014.

Analysis of a dataset gathered from equity–based crowdfunding platforms, covering £37.43 milion transactions from 2011 to the first quarter of 2014 and including 188 funded deals and 23,414 micro–transactions, shows that the average deal size of an equity–based crowdfunding campaign is £199,095. On average, it takes 125 investors to fund an equity deal with the average micro–transaction value being £1,599.

The average age of fundraisers is 43 and the average age of investors is 40. From the investor side, the average investment portfolio size is £5,414 with an average diversification rate of 2.48 (i.e. on average, one investor has invested in 2.48 equity–crowdfunding deals).

Almost 95 per cent of the funded equity–based crowdfunding deals were eligible either for the EIS (Enterprise Investment Scheme) or the SEIS (Seed Enterprise Investment Scheme) schemes. Sixty–two per cent of investors didn’t have previous investment experience Equity–based crowdfunding platforms are proving attractive for both retail investors who are new to venture capital investing, as well as for experienced investors.

62 per cent of the 290 investors surveyed described themselves as being retail investors with no previous investment experience. A sample of data from the platforms shows that the average portfolio size for certified high networth individuals and ‘sophisticated investors’ is over £8,000 in contrast to less than £4,000 for ‘retail investors’. The pitch and the team are what matters to investors not comments by other investors Three–quarters of investors had invested in businesses run by entrepreneurs whom they had no previous knowledge about or connection to.

The most common method of discovering investment opportunities was through browsing the equity–crowdfunding platform, with the least being offline promotion of the investment opportunities. Investors primarily invest through equity–based crowdfunding platforms in the hope of making a financial return (very important to 61 per cent of investors).

Portfolio diversification, the ease of the investment process and the added control over where their money goes was also seen as important or very important to more than 75 per cent of surveyed investors. Few investors came to the model to invest in a family member or a friend or to support a local business. Instead, investors are selecting specific investment opportunities on the crowdfunding platform, with the quality of the team( rated ‘important’ or ‘very important’ by 97 per cent of respondents) and the pitch (96 per cent) named as the most important factors.

External endorsements and the views of other investors on forums were deemed less important. While 66 per cent of surveyed investors identified tax reliefs as an important factor, more than half stated that they would have invested even if the tax incentives were not present, with only a quarter saying they would not have.

While investors often read comments by other investors when making investment decisions, they rarely contribute comments or get in touch with other investors to discuss investment opportunities. The money they use to invest is money that would otherwise have (at least partly) been invested elsewhere (68 per cent of respondents) or saved (44 per cent of respondents). Ventures seeking finance tended to find out about equity–based crowdfunding through online advertising or through the media and press. Over a third had sought funding from friends and family or business angels prior to approaching an equity–based crowdfunding platform.

Forty–seven per cent of successful fundraisers have increased their profit For those who were successful in their attempt to fundraise, the biggest challenges with the process were developing a marketing strategy and a crowdfunding pitch. They reported that finding and working with an equity–based crowdfunding platform was not difficult.

Fundraisers found that funders added value beyond their financial contributions to the business through assisting with making connections to people in their networks (63 per cent of respondents) and providing market validation for the venture (60 per cent). Fundraisers believed that the most important routes to successfully sourcing funders was through their existing social networks and direct mailing.

Since securing funding, 47 per cent of fundraisers have increased profits, 70 per cent grew turnover and 60 per cent of them have taken on new employees. Three–quarters of the surveyed fundraisers have also launched a new product or service and two–thirds have attracted media coverage.

Those ventures that failed to reach their funding target identified that failure to generate momentum in the early stages of the campaign, insufficient support from the platform and not doing enough marketing as factors that led to their failure. Despite this, 80 per cent of them said they would be willing to try it again and half would recommend equity–based crowdfunding to others with the rest unsure.

Half of investors plan on investing more in 2015 Of the 196 active investors surveyed, 85 per cent had made their first investment since the beginning of 2013, with 36 per cent of investors becoming active in the last three months. Around half of the investors surveyed plan to invest more in the coming year with around a third planning on investing the same amount.

Eighty–one per cent of investors state they would recommend equity–based crowdfunding to someone they know, while 75 per cent say they would recommend a specific business seeking investment. However, it is important to note that given the nature of investing in early–stage companies and the relative nascent state of equity–based crowdfunding model, that most equity crowdfunding investors are yet to see what returns their investments can bring.

All successful fundraisers would recommend equity–based crowdfunding to someone else seeking funding and 91 per cent of them state they would approach an equity crowdfunding platform first in the future if venture capital is needed.

What is invoice trading?

Firms sell their invoices at a discount to a pool of individual or institutional investors in order to receive funds immediately rather than waiting for invoices to be paid.

Invoice trading grew by 179 per cent in 2014

Invoice trading provides fundraising opportunities for small and medium enterprises to trade their invoices or receivables at a discount in exchange for the speedy procurement of working capital. In 2014 the sector grew by around 169 per cent and in 2015 it saw a further growth by 179 per cent. The average invoice auction duration is just eight hours with the average traded invoice value being £56,075. In the majority of cases, a trade invoice only takes seven micro–transactions to complete, signifying the participation of high net worth individuals and institutional investors in this model.

A relatively small sample of 24 businesses responded to our survey of users of invoice trading, therefore the results that follow should be interpreted with caution. The surveyed SME borrowers were spread across a diverse range of sectors with ‘technology’ and ‘business services’ being the most common. More than half of the respondents were based in London or the South East but there were respondents from almost all regions in the UK.

The businesses using the invoice trading platforms tended to be small with over 90 per cent of them having fewer than 50 employees. Yet these are not necessarily young businesses. Over 40 per cent have been in business for over ten years. A third were less than 5 years old and almost all had a turnover of more than £200,000 with half having a turnover of more than £1 milion.

Invoice trading is used to raise working capital

The vast majority (85%) of businesses were trading invoices to secure working capital and 43% of them had heard about invoice trading through online advertising.

The speed of the process was what businesses valued the most (with 95% stating it was a very important or important factor), with ease of use (81%), transparency (85%) and flexibility (85 per cent) also registering as either very important or important factors.

Unsurprisingly given the reason for approaching invoice trading, the other important impact for SMEs was an improvement in cash flow, reported by 92% of the respondents stating the effect.

Almost all had approached banks beforehand with only a fifth receiving offers of funding from them. Over half saw it as ‘unlikely’ or ‘very unlikely’ that they would have received finance should they not have turned to an invoice trading platform.

Three in four would approach invoice trading before a bank in the future

Since receiving funding, 90 per cent of the respondents reported an increase in profit, 80 per cent of them saw an increase in turnover and 60 per cent recorded an increase in employment. Almost all plan to approach an invoice trading platform for funding in the future with three in four saying they would do so even if banks were to offer funding on similar terms. Eighty–six per cent are ‘likely’ or ‘very likely’ to recommend invoice trading to other businesses.

What is P2P Business Lending Debt–based transactions between individuals and existing businesses – which are mostly SMEs with many individual lenders contributing to any one loan. .

The market has more than tripled in size since 2013 P2P business lending facilitates secured or non–secured business loans between individual lenders to mostly SMEs. Over the last two years P2P business lending has experienced an impressive growth, with a 288 per cent increase from the £193 million in 2013 to a predicted £749 million in 2014.

This growth can be largely attributed to the strong expansion of existing industrial players as well as the recent proliferation of this business model underpinned with the emergence of many new and diverse entrants into the market.

Lenders are creating large portfolios as lending is split among hundreds of borrowers Analysis of primary transactional data from P2P business lending platforms worth £309 million covering over 3,000 loans and 3.18 million transactions from 2011–2013 illustrates that the average business interest rate paid is around 8.8 per cent. The average P2P business lending loan size is £73,222 and it takes approximately 796 transactions from individual lenders to the business borrower to fund a listed loan, with the average loan being just £91.95. P2P business lenders have, on average, a sizeable lending portfolio of £8,137 spread over a median of 52 business loans.

Manufacturing businesses using P2P borrowing most Of 3,112 P2P business loans analysed, the top three most funded industrial sectors are manufacturing, professional and business services and retail. P2P lending for real estate finance also emerging One of the fastest–growing markets within the P2P business lending model is secured lending for real estate mortgages and developments.

For this particular section of the market, which was analysed separately, we found that the average business loan amount is considerable higher at £662,425 with an average loan term of 10 months. In addition to looking at transactional data from platforms, we also surveyed 1,771 lenders and 323 business borrowers who have used P2P business lending, to attain further insights on their behaviour and views on alternative finance.

The survey results mirror the findings from the platform data with 30 per cent having lent between £1,000 and £5,000 and 26 per cent having lent between £5,000 and £20,000. It is however interesting to note that almost 23 per cent have provided loans in the range from £20,000 to £100,000. Also corresponding to the findings from transactional data from platforms, our survey demonstrates that P2P business lenders do actively diversify their lending portfolios. One in four P2P business lenders has lent to more than 100 businesses, and 45 per cent have lent to between 20 and 100 businesses.

Lenders tend to be older males using money set aside for savings or investment P2P business lending is primarily used by men who are 55 or older. Eighty–three per cent of surveyed lenders, and 74 per cent of borrowers were men. Fifty–seven per cent of lenders were 55 or older.

They were also quite wealthy with a third having an annual income in excess of £50,000. The majority of P2P business lenders learned about this alternative finance model through online advertising (28 per cent) and online intermediaries such as MoneySupermarket (25 per cent).

When budgeting for lending through P2P business lending platforms, it is clear that the money primarily comes from lenders’ investment budget (54 per cent) or their savings (45 per cent). Very few people (less than 2 per cent) have lent money they would otherwise use for day–to–day spending. Lenders are primarily motivated by the financial return available The main reason why people use P2P business lending to lend is to make a financial return on investment, with 82 per cent of respondents stating this as very important in their decision.

Building on this, many also stated the service that P2P business lending offers, in terms of the ease of lending process (important or very important to 87 per cent), diversifying investment portfolios (important or very important to 88 per cent) and having control over where the lent money is going (important or very important to 81 per cent) were key to their decision to lend. Unlike the donation and reward–based fundraising, the opportunity to use the P2P business lending model to support a specific sector or industry, supporting friends and family or supporting a social cause was of relatively low importance to the majority of lenders.

Furthermore, it is interesting to observe that almost none of the P2P business lenders had personal connections to the businesses they lent to, with 97 per cent saying their first loan was to someone they didn’t know. Registered but inactive lenders concerned by business creditworthiness We also asked those lenders who have set up accounts with P2P business lending platforms but have yet to make their first loan (5 per cent of all surveyed lenders) what would make them start lending.

The key issue ranked important or very important by these potential lenders was uncertainty about the creditworthiness of business seeking loans (73 per cent of respondents). Uncertainty about how the model worked was not one of the more cited factors with 35 per cent saying this was ‘important’ or ‘very important’. Inactive members highlighted more information about businesses seeking loans (13 per cent), greater tax incentives (31 per cent) and more information about risks associated with lending (11 per cent) as three key factors that would make them begin lending.

Finally, 58 per cent of the surveyed inactive lenders indicated that they would start lending within the next 12 months. Borrower seeking growth or working capital and value speed of service Businesses seeking to borrow via P2P business lending most commonly seek a loan for expansion and/or growth capital (41 per cent) and working capital (34 per cent). SMEs borrowers often choose P2P business lending because the combination of the speed and ease of use of the model, rated important or very important by 94 per cent and 90 per cent of borrowers respectively.

91 per cent of borrowers highlight how they see P2P business lending as an easier way to get funded than traditional channels (e.g. bank) as a key factor in their decision to choose this lending model. P2P business lending is funding many borrowers who would otherwise struggle Responses show that borrowers in many instances have unsuccessfully sought funding from more traditional funders such as banks before attempting to borrow via P2P business lending platforms.

79 per cent of borrowers had attempted to get a bank loan before turning to P2P business Lending, with only 22 per cent of borrowers being offered a bank loan. 33 per cent thought it was unlikely or very unlikely that they would have been able to secure funding elsewhere had they not been successful in getting a loan through the P2P business lending platform, whereas 44 per cent of respondents thought they would have been likely or very likely to secure funding from other sources had they not used P2P business lending.

Businesses receiving loans reporting growth in term of job creation and turnover Most business respondents have experienced positive growth since successfully securing a loan. 71 per cent of borrowers reported growth in turnover, 63 per cent experienced growth in profit with 53 per cent having increased their employment.

The majority of the remaining respondents reported that their turnover, profit or employment levels had remained largely the same. Less than 5 per cent reported contraction under any metrics. Growth of model likely to continue in 2015 The rapid growth of P2P business lending is illustrated not just by the increasing amount of money lent to businesses via the model in recent years, but also by the number of people and businesses who have only just started to use the platforms to lend and borrow. More than 69 per cent of P2P business lenders surveyed have begun using the model in just the last two years with half of these starting since the beginning of 2014.

Similar trends exist on the borrower side with 48 per cent of the businesses responding to the survey having first borrowed in 2014 and 40 per cent in 2013. Looking ahead, the majority of P2P business lenders expect to increase their lending in total and to more businesses, with 53 per cent of them expecting to lend more, and 38 per cent of them expecting to lend about the same. In addition, 65 per cent of lenders expect to lend more should their P2P lending qualify for the Individual Savings Account (ISA) scheme. Ninety–four per cent of borrowers state that they will be likely or very likely to approach a P2P business lending platform first if they need finance in the future, and a significant 86 per cent would be likely or very likely to approach a P2P Lending platform even if a bank could offer similar terms. Ninety–seven per cent would be likely or very likely to recommend P2P business lending to other business that they know are seeking funding. Current lenders’ support for the P2P business lending model is emphasized by the fact that 59 per cent of lenders are very likely to recommend P2P business lending to others with money to lend, and 42 per cent of them are very likely to recommend P2P business lending to business looking to borrow money.

Royal Bank of Scotland puts aside £400 million to compensate business owners mistreated by its Global Restructuring Group following FCA inquiry.

The Royal Bank Of Scotland (RBS) has put aside £400 million to cover the cost of a redress programme for small business customers of the bank’s Global Restructuring Group (GRG) between 2008 and 2013. The activities of the GRG were investigated by the Financial Conduct Authority (FCA) after a number of former customers complained about the way they were treated. Some of the most serious allegations suggested that RBS moved businesses to the GRG when they did not need support, and that RBS’s actions directly led to the collapse of these businesses.

While the FCA report found ‘no evidence’ to support the most serious allegations it did identify a number of failings from RBS. These failings included issues around customer complaints, communication and charges. As a result of the report, RBS has set up a new compensation process for GRG customers.

It will be led by retired High Court judge William Blackburne. RBS will also automatically refund all complex fees paid by small business customers of GRG between 2008 and 2013. This includes all exit fees, asset sale fees and risk assessment fees. The bank said it will put aside £400 million to cover the cost of this process. Ross McEwan, chief executive of RBS, said: ‘We have acknowledged for some time that mistakes were made.

Some of our customers went through what was a traumatic and painful experience as a result of the crisis. I am very sorry that we did not provide the level of service and understanding we should have done.’ The FCA will publish a full account of its findings once it has considered whether it will take further action. However, it cautioned that as the actions carried out by the GRG were largely unregulated the FCA’s powers were ‘limited’. Credited to: http://citywire.co.uk/money/rbs-apologises-to-small-firms-hurt-by-restructuring-unit/a966640