Category Archives: Equity Crowdfunding

Canadian Startup Equibit Wants to Decentralize the Securities Industry

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Coinsquare | | Jan 13, 2018

Equibit Group is a Canadian blockchain company with plans to decentralize the securities industry.

Formed in 2015, their vision is to create the ultimate registration system for intangible assets, and move the securities industry onto the blockchain. The platform will allow anyone to transfer value without the need for an intermediary. They believe their system will be as valuable to a bank as it is to an individual investor.

Traditionally third parties like custodians are responsible for maintaining complex records for the ownership of securities. Co-founder and CEO Chris Horlacher saw that the blockchain could create a more trustless system which removed the need for third parties while increasing security.

Horlacher became intrigued with Bitcoin after first hearing of it in 2010. At the time a little-known technology while the world recovered from the financial crisis, he saw an opportunity. He saw that the core technology behind Bitcoin could be modified to serve the securities industry.

Real Also:

Chris Horlacher, Chairman; CEO, Equibit Development Corporation, Joins NCFA’s Ambassador Program

Canadian EDCs Blockchain Crowdfund Scores $0.5m In Equibits Cryptocurrency Sales

ENTERPRISE SOLUTIONS

Equibit Group has three apps which allow users to interact with their blockchain in different ways.

EquibitCore allows users to participate in network consensus by running a full node. EquibitCore will soon be pre-released to a select group of miners, who will create the necessary hash power needed to maintain the network. Once completed, the team plans to launch EquibitCore to the public.

They have also developed Equibit Portfolio,  a web-based wallet where users can store their Equibits. Investors can also store securities purchased through the Equibit network in the wallet.

What’s unique about Equibit, though, is that investors can buy and sell securities on the network without the need for a transfer agent.

Equibit Supernode is an app that aims at enterprise solutions. Companies can use Supernodes in many flexible ways, such as creating their own securities-related infrastructures for situations like raising capital or safely managing the assets of clients.

EQUIBIT AND BITCOIN

Equibit is based on the Bitcoin protocol. The company paid homage to this fact when they embedded a news article into the genesis block, which they recently mined. The news article could be viewed by the miners who were pre-selected to run full nodes.

Continue to the full article --> here

 


The National Crowdfunding Association of Canada (NCFA Canada) is a national non-profit actively engaged with social and investment crowdfunding, alternative finance, fintech, peer-to-peer (P2P), initial coin offerings (ICO), and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, networking opportunities and services to thousands of community members and works closely with industry, government, academia and eco-system partners and affiliates to create a vibrant and innovative fintech and online financing industry in Canada.  For more information, please visit: www.ncfacanada.org

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Saskatchewan and Alberta make cross-border financing easier

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Alberta Securities Commission | Dec 12, 2017

CALGARY, Dec. 12, 2017 /CNW/ - The Financial and Consumer Affairs Authority of Saskatchewan (FCAA) has changed its start-up crowdfunding exemption to allow businesses in Saskatchewan and Alberta to raise funds from investors residing in those provinces.

"This change will enhance capital raising opportunities for businesses in Saskatchewan and Alberta and investment opportunities for investors in those provinces. Given the geographical proximity, and similarities in industries, it makes sense for us to coordinate our efforts to facilitate cross-border financings with our neighbouring provinces," said FCAA CEO Roger Sobotkiewicz.

To allow for the interjurisdictional raising of capital, Saskatchewan has amended General Order 45-929 Start-up Crowdfunding Registration and Prospectus Exemptions (SK GO 45-929), and Alberta has changed the Companion Policy to Alberta Securities Commission (ASC) Rule 45-517 to clarify how cross-border financings will work.

See:  Advancing the dialogue on the future of financial services

Start-ups and early stage businesses must be aware of the different requirements in each jurisdiction and comply with the requirements of both SK GO 45-929 and ASC Rule 45-517. One significant difference between the two exemptions is that to raise money through a crowdfunding portal in Alberta, businesses must use a registered dealer. In Saskatchewan businesses must use an online funding portal, which is not required to be operated by a registered dealer.

For more information about SK GO 45-929 visit http://www.fcaa.gov.sk.ca/Exemption-Order-45-929. The ASC Rule 45-517 can be found on the ASC website at albertasecurities.com.

The FCAA is a crown corporation responsible for developing and enforcing Saskatchewan securities laws, which regulate Saskatchewan capital markets and protect investors. The ASC is the regulatory authority responsible for administering Alberta's securities laws. The ASC is entrusted to foster a fair and efficient capital market in Alberta and to protect investors.

As members of the Canadian Securities Administrators, the FCAA and ASC work to improve, coordinate and harmonize the regulation of Canada's capital markets.

SOURCE Alberta Securities Commission

For further information: For Media Inquiries: Matthew Barton, Financial and Consumer Affairs Authority Saskatchewan, Communications Consultant, 306-787-6067; Hilary McMeekin, Alberta Securities Commission, Manager, Communications, 403.592.8186; For Investor Inquiries: ASC Public Inquiries, Toll Free 1.877.355.4488


The National Crowdfunding Association of Canada (NCFA Canada) is a national non-profit actively engaged with social and investment crowdfunding, alternative finance, fintech, peer-to-peer (P2P), initial coin offerings (ICO), and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, networking opportunities and services to thousands of community members and works closely with industry, government, academia and eco-system partners and affiliates to create a vibrant and innovative fintech and online financing industry in Canada.  For more information, please visit: www.ncfacanada.org

 

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Jan 8, 2018: Intro Presentation on Raising Equity and Funding for your Startup

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NCFA Canada | Jan 15, 2018

Slides:  NCFA Canada Founder and CEO, Craig Asano, delivers a presentation on raising equity and funding for the graduating class of Founder Institute companies in Toronto on Jan 8:

  1. Equity & Funding Introduction Date: January 8, 2018 Prepared for: Founders Institute Toronto Prepared by: Craig Asano, NCFA Canada
  2. Fintech & Funding Association Massive Fintech Network Partners Advisors Members 90+ Platforms 20+ Providers 45 Portals 2018 2017 2016 2015 Oct 2012 Programs Services Global Network P1 P2
  3. Are you ready to raise capital?
  4. Are you ready to raise capital? Set your valuation appropriately • Look for comparable businesses • Geographic and investor group dependent • Discounted cash flow. Make your projections realistic. would you be willing to take your compensation as a % of forecast? • Ultimately a negotiation between investors and the business • Expect 10% - 30% dilution per round • Use preferred shares, convertible notes, SAFE / SAFT if uncertain or to avoid significant dilution How much time can you devote to funding? • Do not do this half ass. If after a defined period (ie 1 year) you’ve been unsuccessful then face facts (markets are highly efficient) • Understand potential impact to ego / brand equity and team motivation • Leverage templates. Be resourceful. Seek expertise.
  5. Are you ready to raise capital? How much money should we raise? • Determine key milestones that impact business’ value • IP strategy, Prototype • Sales and Revenue (ie repeat customers/month • Product/market fit or key development milestones • Human resources and team building (growth) • Raise what you need to get you to the next milestone (iterate and prove) Bootstrapping: advance your situation using existing resources Lean start-up: get to market and revenue positive as quickly as possible What non-dilutive sources of capital are available at each step?
  6. Are you ready to raise capital? Understand your initial capital structure (and dilution) • Founders (80-90%), Leadership team (10-15%), Advisors (1-3%) • Skin in the game • Put in writing and use vested agreements • Source cap table excel sheets online
  7. Where can I find Investors? • Identify potential investors and sources of funding (keep doors open): • Government grants / funds • Corporate sponsorships and grant programs • Friends and family, Loans and credit • Crowdfunding (Equity, debt/lending, reward, ICOs/tokens, Royalty) • Angel investors • Venture capital • Dealer-brokers, agents, intermediaries • Private equity interested in side-car investments • Ask for introductions • Global markets Sources of Private Capital
  8. Be strategic with your approach • Make a list of contacts that can realistically help (assign probability and amount you are seeking from them) • Seek to develop long term relationships and understand what you can offer them and vice versa. • Learning loop: Listen – learn – track and improve (alignment, probability) • Start building your funding networks yesterday • Online – personal & company profiles • Offline - Events, conferences, pitch forums, investor networks • Understand the timing of your ask relative to the ‘funding window’ and type of investor • Stay on top of funding research and news to find similar companies to learn from / with. • Ask for introductions • Turn advocates into loyal customers and investors Get in Funding Mode
  9. What are investors looking for? • A product/services that addresses a large market need (not a nice to have) • Team that can execute who has a solid understanding of business and challenges • Validation/proof (de-risk) • Some are seeking social impact or to balance impact with profits The Investment Process • Pitch deck is bare essential • Meet and greet is only the first step • All investment basics must be met • Due diligence review • Terms negotiated • Close (in person) What are investors looking for?
  10. Deal Breakers and Tips • Avoid one man team, no skin in the game, unrealistic valuations, serious character flaws • Raise equity capital with no clear purpose, to replace debt, pay big salaries, to develop an idea and not a business • Face to face meetings (3-5x more capital $ than email or call) • Securing initial key/lead investor will make raising $ significantly easier • Only invest if they know you, know the business and like the investment opportunity What you Need to get Started
  11. Basic Crowdfunding Models < $10K $10 - $250K < $100 - $350K+ < $250K - $3M+ Social Material Investment Benefits
  12. Raising Capital Online in Canada
  13. Wide distribution over the internet • Low cost, efficient, transparent capital • The `great equalizer` • Media/PR, awareness • Increase customer engagement and • Evangelize backers into investors (customer acquisition) • Reduce risk by getting feedback on new launches (product or ventures) • Market research Access to Capital Marketing Platform Validation • Raising funds via crowdfunding markets is a very public and transparent • Protect your IP and speak to a lawyer • Crowdfunding takes a lot of effort and commitment • The majority of Ideas fail to reach their funding goal • How will this affect your companies brand? Expose your Idea Resourcing Failure Crowdfunding Pros/Cons Benefits Risks For Companies
  14. Examples Source: Kickstarter Campaign page Innovation – Social – Incentives – Economic Growth Quidni Estate Winery (NCFA Director) • Just completed $100K equity raise (for 3% equity ownership) • Took over a winery. Went digital (including online wine sales). Converted virtual wine tasters into investors Impak Finance (Equity Offering) • Raised $1.2 million (goal was $500K for 6%) from 1450 shareholders to create first socially responsible Canadian bank • $500,000 in the first 24 hours! • Inclusive & accessible: $100 shares for $100
  15. NCFA Canadian Online Funding Directory Reward/Donation: Equity-based via Dealer: • Steady growth in portals • Equity, Debt & Royalties all emerging • Fintech is all the rage • Real estate and entertainment, film/media crowdfunding emerging Consumer and Small Business Loans:
  16. Crowdfunding Framework Planning & Strategy • The greater your planning efforts, the greater your chance of achieving your funding goal • Do not launch a crowdfunding campaign if you are not ready. (3 months) (40 days – 90 days) (Ongoing) Post-campaign • Your campaign is done but now you have to deliver on your promise • Fulfillment • Ongoing customer engagement Campaign Execution • Daily execution of tasks outlined in the campaign plan • Control, monitor and adapt Feedback Loop
  17. Success Factors SUCCESS 2. Network Strength • Sizeable online network and social media presence? • Will media/PR and influential bloggers cover your story? 1. Quality Idea & Pitch • Unique, enterprising and clear value proposition (conveyed online in a simple manner) • Get others excited about your story? • Clear funding target and specific goals? 4. Key Docs and Content • Compliant and necessary for investor review 3. Strong Committed Team • Is your team credible, committed and willing to deploy the resources and time to execute effectively? • Time management HARD WORK! 5. Marketing Campaign & Incentives • Planning and strategy with ability to execute through launch to post campaign
  18. Common Mistakes • We underestimated the time commitment involved • We didn’t test our campaign sufficiently • We launched before we were ready • We didn’t develop an accurate budget • We didn’t consult legal counsel or professional providers • We didn’t account for taxes • We tried to do everything on a shoestring • We didn’t realize how important the video was • We didn’t understand liability exposure (eg. misrepresentation) and intellectual property • We had little to no traction so we gave up • We blamed it on the portal
  19. Join Us Education & Research Market Access Crowdfunding Infrastructure Capital Raising Prep Services Support and Leadership Advocacy GET IT IN TOUCH Fintech & Funding Association ncfacanada.org crowdfundingsummit.ca

The National Crowdfunding Association of Canada (NCFA Canada) is a national non-profit actively engaged with social and investment crowdfunding, alternative finance, fintech, peer-to-peer (P2P), initial coin offerings (ICO), and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, networking opportunities and services to thousands of community members and works closely with industry, government, academia and eco-system partners and affiliates to create a vibrant and innovative fintech and online financing industry in Canada.  For more information, please visit: www.ncfacanada.org

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Free to Trade: Securities Issued Under Reg A+ May Trade in Canada

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Crowdfund Insider | JD Alois | Dec 24, 2017

One of the attractive aspects of Reg A+, as created by the JOBS Act of 2012, is the fact issuers may immediately trade securities following a funding round. This has led to a growing number of SMEs to raise capital under Reg A+ and quickly list shares on NYSE, NASDAQ or OTC Markets.

As the rule is still quite new, regulators continue to adapt to the new exemption. This holds true for Canada, a country that has leveraged Reg A+ for cross border funding rounds.

Earlier this week, the Ontario Securities Commission (OSC) published a document recognizing the ability for Reg A+ issues to trade immediately as well.  The approval was noted in a tweet by Alixe Cormick, a Canada based securities attorney and a leader in the crowdfunding movement.

See:  How to Effectively Market an Equity Crowdfunding/Reg A+ Offering

While not a major change, the approval brings “greater certainty to cross-border activities” while making Reg A+ more amenable to issuers. While the Canadian securities market is governed by multiple provincial regulators, Ontario is the financial center and other provinces should follow suit.

Continue to the full article --> here


The National Crowdfunding Association of Canada (NCFA Canada) is a national non-profit actively engaged with social and investment crowdfunding, alternative finance, fintech, peer-to-peer (P2P), initial coin offerings (ICO), and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, networking opportunities and services to thousands of community members and works closely with industry, government, academia and eco-system partners and affiliates to create a vibrant and innovative fintech and online financing industry in Canada.  For more information, please visit:  www.ncfacanada.org

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Katipult CEO Brock Murray Discusses How to Use Crowdfunding Software to Market Reg. A+ Offerings on the “Reg.A Money Show”

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NB Herard | By:  | Dec 17, 2017

The Regulation A+ equity crowdfunding industry is starting to see groundbreaking software in use to run crowdfunding platforms and portals. Katipult is one such firm offering private label software services to Reg.A+ issuers allowing them to brand Regulation A offerings on their own website domain.

Las Vegas, NV, December 17, 2017 — The Reg.A Funding Group announced today that they have published their latest “Reg.A+ Money Show” radio podcast in which Katipult CEO Brock Murray discussed how to use crowdfunding software to market and better brand Regulation A+ offerings.

Marketing and branding are two crucial pieces of what makes a Regulation A+ offering successful. On this podcast episode, the “Reg.A Money Show” interviewed Brock Murray from Katipult to get his take on how software is transforming the industry and how his private label software company can help Reg.A+ issuers enhance their brand even further by developing their very own “Crowdfunding Portal” hosted directly on their website domains. Cloud-based software infrastructure now allows firms to design, setup, and operate an investment platform across multiple distribution channels including web, mobile, and social media – and brand it totally their own.

Besides being syndicated on the iHeartRadio Network, you can access the radio podcast here:

Said “Reg.A Money Show” co-host Ron Costa, “Just as software has touched basically every industry on the planet, now we’re seeing groundbreaking cloud-based software like Katipult in use in the Reg.A+ space to run crowdfunding platforms and portals. Reg.A+ will be all the better as a result.”

See: 

Canadian Fintech Katipult Becomes Public Company, Trades on TSXV under Ticker FUND

Fineqia Partners with JOI Media's Katipult for Technology Platform

About Katipult:
Katipult is a financial technology company that offers proprietary Crowdfunding Software that boasts the latest, powerful features and tools to launch a successful Real Estate or Equity Crowdfunding platform. Their software is being used in over 20 unique regulatory environments to grow investor networks, efficiently manage investors, and streamline deal flow administration. More information is available at www.katipult.com.

 

About The Reg.A Money Show
The “Reg.A Money Show” provides information and Reg.A education from the founders over at the “Reg.A Funding Group” as well as market insights from a variety of industry experts who appear on the show as guests. The show is hosted by Ron Costa and Miguel Dotres, who bring a wealth of information in regards to Reg A+, SEC filings, social media marketing, and various other topics in an entertaining and informative format. The podcast is quickly emerging as a “must listen” to all those interested in issuing Reg.A paper or investors interested in participating in a company’s Regulation A+ offering.

About The Reg.A Funding Group
With years of experience in the capital markets and proven results with social marketing, the Reg.A Funding Group provides real world, effective Regulation A advisory services for startup, growth and acquisition financing, while specializing in helping companies raise money with Regulation A+ Tier 1 and Tier 2 crowdfunding offerings. The Reg. A Funding Group can be reached at 612-888-REGA or atinfo@regamoney.com.


The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding, alternative finance, fintech, P2P, ICO, and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, and networking opportunities to over 1600+ members and works closely with industry, government, academia, community and eco-system partners and affiliates to create a strong and vibrant crowdfunding industry in Canada.  For more information, please visit:  www.ncfacanada.org

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RED Mountain Hurdles Historic $1.5 Million Mark; Keeps Going

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Nasdaq Newswire - Red Mountain | Dec 13, 2017

Scrappy Ski Mountain Reaches Major Milestone in Crowdfunding Campaign

ROSSLAND, British Columbia, Dec. 13, 2017 (GLOBE NEWSWIRE) -- Nearly sixteen months ago, RED Mountain launched an historic initiative for ski hills to raise capital through crowdfunding, offering ownership in the storied Canadian ski resort to investors for starting at $1000. Today, RED is proud to announce that it has hit— and exceeded — its minimum offering of $1.5 Million collectively raised on both StartEngine.com in the USA and FrontFundr.com in Canada and has accepted the first round of subscriptions under the crowdfunding offering. This means that the first funds can be accessed for use in “improving the adventure,” and investors can begin using some of the perks offered as early as this ski season.

See:  RED Mountain Goes LIVE With Crowdfunding in Canada; Urges Fans to “Fight The Man. Own The Mountain.”

“It’s hard for me to even put into words what this milestone means to our team,” says RED CEO Howard Katkov. “This campaign has been non-stop since we launched… It’s been intense in a way I’ve never experienced in any of my previous business endeavors, but most gratifying for me, my team, and our community. We planted this flag for independent skiing and touched a nerve with skiers and boarders around the world. It’s way bigger than RED Mountain now — and RED’s pretty big!”

Dubbed “Fight The Man. Own The Mountain,” the RED campaign has raised eyebrows as well as money, highlighting the importance of independent skiing.  RED Mountain has presented itself as one big, continually growing “family”, something very unique, juxtaposed to the rapid corporate consolidation of ski resorts in North America.

“After we tossed this notion out there 16 months ago, we received pledges of over $13 Million,” explains Katkov.

“We knew that not everyone would convert to their reservations to subscriptions for Class D Units— that not everyone is able to — but the traction we’ve seen on this issue is commendable on its own. More people are aware of the transformation of skiing due to corporate consolidation and we have created a touch point for those who care about independence, authenticity, affordability and access. We’ve received investments from numerous supporters who’ve never even been here! RED isn’t the only independent out there fighting the good fight, but we have become a high-profile underdog.”

“RED is defining a movement that is transforming what it means to be an Angel Investor,” explains Sean Burke, COO of FrontFundr. “You don’t need to be a high net worth individual to invest and own a piece of RED and this is what democratized investing in private enterprises is all about. RED has proven this and now holds the single largest closing for equity crowdfunding in Canada, with total subscriptions of over $1.5million.”

“Our passion hasn’t wavered,” adds Katkov. “We will continue to accept subscriptions for the Fight the Man / Own the Mountain crowdfunding offering over the winter and fully expect to raise additional equity after this great start. Just know there’s room at the table of this historic offering and truly unique opportunity to own a chunk of RED Mountain. We know that many more die-hards will be joining the family over the winter and we can’t wait to meet them!”

The US offering circular can be viewed here.

Source:  here

Press inquiries can start here:

Christine Andison – Planning & Development
RED Mountain Resort
250-362-5551
christine.andison@redmountainventures.com


 

The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding, alternative finance, fintech, P2P, ICO, and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, and networking opportunities to over 1600+ members and works closely with industry, government, academia, community and eco-system partners and affiliates to create a strong and vibrant crowdfunding industry in Canada.  For more information, please visit: www.ncfacanada.org

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Nov 20, 2017: NCFA Canada Welcomes Competition Bureau’s recommendations to encourage competition and innovation in Canada’s financial services sector

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NCFA Canada | Robin Ford | Nov 20, 2017

Competition Bureau request for public comments on draft study:  Technology-led innovation and emerging services in the Canadian financial services sector

The Competition Bureau recently announced a draft report and issued a request for public consultation regarding technology-led innovation and emerging services in the Canadian financial services sector.  The consultation took place between November 6 and November 20, 2017 (11:59 pm Pacific time). and interested parties including NCFA Canada were invited to provide their feedback on the draft report no later than November 20, 2017.

Visit this link to learn more about the Competition Bureau and the scope and the premise of the study/report:  http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/04315.html

NCFA Canada's submitted response:

  1. NCFA welcomes this report and its recommendations to encourage competition and innovation in Canada’s financial services sector.
  2. We agree that " competition is good for both business and consumers—and regulation should be minimally intrusive on market forces". We also agree that SMEs "are key drivers of economic growth—and their success is crucial to Canada's long‑term prosperity".
  3. We agree with the barriers to entry listed in the draft report (paragraphs in the report are not numbered) but would add to the list: inadequate incentives and assistance by governments, public funders, and regulators compared to other jurisdictions (eg, tax incentives, start-up loans or guarantees, grants, collaboration on data collection and analysis, educational programs for investors and start-ups, help with regulatory compliance, etc).As the draft report mentions, the UK has been very assertive in supporting start-ups and fintech. HM Treasury recently announced that small businesses struggling to access finance from the banks have found funds via government requirements that the biggest banks pass on the details of small businesses they have rejected for finance to alternative finance platforms - Funding Xchange, Business Finance Compared, Alternative Business Funding, and Funding Option. <https://www.gov.uk/government/publications/designation-of-banks-and-finance-platforms-for-finance-platforms-regulations>4. With respect to barriers caused by regulation, we add only that regulatory burden also tends to favour larger incumbent firms.5. Regulatory arbitrage is not necessarily a bad thing, as the report appears to suggest.6. We support all the recommendations in the report, in particular the recommendation for a FinTech policy lead in this complex and fast moving area.7. We would like to see an additional recommendation for more transparency in regulatory analysis. It has been very difficult in the past to respond to regulators' proposals because the published analyses have not been clear or complete. The problem proposed to be solved by regulation is rarely defined, the reasons for concluding that a regulatory intervention is needed are rarely set out, alternative solutions are not described with the reason(s) why one solution has been chosen rather than another, and (published) cost benefit analysis or impact assessment is rare. This means that stakeholders must infer much of the analysis and often do not have the data they need to respond. We would like to see a more transparent regulatory approach to reduce the risk of unnecessary or incorrect regulation and to enhance collaboration.

    We would also like to see the encouragement of fintech advisory groups to governments and regulators with strong representation from the businesses themselves.

    8. The statements in the following paragraph are contestable - some are highly contestable.

    "The large financial institutions in this country did not fail, largely due to Canada’s strong regulatory regime and the sound business practices of those institutions. Because our financial institutions did not fail, demand for P2P lending and equity crowdfunding is significantly lower in Canada than in jurisdictions where the financial crisis had a greater impact or where regulatory regimes were insufficient to prevent widespread bank failure. In those jurisdictions, regulators responded by strengthening restraints on financial institutions, effectively causing a contraction in available SME credit. As a result, demand for P2P lending and equity crowdfunding increased significantly faster than in Canada."

    We suggest that references to support these conclusions be added.

    9. We are not sure why, in the description of the UK's regulatory framework for P2P, the word "forces" rather than simply "requires" is used.

    10. We do not agree that "in the UK, [a] renewed focus on competition has led to the establishment of the "twin peaks" of regulatory structure: the Prudential Regulation Authority (PRA) and the FCA." Rather, it was the other way round. As HM Treasury's consultation document of July 2010 states -

    "1.4 The UK’s ‘tripartite’ regulatory system made three authorities – the Bank of England (the Bank), the Financial Services Authority (FSA) and the Treasury – collectively responsible for financial stability, and, as a result, this system failed in a number of important ways."

    "1.6 Perhaps the most obvious failing of the UK system, however, is the fact that no single institution has the responsibility, authority or powers to monitor the system as a whole, identify potentially destabilising trends, and respond to them with concerted action." [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/81389/consult_financial_regulation_condoc.pdf]

    The UK Government's decision to change the regulatory structure led to a renewed focus on (among other things) the competition objective of the regulator and (after strenuous debates in Parliament) a stronger competition objective was added to the legislation.

    11. We suggest that "risk" be defined. For most risk professionals, it simply means "uncertainty". With uncertainly comes both threat and opportunity. And of course risk does not exist in a vacuum, it is always 'risk to what?' (to competition? to regulatory objectives?).

    Thank you for the opportunity to comment.


 

The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding, alternative finance, fintech, P2P, ICO, and online investing stakeholders across the country. NCFA Canada provides education, research, industry stewardship, and networking opportunities to over 1600+ members and works closely with industry, government, academia, community and eco-system partners and affiliates to create a strong and vibrant crowdfunding industry in Canada.  For more information, please visit:  www.ncfacanada.org

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