Karsten Wenzlaff, Advisor
August 26th, 2025
Crowdfund Insider | | Aug 31, 2016

After nearly eight months since the original draft was first issued, the China Banking Regulatory Commission (“CBRC”) announced the official rules for the online lending industry on August 24, 2016. The unveiling came accompanied with a few policy curveballs that few industry participants were expecting. Titled as the “Interim Guidelines” (indicating there could be more permanent policies few years down the road), certain media has hailed the newborn policies as the strictest ever in the history of online lending. However, not much has changed between the draft and final versions with one major exception: borrowers are now subject to a borrowing limit for loans on a single platform as well as across platforms.
Public reactions from industry participants were all positive and supportive as one must never (ever) publicly denounce Chinese policies. Privately, many managers are scrambling to make sense of the new rules while lamenting that regulators have dealt a death blow to the online lending industry.
When Chinese media began circulating rumors of borrowing limits in the days leading up to the official CBRC announcement, many dismissed the reports simply as a rumor. Imagine the disbelief as the policies now confirm that “natural persons may only carry a loan balance of up to RMB 200,000 on a single platform and no more than RMB 1 million across multiple platforms. While legal representatives of organizations and other legal entities may only borrow up to RMB 1 million on a single platform and no more than RMB 5 million across multiple platforms.”
In the press conference held by the CBRC, the following official response offers the following explanation for the motivation behind the borrowing limits:
“To better protect lenders’ rights and to reduce the moral hazard risk of lending platforms, we want to limit the concentration risk in loans and work in conjunction with the applicable laws and filing standards for illegal fundraising cases”
The first part of the statement is easy enough to understand, regulators want to forcibly reduce overexposure to large loans as a moral hazard problem does exist in that platforms are incentivized to make bulky loans as it saves them origination costs and helps them generate larger volumes, while lenders ultimately bear the higher risk from overburdened borrowers. The latter part of the statement however is trickier to explain and rationalize.
According to the relevant rules issued by the Supreme People’s Procuratorate and the Ministry of Public Security, the threshold to establish and prosecute a criminal case for illegal fundraising is RMB 200,000 for individuals and RMB 1 million for organizations. What this means is that if someone illegally fundraises any amount below these thresholds, they will not be prosecuted on a criminal basis and would instead undertake a civil procedure. Therefore the logic here, as one Chinese industry blogger mused, seems to be that all borrowers on lending platforms are now deemed to be fundraising illegally and to protect these borrowers and platforms from criminal prosecution, regulators are enforcing loan limits that match exactly with the criminal case thresholds. In this sense, regulators are attempting to protect lending platforms from being implicated as facilitators in criminal fundraising cases. In addition, drawing a clear line for lending platforms will likely reduce the case load for police departments as platform compliance with the limits would lower the likelihood of criminal cases being filed by lenders. Since the Ministry of Public Security is one of the joint authors of these rules, it has been rumored that they pushed hard for the loan limits so that they can reduce police paperwork from criminal fundraising complaints. This rumor is unverified and highly speculative, of course.
Allow me to digress here as I would like to propose my own solutions to the issues that regulators pointed to as motivation for implementing the loan limits. If regulators are concerned about concentration risk in large loans, a more direct solution to protect lenders would be to mandate an investment limit per loan, thus forcing lenders to diversify their loan portfolio. Using diversification to reduce risk is frequently advertised to lenders by top lending platforms in both China and the US and should address the regulators’ concern for investor protection. However, if regulators are more focused on the moral hazard of originating large loans that benefit platforms and increase risk to lenders, I think there is an even bigger moral hazard issue that should be addressed first.
Many Chinese lending platforms collect an outrageous amount of origination fees from the borrower. Examining a certain NYSE listed Chinese lending platform’s latest annual financials, one can find an average fee rate of 20%+ being charged to the borrowers. With these fees, the resulting cost to the borrower can soar close to 40% APR, a rate of return that even small time loan sharks will find attractive.
The classic moral hazard issue here is clear: platforms can overburden borrowers and increase default risk to lenders by collecting high fees that benefit their own financial performance. Even worse, with poor disclosure from the platform, lenders are often only aware of the interest paid to them by the borrower without knowing about the additional fees that borrowers have to pay to the platform.
To resolve this moral hazard problem, I suggest that regulators seriously consider implementing limits on platform fees for borrowers or set a cap on overall borrowing costs. If not, then regulators should at least mandate detailed disclosure of fees on a per loan basis to reduce the information asymmetry between lenders and platforms on borrowing costs for loans.
Although there are existing private lending laws in China regulating the interest rate that lenders can charge borrowers, there are no regulations on the overall borrowing cost inclusive of all fees. Certain platforms have publicly justified the use of this legal loophole to continue to issue high-interest loans under the guise of platform fees. Eventually and hopefully, in one form or another, there must be policies to control fees charged by all types of regulated lending institutions. Otherwise, such irresponsible lending practices will pose a significant risk to China’s financial sector.
The main issue with enforcing the loan limits is that China has a severely underdeveloped credit rating system and it is often very difficult to verify a borrower’s debt burden while underwriting a new loan. Regulators and platforms would not only have difficulty in determining the debt situation of a borrower across multiple lending platforms, it will also be challenging determine whether the borrower has outstanding loans across a variety of banks, financial institutions, or individual lenders. Perhaps the new policies would further encourage the industry or other government bodies to develop systems to monitor and share credit information of borrowers.
To further complicate enforcement of the rules, loopholes exist for platforms to circumvent the new policies. Institutions can register multiple entities using different legal representatives and spread out loans across these entities within the policy limits. After all, the “Interim Guidelines” does not stipulate limits on aggregate online loans taken out by related entities with different legal representatives. Similarly, individuals can use spouses, relatives, and friends to borrow on their behalf and the individual as the ultimate user of the funds can serve as the guarantor. The policies were most likely designed with this loopholes in mind as regulators do want to provide some leeway for platforms to operate. Ultimately, it would be up to the local financial regulators tasked with enforcement on how they want to apply the rule within their jurisdiction. Strict interpretation and enforcement on a regional level would most likely induce platforms to migrate their place of registration to jurisdictions that have more lax interpretation of the rules. Thus it would be unlikely for local financial regulators to introduce very strict rules considering the potential detrimental effects on economic activity and tax revenues resulting from platforms migrating to other regions.
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.
Financial Times | Aime Williams | Aug 2, 2016
Crowdfunding platforms have experienced a slowdown in deal flow for the first time in five years, in a sign that “armchair investors” are taking a more cautious approach to alternative investments.Crowdfunders, which provide online platforms allowing retail investors to take equity stakes in small unlisted start-up companies, form part of the UK’s burgeoning “alternative finance” ecosystem.
However, the number of investments offered online fell 17 per cent in the first half of 2016, compared with levels seen in the last half of 2015, according to research company Beauhurst.
The fall follows 10 consecutive half years of growth in terms of the number of deals offered to investors.
In value terms, Beauhurst found that crowdfunding platforms raised £87.4m in the first half of 2016, a drop of just over 4 per cent from the £91.3m raised in the previous six months. However, these numbers also include institutional investments in deals offered on crowdfunding sites.
“Equity crowdfunding relies mostly on armchair investors, who will presumably be quicker to retrench their investment activity when they’re fearful, and are therefore good real time gauges of investment sentiment,” he said.
Beauhurst’s data also show that venture capital and private equity firms slowed investment into UK start-ups and high-growth companies in the same period. Including these sectors, Beauhurst recorded a 20 per cent fall in the overall number of investment deals. Investment from institutional investors is now at the lowest level since the beginning of 2013.
Mr Madeira said the broader figures painted a “somewhat bleak” picture for equity investment in the UK’s high-growth businesses.
Bruce Davis, spokesman for the UK Crowdfunding Association (UKCFA), the trade body of crowdfunding platforms, said the dip in deals offered was just “a pause”.
“The market has had a slowdown because of Brexit, but we’re still taking a large share of the market,” he said. “We should expect some sort of blip around Brexit, we’re not immune to the economy.”
The UKCFA said it was confident deal numbers would begin to grow again. “The key to that will be strong signals from the government on strategy to see where it wants to see growth and investment,” said Mr Davis. “[Crowdfunders] are best placed to deliver that into the real economy.”
Peer-to-peer lenders, who make up the bulk of the “alternative finance” sector alongside equity crowdfunders, have also recently seen a slowdown in investors looking to lend to small UK businesses or consumers.
The UK’s financial regulator recently announced a consultation into both kinds of alternative finance company.
Progressa Release | July 29, 2016

Significant Growth Opportunity Targeted With GTA-Focused Model
VANCOUVER, BC--(Marketwired - July 29, 2016) - Progressa, Canada's fastest growing financial technology company focused on helping non-prime and near-prime Canadians, announced today a restructuring that moves the entire lending operations to the recently established Greater Toronto-area office. This decision was made based on the company's long term expansion goals combined with attractive initial feedback from the GTA market, as well as recognition of the large and highly skilled group of talent in the financial services industry.
Recently opened in June of this year, the Toronto based operations of Progressa has seen significant growth with 20 employees hired from over 1500 applications fielded from some of the brightest minds in finance and technology. With such encouraging initial results, the decision was made to move the lending operations closer to Canada's biggest financial centre, and into the same time zone as a large customer cohort, allowing for more efficient client service and increased hiring capacity. Progressa will also benefit from invaluable peer support from organizations such as MaRS located in the immediate vicinity of the new offices.
"We are very encouraged with the growth of the Toronto operation and saw significant growth opportunity in moving our lending operations East," said Progressa CEO, Ali Pourdad. "There are some difficult decisions to be made in business and unfortunately we had to say goodbye to seventeen dedicated team members in the Vancouver office as we shifted our lending focus towards growth in Toronto. We are incredibly grateful for their contributions and loyalty to the company and are sad to see them go. We are doing everything we can to provide support to our former employees during this transition period."
Under the new structure, all lending operations will operate out of Toronto while management oversight and non-lending services remain in the original Vancouver office. This provides Progressa room in Vancouver to grow the equally vital data science, software development, and marketing teams while it continues to expand its loan origination exponentially.
About Progressa
Progressa is Canada's fastest growing financial technology company focused on helping non-prime and near-prime Canadians seeking to improve their financial health. Progressa serves over three million Canadians who have had their credit rating impacted by overdue bills and items that have gone to collections. With the help of advanced data science and analytics, Progressa effectively evaluates credit risk and provides loan opportunities where traditional institutions cannot.
Source: Progressa Release
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.
Crowdfund Insider | | Jul 8, 2016

The Financial Conduct Authority (FCA) has announced a “call for input” in preparation for an expected review of existing crowdfunding regulations in the UK. The FCA will be revisiting rules surrounding investment based crowdfunding including both debt and equity.
In early 2015, the FCA conducted an interim review of crowdfunding regulations and concluded, at that time, there was “no need to change.”
Interested parties may forward their feedback to the FCA by September 8, 2016.
The FCA instituted formal rules for the crowdfunding sector of alternative finance in March of 2014. In 2015, approximately £2.7 billion was invested on regulated crowdfunding platforms, up significantly from about £500 million in 2013. The FCA states there are more than 100 platforms operating in the UK market or seeking FCA authorisation.
Christopher Woolard, the Director of Strategy and Competition at the FCA, stated it was the right time to review and reflect on the market growth;
“The crowdfunding market is an innovative and growing sector and one which we see as part of promoting effective competition. We introduced rules in 2014 to ensure consumers were protected without preventing the market from enhancing competition through expansion and innovation. Since then the market has grown rapidly and we want to explore concerns that have been expressed about developments in some aspects of the market. We believe now is the right time to consider whether our requirements remain appropriate and that we have the right rules to support the development of this dynamic market by ensuring consumers are adequately protected.”
The FCA highlighted specific areas of feedback for the loan-based crowdfunding sector including:
The FCA also stated its interest in comments on the effect on competition of the growth of loan-based crowdfunding. The FCA also signaled its intent to consult on applying the usual mortgage lending standards to Peer-to-Peer (P2P) platforms in order to give consumers the full benefit of these protections.
Regarding “investment based crowdfunding”, the FCA posted several requests for feedback;
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.
ProfitGuide | Robert Gold | June 24, 2016

Thanks to her generous parents, Arti Modi made it through university without student loans. Modi did have a credit card, but she almost never used it. It’s the kind of responsible behaviour she should have been rewarded for.
But to a financial institution, the then-recently graduated Modi’s debt-free conduct made her an unknown quantity. “I go to the bank and I try to get a really good loan out,” she recounts. “But unfortunately, I don’t have any credit files, so I don’t have the credit history to be able to receive an affordable loan rate.”
That was just over a decade ago. Today, Modi is the founder and CEO of Lending Arch, one of the many startups recently launched in the financial technology (fintech) space. The consumer borrowing platform, which went live last year, serves customers with the kind of profile Modi once had. Lending Arch, calls them “future prime”—meaning that they may not have a big credit score or a heavy credit file yet, but still have the potential to be good borrowers.
Here are three key lessons Modi learned while starting Lending Arch.
There’s a line of thinking in technology that you should get out in front of potential customers as quickly as possible, and worry about fixes and improvements later. This minimum viable product (MVP) strategy holds that “if you’re really happy with the way that [the product] works, you probably worked on it too long,” explains Modi. She disagrees. “You only get one chance to look good.”
It’s important to be proud of the product you put out into the market, Modi says. But she doesn’t dispute the wisdom of constant improvement. “Use [your MVP] as a stepping stool to be able to do further iterations,” she counsels.
Like any good entrepreneur, Modi believes her company has a defensible strategy that differentiates it from the competition. In Lending Arch’s case, it’s the kind of borrower the platform serves. Most lenders work off a potential client’s credit score, but Modi’s firm factors in details like employment, industry, education, and financial literacy. “There’s a huge amount of data that we’re able to put together … to be able to find those future-prime borrowers [among] those that have dropped off what our competitors are able to underwrite, or who the banks simply cannot look at,” she explains.
But Modi is also aware that there’s no shortage of companies trying to attract the attention of Lending Arch’s target demographic online. That’s where capital comes in. “You need to have a decent marketing budget to be able to actually position and market the platform that you’re putting out there,” she explains.
Online marketing is an especially expensive proposition if you’re in fintech. “Some of the most expensive words online are ‘insurance’ and ‘investing,’ and then of course ‘lending,’” she notes. Lending Arch is starting to look for channel and strategic partners to help get the word out about the platform and attract potential borrowers “What that will do is it will basically bring us customers at the point that they need a loan, but without using online digital marketing to be able to market to them,” says Modi.
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.
Financial Times | Emma Dunkley | June 20, 2016

EU states are to support small British businesses through a UK peer-to-peer lender in the first deal of its kind, despite uncertainty surrounding the referendum this week.
The European Investment Bank, whose shareholders are members of the EU, is to lend £100m to smaller companies through Funding Circle in a show of support for alternative finance in the UK.
The deal comes days before the UK’s referendum on its membership of the EU, with the Remain and Leave sides now neck-and-neck according to the latest opinion polls.
Funding Circle has facilitated more than £1.25bn of loans to 16,000 businesses in the UK since its launch in 2010. Over the past couple of years the platform has worked to diversify its investor base to include institutions, national governments and international bodies as well as individuals.
A spokesperson for Funding Circle said a “Brexit” vote would affect its ability to strike similar funding agreements in the future. Funding Circle confirmed its support for the Remain campaign on Monday.
Some European alternative finance providers are inserting clauses into their lending terms with UK companies in case of a Brexit, which could increase the cost of funding, according to one person working for a platform.
The new funding partnership is the first time the policy-driven European Investment Bank has lent through a peer-to-peer platform.
P2P or “marketplace” platforms operate online, connecting investors and borrowers.
Unlike banks, P2P sites do not take deposits and lend themselves, but act as an exchange, making money from fees and commissions. With nimble technology, P2P sites can facilitate loans more quickly and can serve customers who might not gain loans from the mainstream banks.
Samir Desai, chief executive of Funding Circle said: “Our partnership with the European Investment Bank is the first of its kind and represents another important step on our journey to creating a global marketplace where creditworthy businesses borrow from a diverse range of investors.”
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.
Borrowell and Equifax Canada Release | Andrew Graham | June 20, 2016

TORONTO, Canada (June 20, 2016) - Borrowell, a leading Canadian fintech lender, today announced a new service that gives Canadians access to their Equifax credit score for free. From the privacy and security of their own homes, Canadians can access their Equifax credit score through Borrowell’s easy-to-use website. Available for the first time in Canada, the no-obligation service allows consumers to learn about their financial wellbeing, without having to apply for credit.
In addition to allowing consumers access to their Equifax credit score, Borrowell’s simple-to-use service also provides information about the factors that may impact credit scores and recommendations on how to improve an individual’s credit worthiness. Furthermore, Borrowell will provide consumers with an updated score every three months, allowing them to track their progress.
According to a 2015 recent survey published by BMO Bank of Montreal, approximately 56 percent of Canadians said they have never checked their credit score, and only 14 percent check at least once a year. In an April 2016 survey conducted by Equifax of more than 1,000 U.S. consumers nationwide, only 27 percent of consumers check their credit score – with the majority of those consumers receiving their score for free from a third-party website.
Our decision to work with Borrowell is based on our mutually similar desire to work with consumers to provide them with the information they need to get started on the path toward financial wellness.”
As well as providing resources that help Canadians better understand their credit scores, Borrowell also plans to present consumers with personalized offers for third-party financial products in addition to its own loan products.
For more information, go to www.borrowell.com
About Borrowell
Borrowell is a Canadian fintech lender that offers fast, fair, and friendly personal loans. Its affordable, fixed-interest loans give Canadians a smarter way to access credit. A wholly online application process instantly provides personalized loan options to Canadians with good credit who want better alternatives to expensive credit card debt. Borrowell is backed by a number of investors including Equitable Bank, Power Corporation, David Chilton (The Wealthy Barber, Dragons’ Den), John Bitove (Sirius XM Canada, Mobilicity) and Joe Canavan (Assante Wealth Management). Find out more at www.borrowell.com.
About Equifax Canada
Equifax powers the financial future of individuals and organizations around the world. Using the combined strength of unique trusted data, technology and innovative analytics, Equifax has grown from a consumer credit company into a leading provider of insights and knowledge that helps its customers make informed decisions. The company organizes, assimilates and analyzes data on more than 800 million consumers and more than 88 million businesses worldwide, and its databases include employee data contributed from more than 5,000 employers. For more information, visit www.equifax.com
The National Crowdfunding Association of Canada (NCFA Canada) is a cross-Canada non-profit actively engaged with both social and investment crowdfunding stakeholders across the country. NCFA Canada provides education, research, leadership, support and networking opportunities to over 1300+ 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. Learn more at ncfacanada.org.