The fine print on how we work with you.
If you engage with us, we may collect, store and use the following kinds of personal information about you through the methods of contact you chose to use at the point of engagement:
More information can be found in the 'Using Your Personal Information' and 'Disclosing Your Personal Information' sections.
From time to time we obtain information from outside sources to help us carry out our business functions.
This information, which often contains personal data, may include:
If you wish to register on our Platform you will need to provide us with the following information, which we may also collect from third-parties:
We may also collect and retain:
If you provide information about other people, for example if you represent a borrower and you provide information about directors, partners, members, shareholders or beneficial owners other than yourself or you have the authority to enter a bid on our Platform on their behalf, then you confirm:
We may use your personal information to:
We will not, without your express consent, provide your personal information to any third-parties for the purpose of direct marketing.
We will share information with our banking service providers, only to the extent necessary for the purposes of processing and reconciling payments you make or receive via our Platform, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
In addition, we may disclose your personal information:
We may disclose your personal data to other registered members on our Platform, including:
We may provide personal data to third-parties, including:
Third-parties who process your personal data on our behalf are permitted to process your personal data in accordance with our instructions and we will take steps to ensure that the transfer and any on-going processing by those third-parties is carried out securely and in accordance with applicable privacy laws.
From time to time we undertake credit reference checks against borrowers and lenders (and against directors, partners, members, shareholders and beneficial owners of borrowers and lenders), guarantors and Agents:
When CRAs receive a search request from Invest & Fund they may:
We may give details of all loans taken through our Platform and how they are managed to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding. Other organisations may see these updates and this affect your ability to obtain credit in the future.
Any records shared with CRAs may remain on file for up to six years after your account is closed, whether any outstanding sums have been settled by you or following a default.
You can contact the CRAs currently operating in the UK. The information they hold may not be the same so you may consider contacting them all. They will charge you a small statutory fee. They are:
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on secure (password and firewall-protected) servers.
All electronic transactions entered into via our Platform will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure and that we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and other login details confidential. We will not ask you for your password, except when you log in to the website.
You may at any time:
We will keep your personal information for as long as you are a customer of Invest & Fund.
After you stop being a customer, we may keep your data for up to 5 years for one or more of these reasons:
We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
In the case of a personal data breach, Invest & Fund shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Information Commissioner's Officer ("ICO"), unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the ICO is not made within 72 hours, it shall be accompanied by reasons for the delay.
Our Platform contains links to other websites. We are not responsible for the privacy policies or practices of third-party websites.
Please let us know if the personal information which we hold about you needs to be corrected or updated, or update your personal details using your Invest & Fund online account.
The data controller responsible in respect of the information collected on our Platform is Invest and Fund Limited. We are registered with the Information Commissioner's Office, registration number ZA014196. The Invest & Fund Data Privacy Manager can be contacted via email here.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
Cookies may be either "session" or "persistent" cookies.
The website also uses third-party cookies (Please click here for further information).
We use both session cookies and persistent cookies on the website.
We may send to you the following cookies:
Overall, these cookies allow us to:
When you use our website, you may also be sent third-party cookies.
Our advertisers and/or service providers may send you cookies. They may use the information they obtain from your use of their cookies to:
Cookies do not contain any information that personally identifies you, however, personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.
Most browsers allow you to refuse to accept cookies. For example:
Blocking all cookies will, however, have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
You can also delete cookies already stored on your computer. For example:
Again, doing this may have a negative impact on the usability of many websites.
The Interactive Advertising Bureau is an industry body that has produced a series of web pages which explain how cookies work and how they can be managed. They can be located here.
Our website is owned and operated by Invest & Fund.
If you have any questions about our cookies or this Cookies Policy, please contact us:
Complaints should be directed to firstname.lastname@example.org.
We have a written complaints procedure, which can be viewed here.
You agree to provide us with information requested during the application process and comply with all our identification and anti-money laundering requirements to enable us to comply with all applicable laws, regulations, rules and regulatory guidance. We may require you to send us copies of relevant passports or other documentation sufficient to verify your identity. As a part of the application process, you must register with us the details of a bank account or building society account based in the United Kingdom and opened in your name. If at some future date you wish to change Your Nominated Bank Account, you may need to be re-identified for anti-money laundering purposes.
Invest & Fund matches Lenders who want a better return on their money with Borrowers who require a loan to fund a property development project. As with all Peer-to-Peer Lenders, the biggest risk posed to Lenders is if a Borrower does not repay their loan. Payments are not guaranteed if a Borrower defaults and so Lenders' capital is at risk.
The main risk for Lenders is if the Borrowers do not repay the loan to the Lenders within the terms agreed in the loan facility agreement.
The term of the loan may be extended in circumstances such as construction schedules have overrun, exit finance is not in place in time or a delay in selling developed units. Whilst I&F operates an active secondary marketplace there is no guarantee that a willing purchaser for a loan placed for resale will be found. So, Lenders may not receive their funds on the dates expected.
If the Borrower does not repay the loan, the legal charge over the property can be exercised to settle the outstanding repayments. However, you should be aware that payments are not guaranteed if a Borrower defaults and for that reason, Lenders’ capital is at risk. Loans in default may be prevented from being traded on the secondary marketplace.
To view our current bad debt rates, please click here.
I&F segregates client funds and holds security in the name of a Security Trustee:
Invest & Fund has prepared a Wind-Up plan which has been submitted to and reviewed by the FCA. This sets out the actions that it would take if the decision was taken to wind-down the business, to ensure that Lenders would be protected and that existing loans would continue to be managed effectively. The fully costed plan sets out how I&F would:
Lenders' funds may be held in the client accounts of panel solicitors engaged to deal with certain property finance transactions on behalf of Invest & Fund. As part of such transactions Lenders’ funds may be passed from Invest & Fund’s panel solicitors to solicitors acting on behalf of the Borrowers. These funds will be held by such solicitors in client accounts held with Account Bank(s) under the Solicitors Regulation Authority Client Money rules.
Invest & Fund’s panel solicitors hold their client accounts at FCA regulated banks which may include Lloyds Bank plc, Barclays Bank plc, HSBC UK plc, and Santander UK plc. This list is not comprehensive and is subject to change from time to time.
Invest & Fund is not responsible for the acts or omissions of the Account Bank(s) and if the Account Bank(s) were to become insolvent would not be liable for any shortfall.
Invest & Fund Limited is authorised and regulated by the Financial Conduct Authority (FRN: 711378). Peer-to-peer lending is not covered by the Financial Services Compensation Scheme (FSCS) and so if you suffer a loss, you cannot apply to the FSCS for compensation.
If you have a complaint you may be able to refer it to the Financial Ombudsman Service. Please see our Complaints Procedure for further details.
One of Invest & Fund’s core values is transparency, and we strive to make all relevant information readily available to enable Lenders to make an informed decision. No lending opportunities will be made available on the Invest & Fund website until they have passed the credit review process and been approved by the Head of Credit.
Invest & Fund will provide you with certain factual information about the Borrower, to help the Lender reach an informed decision as to whether to participate in a particular loan opportunity. This will include information about the Borrower’s background, the nature of the request, a description of the asset, the Borrower’s financial performance to date, management analysis, the legal position relating to security for the loan and a review of these key risks and relevant mitigating factors:
Please remember that Invest & Fund do not provide investment advice and if you have any questions about the suitability of a particular loan opportunity to you, please contact your Independent Financial Advisor.
Concentration risk is the probability of loss arising from a large exposure to a particular risk, for example an individual loan. Diversification is a risk management technique of mixing different loans in a portfolio, to reduce the concentration risk.
For that reason, you should consider spreading your exposure to risk by lending to more than one Borrower. If a loan is not available for funding in the Lending Marketplace at any particular time, you can check the Resale Marketplace for opportunities to trade loans for previously-funded applications with other Lenders on our site.
Invest & Fund undertakes its own detailed due diligence on potential Borrowers and their projects as well as seeking reports from professionals such as valuers, solicitors and surveyors, as appropriate. All of the loans are reviewed by the credit team and are approved by the Head of Credit who considers whether loans meet our credit standards and only then will they allow a loan to be drawn down if it is successfully funded. Invest & Fund always ensures that there is Borrower equity in any loan proposition, and there are legally enforceable guarantees in place.
Property development loans are released in drawdown tranches against the measured progress of the development. Every drawdown request is reviewed by our credit team and approved by the Head of Credit who considers the credit quality and must provide his sign-off otherwise the drawdown will not be allowed to progress. Although it has not happened to date there is also the possibility that the drawdown will not have attracted sufficient interest by the end of the auction, and so cannot progress. Either scenario may mean that the Borrower has to put in more of its own funds, restructure the drawdown or even seek refinance elsewhere. Any Lenders who have bid on a loan which has been refused or underfunded prior to drawdown will have their monies refunded. Lenders who are already invested in earlier drawdowns of the same scheme will have the benefit of the value of the security and guarantees if the scheme fails to progress. However, you should be aware that payments are not guaranteed and for that reason, Lenders' capital is at risk.
In common with some other Peer-to-Peer platforms I&F lenders gain exposure to direct lending and so benefit directly and fully (from which facility fees are deducted) from the interest rate paid, but as highlighted in this Understanding Risks section property lending is not without risks. I&F acts as agent so does not lend in its own right nor does it make any margin on interest rate earned, so I&F does not take lending risk or the associated legal risk. The direct nature of the lending means that it may be possible to argue that there is a contractual relationship between Lender and Borrower. The risk therefore exists that a Borrower could seek to take action against I&F (and/or the Security Trustee) and it is theoretically possible that the Lenders to that Borrower may be joined as party to such an action. Scenarios might include where we take recovery action on a defaulted loan or, if funding was not made available to future stage drawdowns (see Risk detailed above: ‘Drawdowns being refused or refunded’). I&F mitigates these risks by having its loan agreements and security documents drawn up by external lawyers and takes legal advice on a case by case basis before completing each new facility agreement and before taking recovery action. Unlike some other platforms our Lenders have no obligation to lend on subsequent drawdowns and it is made clear to Borrowers (who will have received their own independent legal advice before borrowing) that the funding of future drawdowns is not guaranteed. We have strong processes and sign-offs to ensure that we only take recovery action where a clear and verifiable contractual breach has taken place. Our position on recovery in default situations and the fact there is no obligation on our Lenders to lend on further drawdowns has been verified by our external lawyers.
Each application is closely scrutinised and numerous aspects are looked at both in isolation and in conjunction with each other. There are times where a negative aspect on its own might not be enough to merit a decline but combined with other aspects it may well be. Equally, that same negative aspect could stop us from wanting to review further information.
There are three key stages in the loan risk assessment process:
Loan risk is assessed by focusing on 1) the Property, 2) the Borrower and 3) the Security. The following list highlights some key considerations:
As part of the assessment of a particular borrower, a wide range of factors will be evaluated, which include:
All in all, there are a myriad of factors that can affect our lending decisions and it all depends on their individual weighting. The appetite and safety of our Lenders is paramount and whilst I&F will do its best to assist a Borrower with their project, if we do not feel that it is something that our Lenders would wish to see, it will be declined.
For those applications which meet our standards a credit summary is drafted by the Internal Credit team and approved by the Head of Credit. It is published on the platform when a loan is made available. It provides an evaluation of the skills, experience and creditworthiness of the borrower, as well as an assessment of the overall project and proposal.
Invest & Fund regularly reports on its financial condition to the Financial Conduct Authority (FCA). Invest & Fund has also gone through a number of fundraising rounds and gradually increased its shareholder base. If, however the Board of Invest & Fund was to decide to wind-down its operations or to fail then we are required by the FCA to execute a Wind-down plan, so we have such a plan in place, a summary of which is provided below.
The plan is designed to help facilitate an orderly management and run-off of the loan book but may not be as effective in a disorderly run-off situation.
From a structural perspective:
Under the plan Invest and Fund Ltd will retain responsibility for the management and operation of the Wind-Down plan supervised by the Executive Management Committee of the business and reporting to the Board. The following table summarises the roles of Invest and Fund Ltd, and the security trustee I&F Securities Ltd:
Invest and Fund Ltd
I&F Securities Limited (IFSL)
Once all of the Loans have been repaid and the Lenders funds returned to them then Invest &Fund will apply for formal permission from the FCA for its Part 4A regulatory permission to be cancelled.
The Wind-Down plan is designed to help facilitate an orderly management and run-off of the loan book but may not be as effective in a disorderly run-off situation. Despite the detailed planning it is possible however that the failure of Invest & Fund would result in some unquantifiable difficulties for lenders and borrowers as the Wind Down plan is executed.
Lenders will continue to be able to fund the existing loans that they already hold, the quality or status of the Lender’s security will not be affected by the Wind-Down. The security will continue to be held by the independent Security Trustee, I&F Securities Limited (IFSL), who will continue to operate independently. Funds which are retained in Lender’s online accounts or are unallocated to a loan are held in a segregated client money account under FCA CASS regulations.
Existing (‘live’) loan agreements will be allowed to run to term. Undrawn stage payments will continue to be posted on the Lending Marketplace for funding by the registered Lenders, and providing the funds are pledged then the funding will be able to be provided. But no new loan facilities will be agreed. Borrowers with live bridging loan will be unaffected. Although the issue of any potential loan term extensions will need specific consideration. For Borrowers with a live property development loan then undrawn stage payments will continue to be posted on the Lending Marketplace to attract funding. Borrowers who have not received an agreed Facility Agreement as at the date of the decision to Wind-Down will not have their applications progressed and will need to seek a new source of finance.
Customers may get in touch with Invest & Fund for any number of reasons. Many of these are simple queries or questions that arise as part of the day to day operation of their account with Invest & Fund or questions around the Invest & Fund platform and marketplace or resale marketplace. It may be that the customer simply wants an acknowledgement of an issue and an apology.These can and should be dealt with immediately, and as such these need not be processed through the formal complaints process instead these are logged as expressions of minor dissatisfaction on the complaints register.
However, if the customer is unhappy with the outcome, or wishes to escalate the issue, then this should be treated as a complaint and dealt with according to the standard process.
A complaint may be by any of the following:
Copies of the relevant documentation would be required to ensure that the above are entitled to complain and also to fulfil data protection requirements.
Level one customer complaints will be handled by the Compliance & Risk Manager , unless by exception another member of staff would be more appropriate. Examples of a level one complaint include minor administrative issues these are logged on the complaints register as expressions of minor dissatisfaction
No complaint should be dealt with by the person about whom the complaint is directed. Complaints against individuals must be dealt with by that person’s line manager.
Some complaints, because of the importance of their source, for example from a regulator or other external body, will be treated separately as a level two complaint. The CFO and OD must be notified in writing about all complaints received that are categorised as level two.
The CFO or OD will ensure that all such complaints are dealt with appropriately and escalated to appropriate management, as necessary.
Complaints may be made to Invest & Fund either verbally or in writing (by email or by letter).
By email: email@example.com
By post: Invest & Fund, HCP Building, Chichester Road, Ponswood, St Leonards on Sea TN38 9BG
By phone: 01424 - 717564
Upon the receipt of a complaint, Invest & Fund will undertake an investigation of that complaint. The investigation is undertaken diligently and impartially, in accordance with Financial Conduct Authority’s rules and guidance, together with consideration of regular updates provided by Financial Ombudsman Service.
The investigation will include:
The following timeframes apply;
The FOS leaflet "Your Complaint and the Ombudsman" will be issued with the 8-week holding letter (for Eligible Complainants only – see "Can I refer my complaint to the Ombudsman?" below).
At this point Invest & Fund needs to decide to either “uphold” or “reject” the customer’s complaint. This decision must be a considered and informed decision, and consistent with all the facts at our disposal. Invest & Fund aims to provide a high-quality response which provides a fair outcome for our customer and this is called the Final Response Letter.
Once a Final Response Letter has been issued then Invest & Fund will close its file. The letter will state if the complaint is eligible to be referred to the Financial Ombudsman Service and details of how to go about this will be provided.
Invest & Fund will provide prompt and full redress if it is at fault. In determining whether any redress is due to a customer, consideration should be given to the extent of any omissions for which Invest & Fund is responsible.
Our regulator, the Financial Conduct Authority (FCA) defines those people who are eligible to refer their complaint to the Financial Ombudsman Service (*Eligible Complainant) as the following;
Eligible complaints can be from an existing customer, a potential customer or a guarantor.
Complaints from non-eligible complainants will be treated the same way in terms of process, investigation and timescales, but they do not have the right to refer their complaint to the Financial Ombudsman Service. Non-eligible complainants are complainants who do not fall into the above definition and may include complaints to Invest & Fund from Professional Clients, Professional Counterparties, introducers and solicitors for example.
This would normally happen after Invest & Fund had issued its final response letter and if you were unhappy with the final decision. However, referral to FOS may also be made if Invest & Fund has not concluded its investigation within an eight-week period.
In cases that are eligible to be referred to the Financial Ombudsman Service (FOS), Invest & Fund will follow the FOS guidelines and if requested to do so will provide redress and will comply fully with any award made by the FOS.
Invest & Fund will cooperate fully with the FOS in the handling of complaints against it, and action any directions given by the FOS promptly.
Once investigated, the FOS will advise on the outcome of the complaint in writing to Invest & Fund.
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