FinTech Peer-to-Peer Lending Platform — UK FCA Authorised

FCA COBS 18A P2P Platform Architecture

COBS 18A (Peer-to-Peer Lending): FCA-specific rules for P2P platforms.

COBS 18A requirements

• 1lender-specific risk disclosure (risk warning on every lender dashboard — "your capital is at risk"),
• 2lender classification (sophisticated, high net worth, restricted — limits on how much retail investors can invest),
• 3appropriateness assessment (retail lenders complete questionnaire — verify understanding of P2P risks),
• 4wind-down plan (operational continuity plan if platform fails — FCA requires documented plan),
• 5provision fund disclosure (if provision fund exists — accurate representation of cover).

Platform

appropriateness assessment workflow at onboarding, annual risk disclosure confirmation, investment limits enforced by account type.

Borrower credit assessment

• 1Experian/Equifax credit file (credit score, defaults, CCJs, IVAs),
• 2TrueLayer Open Banking AISP (6-month income and expenditure data — COBS 18A creditworthiness assessment),
• 3Companies House API (for business loans — director search, financial accounts),
• 4HMRC Making Tax Digital API (self-employed income verification — SA302 alternative).

Credit model

logistic regression (probability of default) trained on 5 years historical loan data.

Automated decision

• &lt
• 5 minutes for personal loans up to £15,000.

Manual underwriting

• &gt
• £15,000 or any automated decline that meets manual review criteria.

Lender portfolio

lender dashboard (invested amount, expected return, current yield, risk band distribution, expected default rate).

Diversification

automatic loan allocation (lender's investment spread across minimum 50 loans — reduces concentration risk).

Secondary market

lenders can sell loan parts to other lenders (liquidity mechanism — important for COBS 18A wind-down plan).

Secondary market API

loan part listing, buyer matching, settlement.

Lender tax reporting

annual tax certificate (interest income, FSCS protections).

IFISA wrapper

lenders can hold P2P loans in an Innovative Finance ISA — ClickMasters integrates HMRC ISA manager API.

P2P AML

• 1lender KYC (Onfido eKYC — identity + address verification),
• 2borrower KYC (enhanced due diligence for business loans — directors verified),
• 3PEP/sanctions screening (ComplyAdvantage — lenders and borrowers),
• 4source of funds declaration (lenders above £50,000 must declare source of funds),
• 5transaction monitoring (unusual lending patterns — rapid large deposits, unusual repayment behaviour). HMRC self-reporting: P2P platforms must provide HMRC with annual data on all lender interest paid (HMRC Reporting Rule — Third Party Reporting).

Fraud detection

ML model trained on historical fraud cases (account takeover, synthetic identity fraud).