David W. Perkins
Analyst in Macroeconomic Policy (Macroeconomic Policy Analyst)
Congressional Research Service
Washington, District Of Columbia
Dear Mr. Perkins,
Thank you for your updated CRS Report named: Marketplace Lending: Fintech in Consumer and Small-Business Lending.
Thank you for also recognizing that "peer-to-peer" lending terminology is often applied in a misleading manner.
Two suggestions to you for your next version of your report, if you don't mind:
1 - Regarding your Footnote 1:
Two notes on terminology: The term peer-to-peer lending was widely used during the early development of the industry. Marketplace lending includes peer-to-peer lending but also refers to a wider range of lending activity. Peer-to peer lending involves selling loans to individual people [ NOT NECESSARILY CORRECT - the test is based upon who carries the primary burden of compliance, which is the "lender" not the "borrower; indeed, the term ("peer to peer lending") itself defines the primary process, namely, lending. For example, a typical peer-to-peer transaction is not defined by the borrower, it is the classification of "lender" that matters. Individuals (or privately held corporations) who lend their own private equity funds have the least regulatory compliance requirements of all classes of "lenders". AN ONTOLOGY-CORRECT phrase would be: "Peer-to-Peer lending involves private individuals who use their own private equity capital to invest in secured or unsecured lending opportunities to applicants (individual and non-individual) who seek to borrow funds." ] and used to be a very prevalent business model in the industry. However, large institutional investors and hedge funds play an increasingly prominent role in funding marketplace loans, making the term peer misleading.
2 - Regarding your Figure 1:
"Examples of Marketplace Lender Business Models" does not appear to be formed from ontologically sound, process-based assessment of the "actual or ostensible business activity". For example, "Direct Lending" is a term synonymous with "Peer-to-Peer" lending where the applicant interacts directly with the lender. Indirect Lending is typical of "pooled funds" (ie: institutional investors) who seek to enter into a lending transaction by the applicant does not interact directly with the lender.
Finally, "who am I?" and "why should you consider my suggestions?"
My name is Anoop Bungay and you will discover that your's truly developed the world's first Crypto-/Peer-to-Peer (P2P)/Private/Secret/Shadow financial system with both regulated and non-regulated components, continuously registered since May 9, 2008 (over a decade) to the USA NIST (National Institute of Standards and Technology) ANSI (American National Standards Institute) Risk-Based, Quality Management Systems standard: ISO 9001:2015 (and it's predecessor standards; ISO 9001:2008 and ISO 9001:2000). The Crypto-/Peer-to-Peer (P2P)/Private/Secret/Shadow financial network (found at www.privatelender.org) was brought "online" on April 9, 2005 and was built on seminal BlockChain principles first identified when developing the peer-to-peer finance ontology. Indeed, Privatelender.org - a Canada-based website - is the first application of "BlockChain-in-finance", based systems and technology as described in a proprietary dissertation entitled: Binary Digit Debt: A Peer-to-Peer Electronic Finance System. The binary digit debt instrument (generically referred to as 'electronic debt"/e-debt/crypto-debt) is marketed globally pursuant to the Madrid Protocol as a US Patent and Trademark registered brand, namely "BITMORTGAGE®". The BITMORTGAGE® brand of peer-to-peer binary digit debt instrument predates, by over 4 years, the introduction of a binary digit currency (payment) system; genericized in name as as "bitcoin".
In order to maintain over a decade of continuous registration to the USA NIST/ANSI National Standards, many years of primary research was invested in order to build an acceptable, sound ontology in the field of peer-to-peer (Crypto-/Private/Secret/
- is successfully harmonized peer-to-peer to financial activities to the National and International standard of 119 countries.
- is built on the world's first internationally recognized, defense standard, military/law enforcement-grade, turn-key, plug 'n play (PnP), end-to-end (E2E) "secure, risk-based meta-operating system" built on artificial algorithmic intelligent (AAI™) BlockChain principles; designed to assure statutory, regulatory and process conformity of a regulated organization (regulatee) within any industry sector.
Should you be interested in learning more, please visit www.mqcc.org. While peer-to-peer lending was our original business, MQCC spends most of it's time marketing to Governments, Legislators, Regulators and Regulatees in order to educate and implement systems and technology related to matters of supervisory tech and conformity science; a new field of study borne out of the discovery of the application of "BlockChain-in-finance" - see www.conformity.org to learn about conformity science.
Thank you for the opportunity to share the two suggestions with you, Mr. Perkins,
Your's truly,
/s/
Anoop Bungay
If you have questions, please contact me at your convenience. In order to prevent errors and omissions, email is the preferred choice of communication.
Thank you for choosing MortgageQuote Canada Corp., 'Proud sponsor of the Canadian dream.'®
Sincerely yours,
A. K. (Anoop) Bungay
President
President
MQCC™
The First Name in Global Blockchain Conformity Systems & Technology™
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