Archive for 2017

Two U.S. Senators Say ‘Not So Fast’ to OCC’s Plans for Limited Charter

January 10, 2017
Article by:

Senator Sherrod Brown & Senator Jeffrey Merkley

The limited fintech charter concept is meeting resistance from prominent Senate Democrats

Senator Sherrod Brown (D) and Jeffrey A. Merkley (D) both believe that the OCC does not possess the authority to grant the limited purpose charters it plans to move forward with. In a letter penned to Comptroller Thomas Curry on Monday, Brown and Merkley raise several concerns including that such charters would only blur the lines between banking and commerce, pointing out that an applicant need not necessarily be a fintech company to apply, nor need or want to accept deposits.

“As state banking supervisors have pointed out, because so many companies under an alternative charter would be exempt from the Bank Company Holding Act, nothing would ensure that both bank and currently impermissible non-bank activities were intermingled in one company, and that a commercial entity could not create or acquire an alternatively chartered company,” they write.

Brown and Merkley’s other concerns may be premature since the OCC is currently seeking information from the fintech industry on such issues in its official 13-question Request for Comment (found on the last pages of this document).

The full letter submitted to Comptroller Curry can be viewed here.

Confessions of a Fintech Chief Data Scientist

January 8, 2017

Justin DickersonMy name is Justin Dickerson. For most of 2016, I was the Chief Data Scientist at Snap Advances (Snap), a funding company of merchant cash advances based in Salt Lake City, Utah. I can’t discuss my awesome work at Snap for obvious reasons. And fortunately, I don’t need to in order to make the key points I want to convey through this article. That’s because I’ve also been a senior level data scientist at two other companies, and I’m also a well-regarded statistician who holds one of the most prestigious credentials offered by the American Statistical Association.

One discovery over the past year prompted me to start collecting my thoughts for this article. I was looking at the financial performance of On Deck Capital (the largest company in the alternative fintech industry which is also publicly traded) through the first nine months of 2016 relative to the same period in 2015. Gross revenue increased more than $22 million while net income for the same period fell nearly $50 million. I’m not an accountant, but that doesn’t sound good to me. And let’s face it, this fact doesn’t surprise anyone in our industry, especially given what’s happening at CAN Capital. But one interesting and overlooked fact is worth considering. According to my Linkedin search, there were between 30 and 40 data scientists (all levels) working for On Deck Capital during the same time period in which they lost $50 million. So, not only does On Deck Capital lose a lot of money, it appears they need a lot of intellectual horsepower to figure out how to do so.

And here we are today. We’re looking at an industry full of companies trying to navigate the abyss of hyper-aggressive originators and spiraling default rates. If you’re a Chief Data Scientist for one of these companies, you’re undoubtedly feeling the heat from your management team. The problem is simple. How do you grow your business (or even stabilize it) in an environment where you have to take too many uncomfortable risks? We’ll ignore the fact this question has plagued much larger industries for many years (e.g., trying to compete against Wal Mart in the retail space). Boards of Directors in alternative fintech have short memories and believe this is a unique problem to their industry and era. As a result, data scientists are at a premium as they’re seen as key players in how to resolve this crisis and steer their companies to safe harbors. Well, here is my opinion. They’re dead wrong, and here is why.

Data Scientists Are Tactical, not Strategic

This statement may end up being the most controversial thing said in the data science industry this year. But let me make my case. Of those 30-40 data scientists working for On Deck Capital, more than 80% of them have a Master’s degree in a field of study synonymous with data science. Specifically, many of them attended Columbia University’s Master’s degree program in Operations Research. The four required courses for that degree are: Optimization Models and Methods, Introduction to Probability and Statistics, Stochastic Models, and Simulation. From there, students can choose from one of six concentrations (all but one of which are targeted toward quantitative methods). Further, students selected for this program already have highly refined quantitative skills as demonstrated by the pre-requisite courses for admission (e.g., multivariate calculus, linear algebra, etc.). So, in essence, the program takes really smart quantitative people (quants) and makes them even smarter quants, while sprinkling in 6 elective courses which may or may not provide an opportunity to learn something about the “real” world of business.

Make no mistake, the students attracted to programs such as these generally aren’t the professionals you send to meet with investors and pitch them on new strategic directions for a company. They are the professionals who sit in cubicles and spend their days writing code. They are experts in programming languages such as R, Python, Java, Scala, and many others. Ironically, they are enslaved to similar rules which govern the same supervised machine learning algorithms they create each day. They aren’t allowed to “get out of the box” and see the “forest through the trees.” If I’m portraying them as a bit robotic, that’s intentional on my part.

I don’t want to leave the impression data scientists can’t think for themselves. Specifically, those who earn a PhD are known to have such skills and are often praised for their abilities to rise above the technical chains of their existence and offer strategic direction to an organization. But they are few and far between in the data science factory found deep in the bowels of companies like On Deck Capital. Instead, more and more alternative fintech companies seek out the same “cookie-cutter” data scientist who can check off the same boxes on the hiring list. This means the data scientist role is relegated to a part of the company lacking diversity of thought, creativity, and the organizational respect needed to save a company from itself.

The Law of Diminishing Returns

One of the most intelligent questions asked of me within the alternative fintech industry was, “do we really have enough data to justify so many data scientists?” As a Chief Data Scientist, you always want to answer that question with an emphatic, “YES!” Even better, you may tell your management team you need even more data scientists to make a “real and lasting contribution to the company.” After all, the existence of your team depends on it. But when you’re away from the management team and thinking about the structure of your department, the honest Chief Data Scientist knows the company is at risk of experiencing the law of diminishing returns.

All of us can recognize the law of diminishing returns from our freshman year Economics course. In short, it’s the concept of achieving less than a one to one relationship between an additional unit of input relative to the resulting measured output. For example, the reduction in default rate for a financial product is hardly ever proportional to the number of data scientists employed by the company to predict default rates. In fact, I would argue once you have more than two or three data scientists, even the largest organizations would have a difficult time justifying the payroll investment based on proportional gains in default rate management.

So, why do companies like On Deck Capital have so many data scientists? I believe it’s more akin to the comfort food we all like to eat in the winter. There is hardly anything as satisfying as my grandmother’s homemade chili during a cold Utah night. And the more of it I get, the warmer I feel! The problem is the chill of winter eventually fades and the light of day shone on financial statements eventually begs the question of whether we’ve simply eaten too much.

Make no mistake, NO organization needs endless amounts of data scientists to be successful. In fact, I would argue two or three excellent data scientists armed with superior data science/machine learning platform technology such as those offered by IBM, Microsoft, or DataRobot is more than enough to guide an organization to success. The key when thinking about staffing a data science department is to think in terms of credibility. If I have three data scientists each armed with PhD training, 15 years of industry experience, and the tools (such as a great machine learning platform) to do the mundane parts of data science usually done by legions of Master’s degree data scientists, am I more credible in the organization than I am with 30 quants who all grew up in an economy where nothing bad ever happened to financial institutions? If you want your data scientists to help your organization, you’ve got to be willing to let them into the board room and present digestible recommendations for action. So the question becomes, do I have a team that is credible enough to meet such a standard?

The Supremacy of Domain Expertise

I learned a lot during my time as a Chief Data Scientist. Since leaving Snap, I’ve established two companies. The first is Crossfold Analytics. This is my data science consulting company. We only serve the fintech industry and we spend most of our time building real-time machine learning prediction services for small to mid-sized fintech companies. And I think we’re darn good at it! The second company is Crossfold Capital. This is my independent sales organization (ISO) focusing on merchant cash advance, business loan, and factoring products. It was when I established Crossfold Capital that I learned the most valuable lesson of all about data science in alternative fintech. Nothing will ever replace the experience of working in the trenches of the business (what I call “domain” expertise). In alternative fintech, this is generally working within the trenches of a sales organization. If I could go back in time and start over as Chief Data Scientist at Snap, I would start my job by underwriting files and selling merchant cash advances for a month. Absolutely nothing I learned in math, statistics, or any quantitative subject can replace what I’ve learned running my own ISO in just the past two months. I wish every alternative fintech company would adopt a training program for data scientists that allowed them to spend their first month in the field calling on clients and working with potential customers. If you understand the business, you can bring immeasurable value to your company by blending that understanding with your technical skills as a data scientist. I truly believe such an approach could take the power of a data scientist and magnify it three-fold. Otherwise, you end up having a rogue department of quants that people in the trenches of the business either don’t understand or don’t trust.

My Recommendation to Alternative Fintech Companies

Based on what I’ve learned as an alternative fintech data science professional, I would make three recommendations to all companies in our industry. First, hire diverse talent. It’s imperative a data scientist knows enough about coding to be effective at building predictive models. But I would trade extensive coding expertise for a data scientist who also had a Bachelor’s or Master’s degree in business administration. We don’t need an army of robots in data science. We need gifted thinkers who also happen to have advanced technical skills. Second, don’t “over-eat” even though it can be cold outside. More data scientists aren’t going to solve your problems. In fact, hiring the same type of data scientist only encourages “group-think” which can actually be very detrimental to your organization. Focus on building a credible data science department, not a massive data science department. Finally, put your smartest people in the dirt of the business. Have them spend a week underwriting files. Then send them to sell your products with one of your ISO managers. Don’t treat your data scientists as fragile figurines. As a good friend of mine from Texas says about his gun collection, “they may be worth a lot, but they’re so dirty from hunting you wouldn’t know it!”

I hope my confessions help your organization navigate both fair seas and choppy water.

My Marketplace Lending 2017 Projections

January 8, 2017
Article by:

2017 projectionsLendIt co-founder Peter Renton has projected that there won’t be any new industry IPOs this year. While I don’t know if I’d say he’s wrong (a year is a long time), one thing that has changed since 2014 is a shift away from the “tech” label. When OnDeck went public, they positioned themselves as a technology company. Today, they more closely identify themselves as a non-bank commercial lender. Lending Club too was a “tech company.” Now they might be more appropriately characterized as an online consumer lender, especially since their competitors are traditional financial institutions like Discover Bank and Goldman Sachs. So the public markets in 2017 may not be ready for a tech company that can lend but they may be ready for a lending company that has tech. The difference is real.

On regulation, while a Trump presidency may mean that federal regulatory threats will subside, my projection is that the judiciary system will instead play a prominent role in 2017. Whether it’s state courts or federal courts, expect the rules of engagement in marketplace lending or merchant cash advance to become more clear than ever before.

I think it would be easy to predict consolidation in 2017, so more than that, I believe some companies will just wind down and others who arrived too late to the game will just move on to something else. That’s not necessarily a pessimistic outlook since this will give the more serious players a chance to flex their muscles and continue strong growth. This is a natural cycle in any industry that experiences a rapid growth phase.

There will be at least one black swan event. We don’t know what we don’t know.

Lastly, if you want to come up with your own predictions you should attend the 2017 LendIt Conference this March in NYC as it’s the best opportunity to take the temperature and size up the future. I have been to the last three annual LendIt USA conferences and in my opinion each has set the tone for the rest of the year.

You can get 15% off the registration price with Promo Code: Debanked17USA.

Merchant Cash Advance’s David and Goliath End an Era

January 5, 2017
Article by:

David vs. GoliathBefore there was Capify and CAN Capital, there was AmeriMerchant and AdvanceMe. Those are the original names of the two industry rivals whose history goes back more than 10 years. When I started working for an MCA company in 2006, I was taught two things, that AdvanceMe claimed to have a patent on merchant cash advance’s core feature and that AmeriMerchant’s CEO was leading the charge to have it invalidated. Back then, AdvanceMe had sued AmeriMerchant and several other companies for violating its automated payment patent and it was the biggest threat to the industry’s future at the time.

A real life David and Goliath saga, it was only fitting that AmeriMerchant’s CEO was actually named David. His last name Goldin, he went on to win the lawsuit in such a big way, the story was featured in the New York Times. At that time in 2007, the Times quotes Goldin as saying, “It’s a victory against patent trolls. This has changed the landscape. The days of coming up with an obvious idea and patenting it and using legal extortion are over.”

With the patent invalidated, numerous entrepreneurs felt the coast was clear to start a merchant cash advance company, thus paving the way to become an industry that now originates more than $10 billion a year in funding to small businesses. AdvanceMe was a Goliath in that it held a virtual monopoly on MCA in the late 90s and early 2000s. They had such a huge head start on everyone, that they were still the largest MCA company in the US in 2014 (if you don’t count OnDeck which only does loans).

tug of warThat era is coming to a close. AdvanceMe, today CAN Capital, suspended funding in late November of 2016 after internal issues were discovered, which resulted in mass layoffs and executive departures. And AmeriMerchant, today Capify, announced it is integrating its US operations with another industry rival, Strategic Funding Source (SFS), who will be managing all of their US customers going forward.

While CAN Capital’s ultimate fate is still yet to be determined, the end of Capify’s US presence is an M&A event, the first one of 2017. An insider at SFS said on a call that Capify’s international operations were not part of the deal in any way. Goldin will continue to run his company’s other offices such as Capify UK like normal. In the US however, more than twenty of Capify’s employees are being transitioned to work as SFS employees and to work from SFS’s office.

In the transaction’s announcement, Goldin is quoted as saying “we are very pleased to have put together a deal with Strategic Funding that will provide our customers a future source of important capital. As a company that shares our values of providing simple, transparent and responsible access to capital for small and mid-sized businesses, it was a logical transition.”

SFS, founded in 2006, and today one of the largest MCA funders in the nation, is a worthy successor. In a way, the more things in this industry change, the more things stay the same. As a testament to that, the antagonist of the 2007 NY Times story is Glenn Goldman, then the CEO of AdvanceMe and today the head of Credibly, another MCA competitor that also underwent a name change.

At the time, Goldman wrote to the Times, saying, “Although we feel vindicated that the court found clear infringement of our patent by each of the defendants, we respectfully disagree with the court’s findings on validity.”

Ironically, ACH is now the main payment mechanism for merchant cash advances, not split-processing, rendering the patent battle that took place a decade ago practically moot. It’s the end of an era.

Strategic Funding Source Integrates U.S. Operations of Capify

January 4, 2017
Article by:

New York, NY – Strategic Funding Source, Inc., today announced that it has entered into an agreement to integrate the United States operations of Capify into its adaptive proprietary operating platform. Both Strategic Funding and Capify have been providing non-bank financing options to small and mid-size businesses for over a decade. This integration enables Strategic Funding to expand its US operations by marketing to and providing capital to existing Capify customers who will, upon renewal of existing merchant cash advances or business loans, become part of the Strategic Funding family of customers.

“We are very pleased to have put together a deal with Strategic Funding that will provide our customers a future source of important capital. As a company that shares our values of providing simple, transparent and responsible access to capital for small and mid-sized businesses, it was a logical transition,” said David Goldin, Founder and CEO of Capify.

As part of the transition, many of Capify’s New York-based employees will become part of the larger and growing family of employees at Strategic Funding. The transition also allows Capify’s existing U.S. clients and partners the opportunity to take advantage of a larger variety of financing options, while still benefitting from the same standards of transparency and integrity that they have come to expect from Capify.

“It is rare that two companies in the same industry can come together and craft a synergistic deal that serves the best interests and strategies of each – but this integration does just that,” stated, Andy Reiser, CEO of Strategic Funding. “We have been friends of David and Capify for many years and have collaborated on and co-invested in the financing of many businesses over the years. We share the same focus on technology and quality underwriting that our customers, partners and the financial industry have come to expect from us. This transaction only strengthens the relationship between the two organizations”

ABOUT STRATEGIC FUNDING

Founded in 2006 and headquartered in NYC, Strategic Funding has been recognized by customers and the industry as one of the most reliable and respected names in small business financing. With flexible financing options, we have provided over 35,000 small businesses with the working capital they needed to take advantage of opportunities and grow. To learn more, visit www.sfscapital.com

The Small Business Lender Rankings (A preliminary peek)

January 4, 2017
Article by:

Small Business Lender Rankings

Here’s a peek at how some of the industry’s largest alternative small business lenders were doing for the year in originations as they headed into the last quarter of 2016. This data should be considered an estimate and is obviously not comprehensive. Still, this should give you a clue where some players will end up:

Lender Q1 – Q3 2016 FY 2015 FY 2014
OnDeck $1,772,000,000 $1,900,000,000 $1,200,000,000
PayPal $1,000,000,000 $850,000,000
Square $550,000,000 $400,000,000 $100,000,000
IOU Financial $87,500,000 $146,400,000 $100,000,000

Other small business finance companies do more than just loans, with many doing merchant cash advances. And some companies work to get customers funded through other platforms when prospective customers don’t fit their risk box. The numbers below are origination approximations regardless of whether the customer was ultimately placed on their balance sheet or someone else’s and whether or not the transaction was a loan or MCA.

Funder Q1 – Q3 2016 FY 2015 FY 2014
Bizfi $415,000,000 $481,000,000 $277,000,000
Yellowstone Capital $350,000,000 $422,000,000 $290,000,000
Platinum Rapid Funding Group $135,000,000 $100,000,000

Platinum Rapid Funding Group Originated $180 Million in 2016

January 3, 2017
Article by:

A social media post by Platinum Rapid Funding Group CEO Ali Mayar, revealed that the Long Island-based company had originated $180 million in deal flow in 2016. That’s almost twice their 2015 volume, and is a new record for the company.

In Mayar’s post, he wrote, “Thank you to everyone who’s a part of this unstoppable organization for an amazing year and the best is yet to come.”

Below, a Platinum Rapid Funding Group photo from last year

Platinum Rapid Funding Group Uniondale, NY

My Three Year Anniversary of Investing on Lending Club’s Platform

January 3, 2017
Article by:

3 Years ExperienceIt’s been three long years since the first month that I ever bought a Lending Club note and to commemorate the event, I decided to go back and see what I did and share what I’ve learned since then.

In January 2014, I attempted to buy ten $25 notes for a total of $250, all of which were A and B-grade with 36 month maturities. Here’s what happened:

  • Four of them paid off early
  • Four of them are current and are just about to mature
  • Two of the loans ended up not getting funded

So I actually only ended up getting $200 worth of notes and the results were great. But I didn’t stop there. I went on to buy more than $85,000 worth of Lending Club notes over the next two and a half years. The last note I ever bought was on June 8, 2016. If you’re wondering if I’ve made money, I have so far, but that still assumes a doomsday event doesn’t happen with the rest of my outstanding notes that will mature over the next few years.

Here are a few things I learned since the day I first started:

Reinvesting isn’t guaranteed
There is no guarantee that a similar new note will be available to replace one that just paid off. In the immediate post-Laplanche era, there were very few notes on the retail platform to buy and sometimes even none at all. Any number of major events could cause a situation like this to happen on a marketplace lending platform so you need to be prepared to manage idle cash should there be few or no suitable replacement notes.

Early payoffs can be very bad
This is related to reinvesting but can be bad all on its own. Lending Club charges retail investors a 1% penalty on outstanding principal whenever a borrower pays off their loan early (so long as the loan is 12 months old). Few people seem to be aware of this and it really makes no sense. Consider that as a retail investor you not only lose the interest you would make for the rest of the life of the loan on a good paying borrower, but you also get hit with a penalty on top of it even though you as the investor had nothing to do with the borrower’s decision. That sucks a lot. And potentially even worse, but plausible, what if there were no identical notes available to replace the ones lost to an early payoff? You lose three times.

Other platforms and banks are working against you
Banks like Discover and Goldman Sachs are actively working to steal Lending Club’s borrowers. And when they are successful, loans get paid off early, which hurts your investments. I’ve had nearly 1,000 of my borrowers pay off early on Lending Club for some reason or another already, so this is a major phenomenon.

Diversification isn’t just about the letter grades
Don’t put all your money in 1 note, but also don’t put all your money on 1 platform. Lending Club is still just a single company so you should only invest a small percentage of your investable assets on it. I have placed smaller experimental amounts on other platforms such as Prosper, StreetShares and Colonial Funding Network (Strategic Funding Source.) And yet, the bulk of my personal investments are actually in more traditional assets.

Holes in transparency
One of Lending Club’s biggest draws has been its transparency with investors but there’s still a lot of information that is withheld. When a borrower pays off early, investors aren’t told why or how it happened. Are borrowers really refinancing a credit card or are they taking the money and going to Vegas for the weekend? Investors don’t know and the true use of funds isn’t verified. Is the borrower broke? Lending Club focuses on a borrower’s credit profile, not on how much cash the borrower has in the bank, which could be $0 or negative. I’ve encountered plenty of investors that have argued that a borrower’s cash flow history is a non-factor or a burden on approval speed, but coming from a commercial financing background, I am still shocked that a consumer’s historical cash flow plays no role in getting a three-to-five year loan.

When a borrower stops paying, don’t expect to know why
A common theme in the collections notes of delinquent borrowers is the dreaded “Called. No answer,” line which can repeat for days, weeks, or months on end. Some borrowers will just stop paying and then never answer Lending Club’s calls again or they’ll ask that they “cease and desist” from making future calls. Was it financial hardship? You won’t always get the satisfaction of knowing, making it truly a numbers game.

This is a speculative investment
The value of your portfolio might not have volatile swings, but there are numerous risk factors that can impact performance. Only invest a small percentage of your investable assets.

It’s a nice investment option to have
Investing in notes backed by consumer loans is a great yield opportunity for retail investors in a low savings account rate environment. Despite the risks, retail investors don’t have many alternatives to earn a decent return outside of the stock market. Hopefully marketplace lending platforms don’t completely move away from retail investors.