Peter:
Several points to consider:
1) Lending Club still states the following:
"If you do not receive any Form 1099s from Lending Club or FOLIOfn by January 31, it likely means that your interest and other payments did not meet Form 1099 criteria for receiving a form."
2) What it appears to me is that Lending Club is treating the "Notes" the same as a "discounted bond", thus meeting the IRS requirement of the 1099-OID in active years and a 1099-B in the year that the bond matures.
So it is possible that many lenders will still not receive 1099s as the IRS only mandates a 1099 of any type when the reporting amount is $10 or more.
3) Since Lending Club is now going to issue 1099-OIDs on notes issued after 10/14/2008, what is interesting is that if they issue 1099-OIDs for 2012 then they should be required by the IRS to issue a matching 1099-B for 2013 for ALL notes that "Mature" in that year. In the 1099-B case, lenders may still be under the $10 rule.
Bottom line, tax reporting on a retail 800+ loan portfolio could become a labor intensive effort as the 1099-B will require a basis amount and the total of the prior years OID amounts to avoid DOUBLE taxation.
My concern is that they maintain the $10 rule and don't provide 1099s under that amount.
I understand that you have contacts at LC and hope that your new Tax blog entry can clarify their future direction.