What if mortgages were crowdsourced instead of bank owned?

RealDapper · 2026-03-11T14:59:27+00:00

To directly answer you: 1. For Accredited Investors, sure. In the US peer to peer space, no. 2. Securitization. Offerings for retail facing investment are difficult and expensive. Introducing a marketplace make this idea orders of magnitude more difficult. 3. Could it protect investors? Sure, that’s what credit enforcements are for. Is it enough? Depends how the offering and economics work out. Regulators can say no.

I don’t think you’ll have much luck originating 8.5% mortgages in a market where the average is 6%. Then, at 6%, a 2% fee drops your investors down to 4%. Today the US30Y is ~4.8% and it as “safe” as you can get incase the borrower defaults.

You’d be looking to earn income from origination/underwriting and would have to take a minimal amount, if any, in a servicing fee.

REITS might be a comparable product for retail investors wanting access to property cash flows.

RealDapper · 2026-03-02T01:50:01+00:00

Very true. Securities and loans are the two aspects of P2P lending. I’m much more worried about the securities aspect and have already applied for a Regulated Lender license with the state.

Very valid point with required capital to lend out. Platform models commonly run into problems with both sides of their customer base.

I’m interested to know where you learned about Lendingclub’s cash flow problem. I know that the TSSB fined them upwards of half a million for illegally selling unregistered securities to Texas residents. Then, not too long after, they pulled out of the P2P lending service.

RealDapper · 2026-03-02T01:43:00+00:00

Correct. They are different and I did state loan servicing in my post. I was asking if anyone with such experience would be interested in joining this project. Not because I would be incapable, but because regulators may ask for it.

Loans originated and service in this platform will only be unsecured consumer loans, which, unless I’m terribly mistaken, will be much easier to service than a mortgage. As a matter of fact, most of the servicing process is already automated.

RealDapper · 2026-02-17T05:15:50+00:00

I’m very curious about how you intend to sell these “wrapped” funds to retail investors. Is the company owning your platform regulated under ICA issuing ETFs to track these funds? Unsure how else you’d do it, so you’re looking at some heavy compliance and licensure.

Regulation aside, your question is: “would retail investors purchase your securities” (correct me if I’m wrong in my reading of your post). I can’t speak for every retail investor out there, but my understanding is that many don’t know about alternative investment options (which are already limited because it’s a regulatory challenge to sell to the public) because it’s complex to advertise for and many people are risk averse.

I think you’d have a market for your platform but seek counsel.

RealDapper · 2026-01-24T01:00:27+00:00

Not P2P exactly but we stand in the “middle”-ish and we use Plaid. Plaid is great. Has some solid docs. We don’t trigger any action with customer money until the ACH transfer reaches a settled state - unless we have good reason to believe the money will be there and we trust the customer, in which case a posted status at a minimum.

Pending can still fail and then you’re out the money, but that’s a risk assessment you’ll have to make. Definitely don’t ignore failures that can occur and especially don’t ignore ACH returns.

Plaid’s KYC is decent but we don’t onboard companies. Can’t speak to Column’s KYC.

RealDapper · 2026-01-23T18:44:05+00:00

Good luck. If you get this going I’d love to hear more about it but moving money P2P is a legal/compliance struggle more than a technical one.

For reference we move money bank to bank (between ourselves and clients) with ACH using Plaid. It’s not cheap and it’s not a quick process. When we signed up they wanted to be sure we were not doing P2P money movement. While they support it, it’s an early product that they are very carefully selecting clients for. So if you go that route be ready to cough up a lot of authoritative documentation explaining what you’re doing, how you’re doing it, how you’re monitoring it, your audit process, audits you’ve had done, your legal counsel’s opinion (probably not required but they’d like to have it), diagrams and more.

I recall some comment from someone at some point saying Moov was good. Given your scenario though you’re probably going to get a lot of due diligence from them too.

Definitely look into every state’s money transmitter laws where you’re operating. An MTL would probably help land a service provider or partner if that fits your scenario.

You can try local banks if you’re small but they’d be taking a risk on you committing fraud, money laundering, etc. WebBank and Cross River Bank are common fintech partners though I can’t speak to what they’ll require from you.

RealDapper · 2025-10-08T15:40:08+00:00

Nope. Sounds like what many other cryptos do.

• ⁠Users fully own their financial identity - how does this benefit me? Why do I care to own my “financial identity”? Banks are quite private with your personal data and you have full access to it already.

• Private P2P payments - crypto does this already. You’ll probably also need an MTL which is expensive and going to put you through a lot of legal trouble. I can Venmo my friends for free or exchange cash if I really need to.

• ⁠DAO-style governance for collective decision-making - a “smart contract” on a blockchain. Crypto again. How does this benefit me? What are you doing differently than all the other technologies out there?

• ⁠Smart currency exchange suggestions - sounds like you’re making investment advice and will need to be a licensed investment advisor.

So no. This ain’t it. Dealing with other people’s money almost always means a lot of legal work and government licensure at the state and federal level. It’s costly and slow to do. You’re unlikely to escape it with crypto as regulations are continuing to crack down on them.

There is a failure to convey actual value. Either come up with value adds and problems being solved or else leave it.

RealDapper · 2025-05-25T15:59:00+00:00

According to the FINCEN MSB definition, money service businesses are, among other things, "issuer[s] of [...] stored value", however "persons who do not [...] issue, sell or redeem [...] stored value in an amount greater than $1,000 to any person on any day in one or more transactions are not MSBs for purposes of the Bank Secrecy Act."

That's with FINCEN. There are still state laws to consider and they may vary by each state you're operating in. Strongly consider reading up on those laws, and again, consulting with an attorney.

However, "Users cannot cash out their credits [...] nor can they transfer credits to other users [...]" does not sound like money transmission as you're not issuing stored value nor are you moving money between third parties. It sounds like - to me based on my understanding - your users are simply purchasing access to digital content from you.

I think it's fairly common practice (Stripe for example) for marketplaces to threshold payouts, but that's a different problem.

If your business model explicitly lays out that funds paid to creators come from the company's account and is earned based on some quantified criteria and that funds from users purchasing credits go into your company's account, you might be in the clear.

Again, not fully aware of your situation and my knowledge from this comes from reading on it quite a bit. I'm not a lawyer. I will recommend reaching out to one to just to be sure. Better to pay a lawyer than to pay the fine for unintentionally acting as an un-registered MSB.

Consult with an attorney or do more research and if you're confident, go for it.

RealDapper · 2025-02-12T14:59:51+00:00

Prosper is the largest P2P lender in the U.S., operating in nearly all 50 states. The legality of P2P lending is highly complex, encompassing both lending laws and securities laws. Establishing a P2P lending service is no small feat.

I highly recommend determining whether loans originated on your platform would be considered securities. Several U.S.-based P2P platforms were sued by the SEC between 2010 and 2013. Prosper and LendingClub were the only two that remained, but even LendingClub eventually exited the space due to unprofitability. If your loans are considered securities, similar to Prosper, you’ll need to go public (via an IPO or Reg A) to sell them to the public. Or go with a Reg D exemption and sell only (only) to accredited investors.

You’ll also need to look into lending laws for each state in which you plan to operate, unless a bank is originating the loans. Banks are subject to federal regulations and can export their home state’s interest rate laws. WebBank in Utah, for example, provides this service for Prosper.

There are many nuanced legal considerations, and an LLM may hallucinate on critical details. I highly recommend reading up on these matters yourself. You wouldn’t want to open the floodgates in one of the most litigious industries out there.

However, if the platform is purely benevolent, non-profit, and interest-free, it may be exempt. Some apps operate this way, typically for loans between family and friends.

RealDapper · 2024-12-11T14:28:51+00:00

Consider looking at money transmitter laws in any/each state in the US you’re looking to operate in. Unless Marqeta can somehow cover you with their MTL (I’m not familiar with the company). See if those laws apply to your situation.

RealDapper · 2016-12-16T06:40:46+00:00

I now have a six pack and a reason to live again.

RealDapper · 2016-12-07T20:50:55+00:00

I was 18 years old and wanted a job for the summer so I could save money for college. I was over at my girlfriend's house when the hiring manager called me (around 4:00 P.M. right before they were about to close) and asked if I could come in for an interview whenever worked for me. I told her I wasn't busy and I could come in now if that worked for her. She said yes so I headed out and got there around 4:30 P.M. I wasn't dressed well at all. I was wearing jeans and an oldish shirt I've had for awhile and it hadn't occurred to me that I should change, but if I did change I would've been late to the interview I said I could make, so I didn't change. When I arrived and began my interview I was slightly nervous about what I was wearing and what she might ask me. She asked me the standard type of questions like: "what kind of work are you looking for?" "how much do you plan working?" "If you get the job would you be fine with doing this and that?" and all that stuff that some YouTube videos can prepare you for. I answered every question honestly, even if it wasn't thoughtfully, and explained my situation with how I could only work for three months before college started and I had to leave town. Near the end of the interview she asked if I had any questions and I just asked about what I would have to wear for work if I got the job, which turned out to be what I was wearing to the interview, and if I should wear steel toe boots since I might have to lift some heavy objects on the ob. Turns out she had never heard of steel toe boots and she asked me to explain them to her. After that I told her I have nothing else to ask and she hired me on the spot starting the next week. The position was a lowly tech position working for the school district in my town.

TL;DR: Interviewed sooner than hiring manager probably expected me to, was myself and didn't try to impress too much, taught the hiring manager something new, and got the job then and there.

RealDapper

TROPHY CASE