A conflict of interest between Investor and an Access Person (an employee of Fellow Finance) may arise if the Access Person or another Investor possesses information that is unavailable for other Investors with regarding the loan application available for investments in the Service (Fellow Finance website).
Fellow Finance offers the following services in which a conflict of interest may arise:
- Intermediation of peer-to-peer loans
- Intermediation of crowdfunded business loans
Fellow Finance has implemented a policy to recognize and prevent conflicts of interest. The conflict of interest prevention policy entails education, internal instructions and administration of access to the loan origination system.
The Access Persons follow and obey the internal policy of preventing conflicts of interest.
Access persons (employees of Fellow Finance) and immediate family (any of the following relatives sharing the same household as the Access Person: child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, including adoptive relationships. The term also includes any related or unrelated individual who resides with, or is financially dependent upon, or whose investments are controlled by, or whose financial support is materially contributed to by, the Access Person, including “significant others.”) can invest in loans only via the investor platform's user interface. Access Persons are prohibited to buy loans in the secondary market and require CEO permission to sell loans in such market. If an Access Person has invested in a business loan, all other investors in that loan will be informed via the loan details published in the online service. Access persons are prohibited to withdraw loans from investors.
However, if the abovementioned prevention mechanisms fail and conflict of interest arise upon loan application process, the Investors are informed about the conflict of interest before execution of investment. The investor will have an opportunity to withdraw his Investment. The loan application process may also be cancelled because of detected conflict of interest on initiative of the Investor or Fellow Finance.
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