ICC declined to comment when asked about how the money was raised. It insisted its investors were not retail and they understood the risks of property investing. A source close to the firm said that it had never accepted retail investors through social media promotions.
The company previously raised £5.6m from investors in 2016 and repaid them last month through an offering called London Delta, it added.
However, Alex May, a bond researcher who alerted Telegraph Money to the development, said that while mini-bonds were no longer allowed to be targeted at ordinary savers, there were still risks for existing investors.
Previous mini-bonds involving property developments, such as those run by London Capital & Finance and Blackmore Bonds, have resulted in pensioners and investors losing millions of pounds. The marketing of mini-bonds to retail investors has been banned since January 2020.
Ravensbourne Rivers bought the land for £23m in February 2018, according to the Land Registry. It borders a Millwall Football Club training ground and local authority fields.
While not impossible to gain planning permission for Metropolitan Open Land, overcoming the protected nature of the land would require “exceptional circumstances” according to London’s development strategy.
Bob Robinson, a director at DPP Planning and a planner of more than 30 years said an applicant in a similar position “would need to present a very strong case for the development and it would have to be seen to be providing significant benefit to the wider community.”
He added: “Significant measures would need to be in place to offset any flood risk before they could get permission.”
A Lewisham Council spokesman said: “The site is Metropolitan Open Land which is equivalent to greenbelt. This means the land has one of the highest protections possible and the Council would resist any proposed residential use. Development sites within Flood Zone 3 are subject to specific planning policies requiring the risk of flood and mitigations to be fully addressed.”
A source close to the firm said an offer for the land from a third party had been made.
ICC said it had also bought a £10m site in Kent in August 2017, for which it expects to win planning permission “shortly” for 187 apartments. It was granted planning permission for a separate 16-flat development in Lewisham in November.
Sir Nick Clegg declined to comment.
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