Author: Zhou pure, Editor: Yang Hao, Publisher: Prism · Tencent Little Moon Studios

From the “two highs” on the criminal case of illegal lending, to the supervision and supplement of the financial guarantee by the Banking Regulatory Commission, the recent intensive regulatory documents have pressed the pause button for the rapidly growing Internet loan-sending business.

In the past two years, the low-cost funds of licensed financial institutions have coincided with the Internet platform with traffic and data. The Internet loan-sharing model has become the most active business in the financial technology field and has supported the number of China. A trillion-dollar consumer financial market.

There are rivers and lakes where there are money.

This mature and profitable business once attracted many traditional players, Internet banks, consumer finance companies, Internet giants, and loan-sending platforms to compete in the competition, and in this rich ecosystem, based on the strength of resources , automatically build a “hierarchical” pyramid.

Today, the lending rate is strictly limited to IRR(internal rate of return) within 36%, and the increasingly expensive traffic costs of the Internet, It is getting harder and harder to make the original win-win loan business. The Internet loan management method that has not yet been officially put on has made the Internet loan lending business face many uncertainties.

When money is not good, the rivers and lakes are beginning to change.

Supervised Plus: 36% of the actual annual interest rate secret

In November, He Qi (pseudonym) found that some of his buying volume groups began to become silent.

He Qi is employed by a licensed consumer finance company and is responsible for developing and docking lending channels. These purchase and sales groups, which are composed of funds, loans, and loans, are the information fields of the institutional funds docking traffic platform, and also an important channel for him to collect cooperation information in the past. However, after the strong supervision of the publication in October, the Internet loan-sending business was deeply affected, and the WeChat group also lost its former embarrassment.

October 21,The Supreme People’s Court, the Supreme People’s Procuratorate, etc. issued a notice on the “Opinions on Handling Certain Issues Concerning Criminal Cases of Illegal Lending”. In addition to the detailed sentencing provisions for illegal lending, the calculation of the lending rate has a unified calibre: > If the illegal lender is charged in the name of introduction fee, consulting fee, management fee, overdue interest, liquidated damages, etc., and pre-deducted from the principal, the relevant amount shall be included in the calculation of the actual annual interest rate.

According to Prism, the interest rates of Internet loans in the past were generally advertised at the annual interest rate APR(Internal Rate of Return) is more representative of the user’s actual loan cost, which is calculated by discounting all future cash inflows. The discount rate after the discounted value of the cash outflow is equal.

Many industry insiders told Prism that the APR 36% interest rate, if converted to IRR calculation, the interest rate is about 58% to 62%, the difference between the two is at least 20 points.

After the aforementioned regulatory documents were issued, Prism was informed that many loan-sending platforms are stepping up their products to make their actual interest rate not exceed 36%, including early settlement fees, penalty interest, overdue fees, etc. Etc., also count towards the actual interest rate. Even, a portion that exceeds 36% of the IRR is returned to the user.

Specially humble.” He Qi described their situation in this way. In his opinion, IRR 36% basically can’t make any money.

Strictly limiting interest rates is only one aspect. Only two days after the above notice was issued, the China Banking Regulatory Commission issued the Notice on Supplementary Provisions on the Supervision and Management of Printing and Financing Guarantee Companies (hereinafter referred to as “Supplementary Provisions”) ), which stipulates that institutions that provide customer referrals, credit assessments, etc. for various lending institutions may not provide or provide financing guarantee services in disguise without approval; for business licenses without financing guarantee business, but actually operate financing For the guarantee business, the regulatory authorities will ban it.

In the actual operation, the loan-in-promotion platform takes the risk of the loan business through the form of financing guarantee, which is the loan-sending business.One of the characteristics is also one of the prerequisites for licensed financial institutions to cooperate with the loan platform.

Huang Yan, a senior researcher at the Institute of Sacks, pointed out that many loan-sending platforms have acquired financing companies through acquisitions or self-built financing companies. The “family” jointly provided loans and loans to banks and other financial institutions, forming a “changing soup without changing medicine” type. The bottom of the pocket. From the perspective of the Supplementary Provisions, the lending institution may be identified as “funding financing guarantee service in disguise”. Although there is a licensed financing guarantee company involved, the actual risk is ultimately determined by the lending institution (or its actual controller) Bear, There is still compliance risk in the long run.

According to “Prisma”, since the official Internet loan regulatory documents have not yet been released, the loan-lousing platforms are all waiting.

One ​​hit: low cost, high yield business

The rise of financial technology in recent years has made Internet access a mainstream. A large number of “white households” (that is, users without any credit history), which is difficult to access the banking service, help with big data on the Internet platform. Next, become a new target user, and the risk premium brought about is obvious.

“The bank has a lot of cheap funds in hand. The Internet platform has the traffic and data, and the risk control capability. The two sides hit it off, the bank will pay the funds, the Internet platform will help the customers, and each will take the necessary expenses. The profits will be divided into proportions. Liu Fang (a pseudonym), vice president of the Department of Loan and Credit, explained the Internet loan assistance to Prism.

For example, the average interest rate of deposits of the Agricultural Bank of China as of the end of June 2019 was only 1.51% per year. Even for the city banks and rural commercial banks with higher costs in the banking system, the capital cost is about 7% to 8%. “This kind of capital cost rate is beyond the reach of the Internet platform.” Liu Fang said.

Anhui Jinfu Group’s president of Digital Finance Group Huang Hao recently wrote in Caijing that traditional commercial banks have more capital channels and lower capital costs, but the long-tail users have less data and the digital risk control capability is relatively weak; the Internet On the contrary, platforms or financial technology institutions have rich scenes that reach long-tail customers, and have mutualThe massive behavioral data under the networked ecology and the big data risk control technology that was exercised in practice, but the scale of funds is insufficient. Only through the cooperation and cooperation of the two sides, the advantages and complementarities can achieve the “p” and “benefit” in the true sense.

Generally speaking, the industry will divide the cooperation mode of financial institutions and Internet platforms into two modes: loan-assisted and joint-loan. The simplest difference is that both parties to the joint loan have the ability to lend (such as banks, consumer finance companies, online small loan companies) Funding and risk sharing; the loan-sharing model is mainly an Internet platform with or without lending qualifications to help financial institutions obtain customer and risk control, pay a certain margin to financial institutions, and introduce insurance or financing companies to carry out the bottom.

Introduction to Liu’s “Priss”, Big banks generally do not need to help loans, because it does not deserve customers, and they have the ability to do it; the main purpose of helping loans is to help some city commercial banks with weak customer and risk control capabilities. Agricultural business. The original competition in the banking industry has become increasingly fierce. Coupled with the strong impact of financial technology, the emergence of this Internet loan-sharing model is like a life-saving straw, which is firmly grasped by city commercial banks.

According to the incomplete statistics of “Prisma”, there are more than 20 cities and rural commercial banks that only cooperate with Internet giants such as BATJ. There are countless cities and rural commercial banks that cooperate with some small loan-to-loan platforms.

The financial report data of listed city commercial banks shows that the growth rate of personal consumption loans of 7 city banks including Shanghai Bank exceeded 100% in 2018, and the scale of personal consumption loans of Tianjin Bank increased from 8.793 billion yuan in 2017 to 77.796 billion yuan. Yuan, the growth rate reached 788.88%. As of the end of June 2019, the balance of personal consumption loans of Shanghai Bank, Jiangsu Bank, Ningbo Bank and Tianjin Bank exceeded 100 billion yuan.

In the perspective of banker Li Yi (alias), there is another reason for the outbreak of Internet syndicated loans in the past two years. Strong>Bank mortgage loans are subject to policy restrictions, resulting in the bank’s personal loan business incremental pressure on the non-mortgage loans, similar Internet model loans, insurance model loans become popular.

Li Yi is the president of a branch of a large state-owned bank. His bank currently has business cooperation with Ant Financial and Jingdong Digital. “Basically, we all pay out, they go out of the customer.”

In his view, for these customers who are applying for loans on the Internet, because their big data is not in the bank, or the qualifications are not up to the bank, they can cooperate with the giants to release higher-interest loans with low risk. At the same time, the nominal number of customers is the bank’s customers, which is equal to the mass acquisition of customers through the giant channel.

“The cost of getting customers is low and the benefits are not low,” he concluded.

Divided into: The traffic side is the biggest winner?

In the chain of Internet joint loans, the proportion of investment, the rate of loan lending, the management of post-loan, the collection of income, and the share of income are all linked together. Each ring needs negotiation and negotiation. However, many practitioners said to Prism that the place where the contradiction is most likely to occur is still in the profit sharing.

He Qi told Prism that in the initial joint loan model, the ratio of capital contribution is generally 1:9 (bank is 9) Later, at the request of suspected regulatory documents, the current funding ratio has become 3:7. In the loan-assisted mode, taking a product with an annualized interest rate of 36% as an example, the funder generally takes 10% to 15% of the product.

Liu Fang introduced the profit sharing model of the loan-assisted mode to Prism in more detail. Similarly, for products with an annualized rate of 36%, financial institutions need a fixed income, usually 10% to 15%. Among them, the capital cost of the city commercial bank is about 7% to 8%, plus its operation, management, and insurance costs. “It is very kind to leave the bank with 12%.”

Second, the remaining half of the income (returned to about 10% to 12% of adulthood) was taken away by the traffic platform. Liu Fang feels that as Internet traffic becomes more expensive and conversion rates generally decline, their customer acquisition costs are no longer lower than the cost of capital.

“Do you think that the last 10%~12% of the income is returned to our loan-sending platform?” Liu Fang asked himself, in which the bad debts should be removed at least 5%~6%, data fees and charges. Add up to at least 2%. “(Last)There is not much left.

Someone who sells water in countless Nuggets stories laughs at the end, Liu Fang feels that money is getting worse and harder to earn: “All work for the traffic party.” To this end, they can only optimize their data and style. Control ability, reduce the cost of obtaining customers, and thus strive for one or two points of revenue.

under the pyramid: the giant sucks most of the mass

In the rich ecosystem of loan and joint loans, if you want to ask who has more right to speak and bargain, different people will give you different answers.

In Liu Fang’s eyes, although the entire cooperation was actively promoted by their loan-help platform, the final decision was made on how to do it, and how to do it, and even how the profit is divided into such details, all said by licensed financial institutions. I have calculated. Because in this market, the license is more scarce than the loan. The loan-laundering platform is clearly at the bottom of the pyramid.

Although it belongs to the Internet platform, Internet giants like BATJ have traffic, licenses (such as Internet banking, small loan licenses) Resources such as big data are enough to get them to the top of the pyramid, and even once they are unwilling to bring financial institutions to “play together.”

Li Yi told Prism that in their joint loan business, the Internet giant clearly dominates, and the giant and the bank are a one-to-many model. The customer channel and big data are basically controlled by the giants. The bank only has funds, no initiative, and the customer is not sticky enough.

“The mortgage model is fine, and there is hope for conversion to a bank customer. If it is unsecured, it will be difficult.” He added.

A McKinsey report in 2018 states that in the past 2 to 3 years, Banking and Internet companies are gradually realizing the indispensable value of each other, tending to share cakes together, and the number of cooperation cases is gradually increasing, such as the four major banks in the state have established cooperation with BATJ, joint-stock banks and city commercial banks Also in action.

“But both parties are extremely cautious in this kind of partnership.” The report said that Internet companies will cooperate with a number of banks to deliberately avoid a single situation of bank partners, resulting in excessive bank capacity and direct access. Internet companies’ customers; likewise, the banking industry is also trying to build its own regional or business advantage, avoiding signing agreements with Internet companies that only exchange the bank’s balance sheets and licenses, but more about the customer’s data.

But now, the regulatory layer’s restrictions on Internet small loans and ABS (asset securitization) have made the Internet giants rely on their own small The model of lending and ABS leverage to obtain funds lending has become unsustainable. This is also the reason why the giants have started to “de-financialize” in the past two years and transform into a financial technology empowerment platform.

For example, in March 2018, the head of Ant Financial’s micro-credit business revealed that Ant Financial has been actively exploring cooperation with financial institutions such as banks, and will strictly follow the requirements of the new regulations. Control, ant gold service will also do risk assessment, but the approval amount is subject to the final results of the organization, ant gold service will not be the bottom.

The giants began to “come down” to cooperate with financial institutions, which is a big impact for Liu Fang’s loan-lost platform. He admits to Prism that after the open cooperation between BATJ, many city commercial banks that had previously cooperated with them chose to cooperate with BATJ. After all, compared with the size of the giants, the cooperation efficiency with the small loan-to-loan platform. Will be a lot lower.

“The giants have taken away most of the business volume in the market,” he said.

Potential risk: Who can get the bottom?

As more and more participants become bigger and bigger, will Internet loan assistance repeat the same mistakes in online lending and become out of control? The regulatory policy that has not yet officially landed has always been like a sword of Damocles, hanging on all practitioners.

According to Liu Fang, the current monthly size of the Internet loan-insurance industry is about 100 billion yuan, and they are all small-distributed loans. “I never feel that it has systemic risks, but it does not rule out that its scale is likely to expand rapidly.

Li Yi also said to Prism that the amount of Internet loan assistance has not yet been amplified. According to their behavior, the loan rate in the country is also on the scale of tens of billions of yuan, which is not large. But if the amount accumulates to a certain extent, he believes that the risk may come from two aspects:

One is from the customer. The comprehensive cost of such loans is basically above 12%, and some even 18%~20%. Almost the sub-prime customers who are willing to accept this cost will have similar risks like the previous campus loans. Not known;

The second is from the platform itself. Banks are so refreshing on such customers that they are based on the Internet platform. If the equivalent is large enough, the Internet platform can still be trusted. It is also unknown.

Huang Hao also mentioned in the aforementioned article that some of the loan-institutions have weak wind control technology capabilities, and even commercial and financial scenarios and data are relatively lacking, but they violate the rules to provide direct or implicit risks to the joint venture banks. “The bank’s risk control management is uneven. Some banks have no system for “independent risk control”, no model, no strategy, and they have given up their own decisions on “loan and no loans, how much to lend”, relying entirely on the Internet platform or helping loans. mechanism. Under such a form, if it cooperates with unqualified loan lending institutions, it will easily lead to an increase in the non-performing rate at the two levels of the lending institutions and banks, resulting in a certain degree of financial risk.

From the supervision and publication of Zhejiang, Beijing and other places, the loan business is required to serve the local; the financial institution itself bears the risk and does not allow the Internet platform to be bottomed out; it should not outsource the core business links such as “three investigations” and risk control. Cooperative institutions, and so on, are some of the most basic requirements.

Liu Fang has clearly felt in the past six months that more and more city commercial banks are hoping to go to the path of their own pockets, and hope that the loan promotion platform will help them improve their risk control capabilities, including accumulating data, Training talents and other measures.

“This aspect is to meet the requirements of supervision; on the other hand, everyone also realizes that they can earn more by themselves. After all, the risk is directly proportional to the income. Whoever bears the risk will be able to get more points. Profit.” Liu Fang said.

At the media briefing on November 12th, the chief risk officer of the China Banking Regulatory Commission and the director of the office, the spokesman of the office, Xiao Yuanqi, reiterated his position on the loan-sending business, saying that the regulatory authorities are open-minded and allow banking business. Business has innovation, on the other hand, it will also pay close attention to the potential risks of the loan-backing business, such as technology security risks, KYC risk, reputation risk, etc. “No matter what kind of cooperation you use,The core business of the bank must be in your own hands.” he stressed.

Earlier, at a ventilation meeting earlier this year, he mentioned that for the Internet loan management method, the regulatory authorities began research a year ago, conducted extensive research, listened to opinions from all sides, and constantly Perfect, “some things still need to continue to observe.”