Recently, it was also reported that Cheng Jianbo, former vice president of JD.COM Science and Technology and general manager of Personal Risk Management Center, will be the general manager of Park Road Zheng Xin Co., Ltd. (hereinafter referred to as "Park Road Zheng Xin"). Previously, the risk control team led by Cheng Jianbo has been "escorting" the operation of JD.COM Baitiao for a long time, and accumulated practical experience in the field of consumer finance big data risk control.
The rivers and lakes of financial lending may not be big, and they are all acquaintances. However, for the whole lending industry, its traffic data, risk control and even customer service, which have occupied the whole business model for a long time, will return to the hands of licensed financial institutions such as banks under the guidance of supervision in the future, and this "landing" process will be even longer.
Industry ups and downs
Li Li is determined to leave the Internet industry by the end of 2020. 20 18 changed jobs from a credit card center of a joint-stock bank to a consumer finance business of a big internet company as a product manager. After bidding farewell to the rigid management bank, at first, the Internet working atmosphere surrounded by post-90 s employees made him feel more relaxed and free, and his salary income was higher than that of the previous bank. Although some invisible benefits such as physical examination and medical reimbursement have shrunk, these are not the first problems for him, a healthy young man.
However, after the initial novelty passed, Li Li found that this pure online personal consumer credit business with joint loans as the main mode was a bit "boring". The whole business model and industrial chain have been shaped very stably. From BD (business) to products, operations and customer service, everyone is just a small screw that can be replaced at any time on the assembly line. After a long time, he seems to be just a "skilled worker" at a certain node. It is difficult to see the hope of personal ability improvement and career promotion.
However, in the first half of 20 19, the whole industry was still on the rise. Banks, consumer finance companies, small loan companies and other investors have great demand for consumer credit, and they are constantly providing low-cost sources of funds. On the contrary, the platform side is struggling to obtain the source of traffic on the asset side, and the whole business and team are still immersed in the atmosphere of vigorous development.
From 20 18 to 20 19, public data show that the loan balances of 360, Fun Store and Lexin, three financial technology companies listed in the US stock market, have made great progress, which may serve as a reference for the development trend of the joint lending industry. Among them, on 20 19, the fun shop clearly put forward the "open platform" model of loan assistance business.
Li Li now recalls that the turning point of the industry atmosphere occurred in the second half of 20 19. In Hangzhou, the crawler business of some large third-party data companies in the industry was shut down and the business leaders were taken away for investigation. Some cooperative banks began to require users to explain the source of data when diverting water. Although banks were more "formal" at that time to meet the supervision, it also sounded the alarm for the industry.
Also in the first half of 20 19, Chen Ming's company just changed from P2P industry to cash loan. The company has a network small loan license, some self-operated loans, and joint loan business with banks and consumer companies. The scale is considered as a waist enterprise in the industry. Chen Ming thinks this is not safe enough. He hopes to jump to a consumer finance company or bank because he feels "safer within the system".
At the same time, Chen Ming's company has just managed to get rid of P2P business, and according to the intention of supervision, it has turned into a business based on joint lending and loan assistance. But in the second half of the year, the third-party data company "had an accident", and he was keenly aware that the regulatory storm of data information had begun.
But no one expected that the sudden COVID-19 epidemic in 2020 would press the pause button for the undercurrent between supervision and industry.
As the operator of an online consumer loan product, Zack Zhang saw too many "real people" in the first half of 2020-some users forged their own diagnosis certificates to avoid repayment, but in fact, with a little verification, they could find new case data in their area. Some users came to Beijing by car from Tianjin for thousands of dollars in arrears, and forced them to "meet" the person in charge of the business. Some users failed to apply for deferred repayment for several times due to arrears of several hundred yuan, threatening customer service personnel to jump off a building. ...
In the case of large fluctuations in users' economy and emotions, the growth of personal consumer credit market has almost stagnated, big data has been more widely used to fight the epidemic, and online contactless credit products of banks have entered a stage of sudden and rapid development. In the second half of the year, the impact of the epidemic on the economy gradually declined, and the haze hanging over the industry seemed to gradually dissipate. In the second half of the year, Zack Zhang felt that the high-risk complaints from front-line customer service slowed down and the business volume rose steadily.
In July 2020, China Banking Regulatory Commission issued the Interim Measures for the Administration of Online Loans of Commercial Banks, and some financial technology companies actively interpreted this normative document. "The biggest highlight of the new regulations is to fully affirm the role of the lending market and institutions, encourage commercial banks to absorb new technologies in a cooperative manner, and promote the reform and innovation of the credit industry, which is of great benefit to the head financial technology platform."
But then, in the Provisions on Several Issues Concerning the Application of Laws in the Trial of Private Lending Cases promulgated by the Supreme Law in August 2020, four times LPR (one-year loan market quotation) was taken as the upper limit of judicial protection of private lending interest rates, and the red line of interest rates was drawn to a tighter position. In the following months, a wave of "anti-collection alliances" appeared in various places. People caught in the trap of high-interest black online loans and private lending regard the provisions of the Supreme Law as a lifeline to get rid of debts. This situation once spread to lending disputes related to banks and consumer finance companies. Although the Supreme Law is aimed at non-financial licensed "private lending", licensed financial institutions still feel pressure in public opinion and morality, and the more so.
For lending institutions that are "protected" by the cancellation of licenses, the upper limit of interest rate for self-operated assets loans can be as close as possible to 24% (the previous "usury" red line), and in the lending business model, some licensed investors have begun to require the design according to the upper limit of 4 times LPR.
Chen Ming saw that his company's target customers are mostly blue-collar and sinking people, and his personal financial ability to resist risks is poor. These characteristics are magnified by the epidemic. Under the epidemic situation, the market demand has shrunk, and the interest rate pricing space has been depressed, which has greatly reduced the profit and profit space of small and medium-sized lending platform institutions. He began to actively look for "the next home", and the best goal was to enter the bank.
From June 5438 to June 2020 10, two head platform institutions were listed one after another. The regulatory expectations and market reputation of the whole industry have turned sharply.
In the fourth quarter of 2020, the Interim Measures for the Management of Internet Microfinance Business (Draft for Comment) was released, accompanied by many public criticisms from the central bank and the banking and insurance regulatory agencies on disorderly innovation of Internet finance, pushing up financing costs and abusing information and data.
This heavy regulatory document directly points out that Internet platform institutions use online small loan licenses beyond the scope, and use the leverage ratio of 3: 7 or even 1:99 to enlarge credit funds in the form of joint investment.
Later, Li Li found that the cooperative banks that he began to pay attention to were shrinking, and the joint loans stopped adding, and some banks even stopped lending.
"The financial prospects of the Internet are worrying." At that time, Li Li made such a judgment and began to actively look for job-hopping opportunities for banks and consumer finance companies.
On the other hand, the licenses of consumer finance companies and direct selling banks that have been frozen for many years have begun to be liberalized. "Supervision also tends to allow licensed financial institutions to carry out financial innovation." At the end of 2020, a foreign investment bank asked some local mutual fund associations, the State Council Development Center, financial supervision research institutions and other experts for their opinions on Internet loans and financial technology supervision. The core views of experts include three aspects: First, Internet antitrust and data strategy are the reasons behind China's tightening of financial technology; Second, the leverage ratio of the residential sector is high, and supervision will restrict consumer credit; Third, online loan supervision will be more stringent.
In the first half of 200212002, in the process that large and small platform institutions in the industry are still turning to joint loans to help loans, Li Li and Chen Ming have resigned from Internet platform companies respectively and joined the consumer finance companies of the banking department one after another.
Game between loan assistance and risk control of small and medium-sized financial institutions
On July 7th, 20021year, some platform institutions received emails from the central bank's credit bureau, requesting to further improve the rectification plan according to the business cooperation flow chart of "platform-credit bureau-financial institution". It is required that "platform institutions shall not directly provide financial institutions with information voluntarily submitted by individuals, information generated within the platform or information obtained from outside in the name of application information, identity information, basic information and personal portrait scoring information when conducting business cooperation with financial institutions such as drainage, loan assistance and joint loan. And it is necessary to achieve a comprehensive' direct connection' between personal information and financial institutions. "
In order to understand this new regulation, it is necessary to clarify the cooperative relationship between the platform and financial institutions in the existing loan assistance business.
According to the Research Report on Innovation and Supervision of Loan-Assisting Business issued by China inclusive finance Research Institute of China Renmin University (hereinafter referred to as "Loan-Assisting Report"), the cooperation processes of all participants in loan-assisting business include pre-lending cooperation, loan-in cooperation and post-lending cooperation.
The Report on Loan Assistance pointed out that in the pre-loan cooperation, all participants need to complete the steps of customer acquisition, initial screening and customer drainage. In terms of customer acquisition and initial screening, lending institutions can reach lending customers through pure online or online-offline combination, and use big data, artificial intelligence and other scientific and technological means to conduct initial screening and risk control on lending customers, and then push them to the funder to screen out the target customer groups that meet the preconditions of the funder. "In terms of customer drainage, lending institutions will push the credit scores and credit suggestions of lending customers to banks and other funders after screening out the target customer groups."
According to a person from a financial technology company, on July 7, the central bank's email asked for rectification mainly aimed at obtaining customer drainage before lending, requiring platform institutions and funders to strengthen the integrity and details of the central bank's data submission in this process.
In the "direct connection" mode, user information is directly transmitted between the platform and financial institutions. In the disconnected direct connection mode required by the central bank, credit reporting agencies are introduced to realize "disconnected direct connection".
However, the key to "moving the whole body" is that under the "direct connection" mode, the quality of information data is directly linked to the income of diversion services of platform institutions.
At present, in the market, the fee for loan assistance business is generally that the funder collects all the fees, and then returns the service fee and interest rebate to the loan assistance institution or credit enhancement institution. For example, in April this year, Xinyi Technology, a US-listed company, said that it was fully shifting to the business model of loan assistance and profit distribution. Previously, the 360 main body has also announced that it will continuously increase the business proportion of its "light capital" lending model.
After accepting this cooperation model, the common goal of banks and financial technology companies will be closely tied together: to achieve profits as soon as possible and as much as possible, while controlling poorly. In this mode, the lending platform will actually do a risk control screening internally, match users with appropriate funders with its own credit evaluation logic, and "fill in the blanks" with some data that can't pass the customs, which will damage the common benefits of both parties.
In other words, in the case of "direct connection" of user data, data quality is also implicitly linked to business income. Then, after the direct connection is cut off, the financial institution cannot directly verify the original data transmitted by the platform to the credit reporting agency, and the lending income and non-performing assets are responsible for themselves.
Jintian believes that after the "direct connection", the existence of credit reporting agencies is directly strengthened in banks and platforms, and its effects at least include: the platform can not directly output its own customer data, but can only give the data processed by credit reporting agencies, thus better protecting the privacy data of customers; Credit reporting agencies implement strict licensed operation, which raises the threshold for general market institutions to participate in loan assistance and joint guarantee; In view of the weakening role of the platform (it is difficult to directly control the quality of customers), the original business model, especially the charging model, may face great changes. If the potential income is significantly reduced, it may further reduce the willingness of the platform to participate in lending assistance and joint lending, thus changing the market ecology.
In the Interim Measures for the Management of Online Loans of Commercial Banks in July last year, the loan-assisting business was actually loosened, and it was clear that commercial banks could cooperate with third-party companies except the core risk control links. Specific cooperation contents include: marketing customer acquisition, joint loan, risk sharing (joint lender and sharing party must be licensed institutions), information technology, overdue collection, etc.
However, on February 20th this year, the CBRC issued the Notice on Further Regulating Internet Loan Business of Commercial Banks, insisting on "implementing risk control requirements". Commercial banks should strengthen the main responsibility of risk control, independently carry out internet loan risk management, and independently complete the risk control links that have an important impact on loan risk assessment and risk control. It is strictly forbidden to outsource key links such as pre-loan, in-loan and post-loan management. "
In this process from relying on external risk control to building its own core risk control, it tests the data technology and risk control management level of small and medium-sized banks.
Because a large-scale lending platform connects financial institutions with multiple investors, investors with high pass rate and fast lending speed may be distributed to more users. In the lending business, financing guarantees and insurance institutions are introduced as credit enhancement, or through commercial agreements such as margin and repurchase of lending platforms, the funders actually enjoy risk-free benefits, and the real risk control mechanism and level do not have much "actual combat" experience.
In an industry activity in the first half of this year, the president of an Internet private bank spoke frankly about this difficult problem and independently controlled the risk. Regulators have made painstaking efforts for independent risk control of banks and other financial institutions. From the initial document 20 14 1 in 2007 to the latest new regulations on mutual lending, they have repeatedly emphasized the issue of independent risk control. But think about it. In recent years, for private banks, for these small banks that developed later, and for small and medium-sized banks that don't have their own traffic, "What do we have?
Then, are small and medium-sized financial institutions ready for the "independent risk control" that has been supervised for many years?
(At the request of the interviewee, Chen Ming, Zack Zhang and Li Li are pseudonyms. )