Author: Pan Xiaojun.
It isThe narration of the number of wordsofSection 178Original article
Is this something you say you don't have? The term credit intermediary is a taboo topic for banks. It's also a topic that regulators shy away from. But the credit intermediary industry has never died because of banking and regulatory taboos.
What is scary is not the thing itself, but the attitude towards things.
At present, there is not a single law or regulation in China that regulates the credit intermediary business. However, it is unavoidable that there are at least 1.5 million full-time credit intermediary practitioners in China, not including those who use part-time business methods such as dispatching orders and pulling banners.
Let's first define the role of a credit intermediary, which is the role of an intermediary between the bank and the borrower. It acts similarly to the real estate agents, marriage agents, domestic brokers, insurance brokers and brokers we often see, helping you find the credit products or services you need to earn a fee. The ancient industry of credit intermediary appeared in the earliest Western Zhou Dynasty in our country and was called the hostage, after the Tang Dynasty, it was called the tooth man, and in the Qing Dynasty, the number of tooth merchants increased, and a special trade union was formed, which became the tooth shop. The famous Guangdong Thirteen Banks are talking about the thirteen dental merchants, finance as an important part of the national production field, the financial industry has existed since ancient times and has never died.
At present, there is no financial law or regulation that can manage and restrain credit intermediaries, and there is basically a gap in the supervision of credit intermediaries.
Although the financial regulators strongly demand that when credit intermediaries are investigated and punished, various regulatory authorities will also issue various "notices" and "guiding opinions", but they cannot really solve the problem. Because credit intermediaries actually play a practical role in production activities, merely punishing or prohibiting them by administrative means will not only fail to extinguish the industry, but will also lead to a situation in which the industry is mixed and bad money drives out good money.
I know you exist, and I know the necessity of your existence, but because you're so dirty and troublesome, I don't want to care either. I just wish you didn't exist, and while I can't, I can think.
Why credit intermediaries exist
Whatever exists has the value of existence. First of all, I would like to quote the definition of the role of credit intermediaries by Mr. Gu Lei, the head of the joint research group of the Research Base for Inclusive Finance and Legal Regulation of Peking UniversityOne isCommercial banks can give the current bank products and matching schemes, which are not only limited in quantity, but also may not meet the needs of small and micro enterprise borrowers for funds, while credit intermediaries can match almost all bank products in the market at one time and give the best matching scheme. Because credit intermediaries can show different credit products of different commercial banks to small and micro enterprise borrowers, small and micro enterprise borrowers can select credit products on their own. Among the different products of many banks, there must be one that is most suitable for the borrower's needs. The second isSmall and micro enterprise loans, especially initial loans, do not know which lenders in the market are most suitable for them, let alone which institutions can obtain successful loans? Which one is faster? Which one has the cheapest interest? However, small and micro enterprise borrowers can customize an effective loan plan by looking for a credit intermediary, which is better to avoid the problems caused by blind application. The third isThere is not much overlap between ordinary small and micro enterprise borrowers and commercial banking channels, and if the borrower has some minor defects, it is very likely that the bank will refuse to lend. Credit intermediaries have a better understanding of the materials and processing processes required for loans from various banks, so they will let the borrower prepare them at one time, and submit the materials at one time, saving them from running back and forth to supplement the materials, which can smoothly assist the approved loans to improve the financing efficiency of small and micro enterprises.
It would be nice if these services were free, but unfortunately they aren't.
Therefore, even if credit intermediaries have these roles, most commercial banking institutions will issue a statement that "bank lending business has never cooperated with loan intermediaries or individuals, and has never charged intermediary fees, agency fees and other fees when handling loans." Consumers should go to regular bank outlets or bank online platforms to handle loan business, and do not blindly listen to or blindly follow others in handling loan business. ”
It's true that this is not a problem for banks, and banks want to be able to meet the needs of their customers, but unfortunately they can't do it.
The author believes that the essence of this matter is the dereliction of duty of supervision, and the same as the original P2P, although the supervision saw the phenomenon and understood the essence of the problem, but it was not about itself, and no department came out to claim this dirty mess, so it also caused the existing chaos. Or quote Mr. Gu Lei's research, foreign countries are experienced, but we have no regulatory departments willing to take the lead to learn.
In Australia, a credit broker (broker) is a licensed loan specialist. They can get loan information and borrower information from a panel of lenders and provide the right credit product to the customer, and then help the customer complete the application all the way to the loan approval. Australian credit brokers are also a group of people with rich financial knowledge, they are trained by the platform's professional services, and systematically master the products of major lending institutions, both in terms of time cost and intellectual cost are far higher than the credit clerks of individual banks and lending institutions. In the UK, the credit system is roughly divided into three parts, lending institutions (including banks and non-bank lending organizations), for-profit credit intermediaries, and financial management departments, among which there are 3,200 loan broker companies or Internet platforms, which is a huge number. Mortgage brokers account for a large proportion of the British credit market, and their role in promoting credit is also obvious, which together constitute the main structure of British credit intermediaries and become a force to be reckoned with in the British credit market, and their matching credit business accounts for more than 60% of the total amount of financial credit lending in the United Kingdom.
The chaos of the credit intermediary industryWhere no one cares, it must be bad money driving out good money. Who can beat humanity? Just like P2P's direct financing is not necessarily less efficient than the indirect financing of financial institutions, but that it operates safely and according to human greed without supervision. The core problem of credit intermediaries is the indiscriminate charging of fees.
Because of the industry attribute problems and traffic, in the current Chinese intermediary environment, low-fee intermediaries cannot survive, and China's credit intermediaries have become a business model of "not opening for a year, opening for three years". At present, more than half of the cost of credit intermediaries is the cost of marketing customer acquisition, which creates a vicious circle in which intermediaries who invest too much in customer acquisition costs must increase intermediary service fees in order to obtain profits.
How can I get a higher fee? Fraud and fraud are tools for credit intermediaries to charge high fees.
Falsifying bank statements, contracts, credit records, or even forged court judgments, household registers, divorce certificates, divorce agreements or divorce judgments, in order to pass the bank's low-interest credit review and help small and micro customers obtain loan financing, if this fraud is to assist small and micro customers to get lower bank interest on small and micro loans. After the epidemic, the state has launched a lot of interest rate policies in order to support small and micro enterprises, and banks and other financial institutions have also complied with the requirements to improve the digital level and launched a full line of tax loan products based on corporate tax payment information, but in fact, illegal intermediaries have used corporate tax loans to carry out tax fraud and defraud bank loans. There are many intermediaries who help clients to make false tax statements by exploiting loopholes in the corporate tax process, thereby helping these clients to successfully obtain excess loans from banks.
The blow to the chaos in the credit intermediary industry has been launched from all sides.
Since 2023, the Shanghai Supervision Bureau of the State Administration of Financial Supervision and Administration has promoted the special governance action of illegal loan intermediaries, strengthened the connection between execution and execution, and worked with the Public Security Bureau, procuratorate, court and other judicial organs to strictly investigate and deal with loan fraud, credit card fraud, illegal business operations, routine fraud and other illegal crimes in the financial field carried out or participated in by illegal loan intermediaries, so as to safeguard the capital security of financial institutions and the legitimate rights and interests of the people, and effectively protect the stability of Shanghai's financial order. In Shanghai, more than 200 cases of economic crimes in the credit field have been detected, more than 100 criminal gangs of various types have been dismantled, and economic losses have been recoveredMore than 15 billion yuan.
The treasure book of maintaining order in the industry has not yet appeared. **When financial regulators strongly require the investigation and punishment of credit intermediaries, various regulatory authorities will also issue "notices" and "guiding opinions", but they cannot really solve the problem. The market has objective needs, the simplest example, whenever a document mentions "illegal intermediaries", but what is an illegal intermediary, what is a legal intermediary, and there is no superior agency to supervise and protect the rights and interests of such intermediaries.
Article 17 of the Measures for the Administration of Personal Loans issued by the State Financial Administration also clarifies that if a lender entrusts a third party to handle some specific matters in the loan investigation, it shall not harm the legitimate rights and interests of the borrower and ensure that the relevant risks are controllable. Lenders should clarify the qualifications of third parties, establish a list management system, and regularly review and update the list. If the State Financial Supervision and Administration Bureau is the promulgator of the regulations, the local financial supervision and administration bureau is obliged to implement the regulations. Otherwise, this regulation has no operational significance.
Since financial business is inseparable from credit intermediaries, it is necessary to manage them well. First, the supervision and management agency is determined, and then the corresponding supervision and management system is promulgated, and then the companies and personnel engaged in the industry are subject to list management and professional certificate system. In this way, we can talk about the follow-up standardized fees and standardized services. Otherwise, the forbidden "covering your ears and stealing the bell" will have no effect.
Actually, it's not difficult to do this, but they don't want to participate in this muddy water. How difficult it is to establish order, and it is much easier to issue a disclaimer and organize several rectification campaigns than to actually do a good job.