網上借貸白皮書

美國財政部在2016年5月10日對網上借貸發表了白皮書。白皮書徵詢了一百位持份者的意見。

網上借貸的轉變

白皮書表示，個體對個體的“人人貸”(P2P)的原意是方便小企業集資，容許個體透過網絡中介平台借錢給小企業。但它已演變成機構投資者，對沖基金的工具。因此，P2P實際已不存在，應將它正名為網上借款。它迅速發展，而它的潛在問題也迅速浮現。

反映的問題

1.         網上交易容易出現漏洞，特別是參與者在網上簽署合同後未必能反查其在承保過程中的資料；

2.        網絡借貸商可以與傳統金融機構，利用財經工具超出其借貸承擔能力；

3.        網上借貨是在超低息、低失業率和大量閒資的情況下發展出來的，它未受到真正的考驗；

4.       向網上平台借貸的小企業應受到進一步保護；

5.        增加透明度，(特別是防止高利貸)；

6.       再保市場並非成熟，(容易出現全面溶解)；和

7.        應完善監管制度。

白皮書建議

1.      加強對小企業借款人的保護和更有效的監督；

2.     確保借款人有一定聲譽和強化和後臺操作的經驗；

3.     為借款人和投資者增加市場透明度；

4.     確保信貸合作夥伴獲得安全和負擔得起的信貸；

5.     透過政府介入，擴展申報機制，以保障安全和負擔得起的信貸； 和

6.     通過創建一個常設工作組，協調網上借貸市場。

金管局2016年3月貨幣與金融穩定情況半年度報告

內地的商業銀行不良貸款於2015年年底增加至 1.3 萬億元人民幣，較 2014 年年底上升約50%。同時，不良貸款率亦由1.25%上升至1.67%。吉林、黑龍江及河南省在2015年第3季較高的不良貸款率，其數值普遍超過3%。關注類貸款佔比已由2014年底的3.1%顯著上升至2015年底的3.8%。

相比之下，香港銀行體系在2015年12月的需要關注貸款為1.44%。

後記

中國網貸規模已達669億美元，約為美國的4倍。目前，美國網貸業平均壞賬率約為6%-7%，中國平均壞賬率是8%。美國的壞賬主要是信用下降的問題，而中國的壞賬中，欺詐和信用下降各占一半。

中國金融體系的一個小咳嗽將會震盪香港，因之，本土所倡導的中國切割論是無知的說法。

香港當局在網上借貸問題上，也不見光彩。小市民每天都看到黑社會追數，貼尋人告示。香港政府以自由市場的名義，無視小市民的私穩和個人權利，間接助長黑社會勢力。

附錄

U.S. DEPARTMENT OF THE TREASURY Opportunities and Challenges in Online Marketplace Lending

 May 10, 2016

THE Online marketplace lending refers to the segment of the financial services industry that uses investment capital and data-driven online platforms to lend either directly or indirectly to consumers and small businesses. This segment initially emerged as a “peer-to-peer” marketplace, with companies giving individual investors the ability to provide financing to individual borrowers. As products and business models have evolved, the investor base for online marketplace lenders has expanded to institutional investors, hedge fund, and financial institutions. In recognition of this shift in investor base, the market as a whole is no longer accurately described as a “peer-to-peer” market. Accordingly, we refer to these companies as “online marketplace lenders.”  

This white paper establishes an overview of the evolving market landscape, reviews stakeholder opinions, and provides policy recommendations. This paper also acknowledges the benefits and risks associated with online marketplace lending, and highlights certain best practices applicable both to established and emerging market participants. Advances in technology and the availability of data are changing the way consumers and small businesses secure financing. Online marketplace lending has emerged as an industry offering faster credit for consumers and small businesses. Through this effort, Treasury took steps to understand the potential opportunities and risks presented by this evolving industry. By engaging directly with industry, Treasury hoped to foster discourse about how this industry could best serve the financial needs of the American public. Treasury received approximately 100 responses to the RFI from online marketplace lenders, trade associations, consumer and small business advocates, academics, investors, and financial institutions. Comments covered a wide range of issues, but several common themes emerged, including the following:

 1. Use of Data and Modeling Techniques for Underwriting is an Innovation and a Risk: RFI commenters agreed the use of data for credit underwriting is a core element of online marketplace lending, and one of the sources of innovation that holds the most promise and risk. While data-driven algorithms may expedite credit assessments and reduce costs, they also carry the risk of disparate impact in credit outcomes and the potential for fair lending violations. Importantly, applicants do not have the opportunity to check and correct data potentially being used in underwriting decisions.

2. There is Opportunity to Expand Access to Credit:

RFI responses suggested that online marketplace lending is expanding access to credit in some segments by providing loans to certain borrowers who might not otherwise have received capital. Although the majority of consumer loans are being originated for debt consolidation purposes, small business loans are being originated to business owners for general working capital and expansion needs. Distribution partnerships between online marketplace lenders and traditional lenders may present an opportunity to leverage technology to expand access to credit further into underserved markets.

3. New Credit Models and Operations Remain Untested:

New business models and underwriting tools have been developed in a period of very low interest rates, declining unemployment, and strong overall credit conditions. However, this industry remains untested through a complete credit cycle. Higher charge off and delinquency rates for recent vintage consumer loans may augur increased concern if and when credit conditions deteriorate.

4. Small Business Borrowers Will Likely Require Enhanced Safeguards: RFI commenters drew attention to uneven protections and regulations currently in place for small business borrowers. RFI commenters across the stakeholder spectrum argued small business borrowers should receive enhanced protections.

5. Greater Transparency Can Benefit Borrowers and Investors: RFI responses strongly supported and agreed on the need for greater transparency for all market participants. Suggested areas for greater transparency include pricing terms for borrowers and standardized loan-level data for investors.

6. Secondary Market for Loans is Undeveloped: Although loan originations are growing at high rates, the secondary market for whole loans originated by online marketplace lenders is limited. RFI commenters agreed that active growth of a securitization market will require transparency and significant repeat issuances.

7. Regulatory Clarity Can Benefit the Market: RFI commenters had diverse views of the role government could play in the market. However, a large number argued that regulators could provide additional clarity around the roles and requirements for the various participants.

In order to encourage safe growth and access to credit through the continued developments of online marketplace lending, this white paper introduces the following recommendations to the federal government and private sector participants:

1. Support more robust small business borrower protections and effective oversight；

2. Ensure sound borrower experience and back-end operations；

3. Promote a transparent marketplace for borrowers and investors；

4. Expand access to credit through partnerships that ensure safe and affordable credit；

5. Support the expansion of safe and affordable credit through access to government-held data； and

6. Facilitate interagency coordination through the creation of a standing working group for online marketplace lending.