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Haohan Huitong Small Loan was fined 1.1 million yuan for lending and leasing business licenses in disguise, obstructing supervision and fulfilling its responsibilities in accordance with the law

author:Blue Whale Finance

A few days ago, Hunan Haohan Huitong Internet Microfinance Co., Ltd. (hereinafter referred to as "Haohan Huitong Small Loan") was fined 1.1 million yuan for two violations, including disguised lending, leasing of business licenses and obstructing the local financial supervision and management department to perform its duties in accordance with the law. This is the fifth fine issued by the microfinance industry this year.

Throughout 2023, the polarization of the microcredit industry will not change, with some institutions increasing capital against the trend, and some institutions withdrawing from the market. In the future, microcredit companies that fail to meet compliance standards and cannot continue to operate will gradually withdraw, while institutions with larger volumes, rich business scenarios and better compliance will become the main force.

According to the official website of Haohan Huitong Small Loan, the company was established in 2017 with a registered capital of 300 million yuan, and the company's loan products include car loans, housing loans, credit loans, enterprise loans, etc. In terms of shareholding structure, Tianyancha information shows that the controlling shareholder of Haohan Huitong Small Loan is Guangzhou Tianhui Capital Management Co., Ltd., holding 70% of the shares, and the other shareholder of the company is Hunan Yingke Interactive Entertainment Network Information Co., Ltd., a live broadcast platform, holding 30% of the shares.

In recent years, many loan assistance and loan super-loans have started the idea of leasing and auctioning licenses due to the need for business compliance. The online small loan will only rent and not sell the license to the outside world, which is also out of the consideration of profit demand, after all, "stay in the green mountains, not afraid of no firewood". The practice of loan assistance and loan overtaking is also based on compliance considerations.

Lenders usually require a license for a small lender, which must be a national Internet small loan, have not been listed on an app, have not opened an account on an information flow advertising platform, and have not done loan over-lending business. Many Internet small loans that have not carried out actual business have cooperated with loan assistance and loan super platforms. Under this channel business model, the lending platform packages the traffic business through license qualifications to meet the compliance requirements of upstream channels.

Compared with acquiring licenses, the leasing model is less costly and the process is simpler. One side has a demand for buying volume, the other side has a license qualification, and the two are connected to the leasing market for online small loan license transactions.

The leasing model of small loan companies to earn money by lying down

The leasing cost of an online small loan license is generally divided into fixed income and profit sharing. Among them, the fixed fee is 200,000-300,000 yuan per month, and the profit sharing is settled according to a certain proportion of the new income generated after the lease, and the higher one can reach 30%. If the cooperation involves profit sharing, the licensee and the intermediary party will also separately send financial personnel to the license-demander to ensure that the transaction flow is true and accurate.

According to a previous industry report by Laser Finance, the license lessee mainly uses the license qualification to endorse the traffic business. Specifically, it can be divided into App listing, information flow advertising account opening and rejection docking.

First of all, with regard to the listing of the App, the microfinance company helps the loan and loan super to put the products on the shelves and package the qualifications as the main operating entity, while in fact, the business is operated by the lender. Realizing the launch of the App can not only independently acquire users, but also establish a carrier for the traffic business and even the lending business.

However, this model of packaging business with a small loan license is easy to touch the compliance red line in terms of product design and consumer protection.

Secondly, having a license endorsement can solve the problem of customer acquisition for information flow advertising. At present, there are two modes of access to loan advertising information flow, one is to hold an Internet small loan license, access to the traffic platform in the name of lending, and the advertising page can guide the download of relevant loan apps, and the other is the loan form, which only obtains customers through the form and cannot download the app.

In the loan market, most of the platforms are directly connected to financial institutions at the back-end, and the revenue model is loan profit sharing or others, so they are accessed in the name of lending when information flow advertisements are placed. According to the requirements of the information flow platform and the employer, a license is required for loan assistance and loan over-placement of loan advertisements, and the entry of the loan assistance form mode is not required for the time being.

Even if you have a license and qualification, the loan information flow is still limited to customer acquisition. "At present, the information flow advertising standards of online platforms are very strict, and it is difficult for local small loan licenses to be recognized, and there must be a national online small loan license. "It doesn't mean that you can have a license, but it also depends on whether there is a quota for information flow." ”

Finally, the docking of refusal is an important purpose of loan assistance and loan super layout of online small loan licenses, and it is also an important part of traffic monetization. Industry insiders said that if the loan platform maintains a good cooperative relationship with the head traffic platform under the premise of being licensed, it can earn 300,000 yuan a day only by buying and refusing to buy it, and it is not a big problem to earn tens of millions of dollars a month.

The so-called rejection refers to the traffic of some cash loan platforms with abundant traffic that fails to pass the platform's risk control after screening and filtering. Generally speaking, the rejection is paid according to UV, and a UV can produce about 2-2.5 times the price difference, for example, a UV that costs 10 yuan can be sold for at least 12-13 yuan.

"At present, the cost of a UV ranges from 15 to 18 yuan for a large-scale compliant mutual finance platform, and after the loan super access platform is rejected, it is then sold to other loan assistance and loan super to earn a comprehensive price difference. "Loan practitioners believe that this is a business that is sure to make money without losing money, and the key is that it needs to cross the license threshold when receiving the amount of rejection.

In addition to the above-mentioned traffic business, the loan supermarket can also lend in disguise through the online small loan license channel. A license intermediary revealed that if the license demander wants to increase the lending business, it needs to increase the service fee. "The funds are actually paid by the license lessee, but the channel fee of 0.2%-0.3% needs to be paid to the licensee. ”

On the one hand, the model of online small loan license leasing can bring stable income to the licensee and revitalize idle resources, and on the other hand, after the loan assistance and loan exceed the license qualification, it can also break through the business restrictions and expand the traffic business. In fact, this seemingly win-win channel cooperation model has hidden risks.

The prospect of licence leasing is in doubt

Since the issuance of Circular No. 141, the extensive expansion of the online small loan business has been continuously rectified, and the most intuitive signal is that the online small loan license has shrunk and the industry has entered the stock stage.

Previously, the China Banking and Insurance Regulatory Commission (CBIRC) made it clear that in view of the problems existing in the online microfinance business of some microfinance companies, it would organize local financial regulatory departments to carry out special rectification and clean-up and standardization, and comprehensively stop the establishment of new online microfinance institutions.

There is no hope of adding new online small loan licenses, but the trend of helping loan licenses is on the rise, which has given rise to the license rental and sale market.

"There is no way, now that the regulatory policy is getting stricter and stricter, if you want to continue to do loans, loans and loans, you may have to be licensed. A number of loan platforms said that the trend of loan licensing has basically been determined, and the company has been seeking Internet small loan licenses everywhere since the beginning of the year, and completed the license layout before the policy is implemented.

Although the current regulatory authorities have not specifically defined the loan assistance business, in the past two years, the weight of fintech rectification and information protection has increased, and the flow business of loan assistance and loan over-lending has been placed within a stricter compliance framework.

At the end of 2021, seven departments, including the People's Bank of China, solicited public comments on the new rules on the marketing of financial products, which regulate the registration of product names and trademarks of third-party internet platforms.

Among them, third-party internet platform operators are required to use financial-related words or content such as "finance" and "loans" in the names of websites, mobile internet applications, mini programs, and self-media, and shall obtain corresponding financial business qualifications or financial information service business qualifications.

In terms of trademark registration, third-party internet platform operators registering and using trademarks containing financial-related words or content such as "finance", "loan" and "credit investigation" shall obtain corresponding financial business qualifications or financial information service business qualifications.

Although the new regulations have not yet been officially promulgated, the loan supermarket and loan assistance platforms have begun to prepare for the license qualifications in advance. In the view of loan practitioners, the new regulatory regulations have the greatest impact on non-licensed loans and loan over-loans, and upstream channels must be licensed in accordance with policy guidelines, and if you want to not be stuck in the links of advertising, App listing and channel access, it is the safest way to hold a license.

Some investors and cash loan platforms have required a licensed investor agreement for loan assistance and loan overtaking. A loan practitioner revealed, "We required last year that there must be a licensed entity for super loans, not a simple cooperation agreement, but a capital agreement with a licensed institution." ”

In terms of licensing layout, for most platforms with average strength, leasing a license is the first choice. However, as demand increases, the cost of leasing a license has also doubled. Loan practitioners revealed that the previous channel cooperation fee was about 1.5 million a year, but this year's price has soared, and the minimum has to start at 3 million.

While the cost of leasing is rising, there is also the possibility of contagion. After all, the financial business belongs to the franchise industry, and all types of entities in the industrial chain must be fully included in the scope of regulatory penetration, but the practice of helping loans and lending super to package business with the help of online small loan licenses deviates from the bottom line of compliance at the regulatory level.

Some people in the industry believe that the life of the loan will not be too long, and it may be rectified and cleaned up within a year.

In addition to leasing licenses, some stronger loan players are also considering buying shares or acquiring licenses. "We give priority to the acquisition of licenses, and if we can't figure it out, we will consider a partnership, and finally we will cooperate with the channel. A staff member of a waist loan platform said.

Compared with leasing licenses, acquiring licenses not only solves the problem of customer acquisition, but also allows the platform to become a lender and operate its own lending business. In addition, it will be more convenient to call credit investigation and risk control modeling with a license.

At present, the online small loan license trading market is relatively active, and the transaction price of a national online small loan license is between 10 million and 20 million.

Despite the enthusiasm of the supply and demand sides of the license, it is difficult to change the transfer of an online small loan license, which ultimately leads to a very small number of licenses that can be successfully changed.

"The transfer of Internet small loan licenses has relatively high requirements for shareholder qualifications, and local regulatory authority is limited, so the approval of transfer requires a higher level of supervision to approve. This means that the key to a license transaction lies in the relationship between the buyer and the seller and the competent authority. An intermediary who has been engaged in financial license trading for a long time said.

Even if the acquisition license is realized, the lending platform will still face subsequent pressure such as capital increase and compliance. For the loan platform, the follow-up business issues are still early to consider, and the most urgent thing at present is obviously to get on the bus first.

During the year, 5 microcredit institutions were fined, and the compliance of microcredit entered the market's vision

Judging from the content of the announcement, the fine of Haohan Huitong Small Loan is the first administrative penalty issued by the Hunan Provincial Local Financial Supervision and Administration Bureau this year. It is worth mentioning that small loan fines, which were not common in previous years, will appear frequently in 2023, especially since the second half of 2023. Including Haohan Huitong Microfinance, at least five microcredit institutions have been punished during the year.

For example, in December 2023, Yingtan Xinjiang Guangda Microfinance Co., Ltd. was fined 100,000 yuan for failing to verify and handle objection information in accordance with regulations, while Xia Ming, chairman and general manager of the company, and Shen Weiwei, engineer of the risk control department, were fined 30,000 yuan and 11,000 yuan respectively. Guizhou Truck Gang Microfinance Co., Ltd. was fined 370,000 yuan by the Guizhou Branch of the People's Bank of China for providing bad personal information without informing the information subject in advance.

Earlier, Beijing Xinjingming Microfinance Co., Ltd. was fined 100,000 yuan in May 2023 for changing shareholders holding more than 5% of the shares without approval, and Beijing Fanhua Microfinance Co., Ltd. was fined 100,000 yuan in August 2023 for untrue, inaccurate and incomplete materials submitted to the local financial regulatory authorities.

Over the past eight years, the number of microfinance companies has been declining. According to the statistical report on microfinance companies in the third quarter of 2023 previously released by the People's Bank of China, as of the end of September 2023, there were 5,604 microfinance companies in the country. The balance of loans was 785.6 billion yuan, a decrease of 125.1 billion yuan in the first three quarters. Compared with the peak of 8,910 in 2015, the number of microfinance companies has decreased by nearly 40%.

At the end of 2023, the payment and consumer finance sectors have ushered in new regulatory signals, among which the new payment regulations have been officially implemented, and the consumer finance sector is a draft for comments. This has also led the market to focus more on the microcredit industry. As early as September 2020, the former China Banking and Insurance Regulatory Commission (CBIRC) issued the Notice on Strengthening the Supervision and Administration of Microfinance Companies, and two months later, the Interim Measures for the Administration of Online Microfinance Business (Draft for Comments) was released, which set out requirements for the registered capital and business scope of online microloans.

Although the above-mentioned draft has not yet been released, a number of practitioners have begun to move closer to it, which is also considered to be the main reason for the subsequent capital increase of many microcredit companies. Not only that, since 2023, Beijing, Shanghai, Guangdong, Hunan, Fujian and other provinces and cities have also successively introduced new regulatory measures for small loans based on the actual situation in their jurisdictions for the protection of consumer rights and interests in the microcredit industry.

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