1、 22 May 2017 FinTech credit Market structure, business models and financial stability implications Report prepared by a Working Group established by the Committee on the Global Financial System (CGFS) and the Financial Stability Board (FSB) ii This publication is available on the website of the BIS

2、(www.bis.org) and the FSB (www.fsb.org). To contact the BIS Media and Public Relations team, please e-mail pressbis.org. You can sign up for e- mail alerts at http:/www.bis.org/emailalerts.htm. To contact the FSB, please e-mail fsbfsb.org. You can sign up for e-mail alerts at www.fsb.org/emailalert

3、or follow the FSB on Twitter: FinStbBoard. Bank for International Settlements and Financial Stability Board 2017. All rights reserved. Brief excerpts may be reproduced or translated provided the source is stated. ISBN 978-92-9259-051-2 (online) iii Preface FinTech credit that is, credit activity fac

4、ilitated by electronic platforms such as peer-to-peer lenders has generated significant interest in financial markets, among policymakers and from the broader public. Yet there is significant uncertainty as to how FinTech credit markets will develop and how they will affect the nature of credit prov

5、ision and the traditional banking sector. Against this background, a group of representatives from the membership of the Committee on the Global Financial System (CGFS) and the Financial Stability Board (FSB) Financial Innovation Network, together with the Secretariats of the CGFS and FSB, undertook

6、 this study of FinTech credit. The study draws on public sources and ongoing work in member institutions to analyse the functioning of FinTech credit markets, including the size, growth and nature of activities. It also assesses the potential microfinancial benefits and risks of these activities, an

7、d considers the possible implications for financial stability in the event that FinTech credit should grow to account for a significant share of overall credit. Conduct and prudential regulatory policies in selected countries are also outlined. This report provides several key messages. The nature o

8、f FinTech credit activity varies significantly across and within countries due to heterogeneity in the business models of FinTech credit platforms. Although FinTech credit markets have expanded at a fast pace over recent years, they currently remain small in size relative to credit extended by tradi

9、tional intermediaries. A bigger share of FinTech-facilitated credit in the financial system could have both financial stability benefits and risks in the future, including access to alternative funding sources in the economy and efficiency pressures on incumbent banks, but also the potential for wea

10、ker lending standards and more procyclical credit provision in the economy. These considerations are explained in more detail in the report. The emergence of FinTech credit markets poses challenges for policymakers in monitoring and regulating such activity. Having good-quality data will be key as t

11、hese markets develop. We hope that the information and analysis contained in this report will assist policymakers with their efforts. William C Dudley Chair, Committee on the Global Financial System President, Federal Reserve Bank of New York Klaas Knot Chair, FSB Standing Committee on Assessment of

12、 Vulnerabilities President, De Nederlandsche Bank iv Table of contents Page Executive Summary . 1 1. Introduction . 2 2. Factors influencing the development of FinTech credit . 3 2.1 Drivers . 3 2.1.1 Supply factors . 3 2.1.2 Demand factors . 4 2.2 Other factors affecting growth potential . 5 3. Siz

13、e and structure of FinTech credit markets . 6 4. Description of FinTech credit activity . 10 4.1 FinTech credit platforms . 11 4.1.1 Traditional P2P lending model . 11 4.1.2 Notary model . 13 4.1.3 Guaranteed return model . 14 4.1.4 Balance sheet model . 15 4.1.5 Invoice trading model . 16 4.2 Lende

14、rs . 17 4.3 Borrowers . 20 5. Micro assessment of FinTech credit activity . 21 5.1 Pricing . 21 5.2 User convenience . 23 5.3 Accessibility . 24 5.4 Potential vulnerabilities of FinTech lending activity . 25 (a) Leverage and liquidity risk . 25 (b) Operational risks . 26 (c) Quality of credit risk a

15、ssessments . 26 (d) Business model incentives . 26 (e) Reliance on investor confidence for new business . 27 (f) Low barriers to entry . 27 (g) Platform profitability risks . 29 6. Financial stability implications of FinTech credit . 30 6.1 Greater share of FinTech credit . 30 v 6.2 Securitisation .

16、 32 6.3 Potential response by incumbent banks . 33 7. Financial regulatory architecture for FinTech credit . 35 7.1 Rationale for the regulation of FinTech credit markets . 35 7.2 Regulation of FinTech credit within existing frameworks . 36 7.3 Examples of regulation dedicated to FinTech credit . 36

17、 7.4 Policy changes to promote FinTech credit . 38 Box A: Data sources used in the report.11 Box B: Scandals at FinTech platforms.28 Box C: Interactions between banks and FinTech platforms.34 Box D: Chinas regulatory framework for internet finance38 References . 41 Members of the Working Group . 43

18、Executive summary FinTech credit refers to credit activity facilitated by electronic platforms. This usually involves borrowers being matched directly with investors, although some platforms use their own balance sheet to lend. FinTech platforms facilitate various forms of credit, including consumer

19、 and business lending, lending against real estate, and non-loan debt funding such as invoice financing. There is also variation in the creditor base of FinTech credit platforms: some source funding mostly from retail investors, while others use significant funding from institutional investors, bank

20、s and securitisation markets. Banks originate loans for FinTech credit platforms in several jurisdictions. The availability of official data on FinTech credit is limited, so most analyses of these markets rely on non-official sector surveys and financial disclosures of platforms. Data availability a

21、nd quality may warrant increased attention as FinTech credit markets develop. Academic surveys on lending volumes in 2015 show considerable dispersion in FinTech credit market size across jurisdictions. In absolute terms, the largest FinTech credit market is China, followed at a distance by the Unit

22、ed States and the United Kingdom. In general, FinTech credit is a small fraction of overall credit across jurisdictions, but it appears to be growing rapidly, and it may have much larger shares in specific market segments. For example, in the United Kingdom, FinTech credit was estimated at 14% of eq

23、uivalent gross bank lending flows to small businesses in 2015 (CCAF and Nesta (2016), but only 1.4% of the outstanding stock of bank credit to consumers and small and medium enterprises as of end-2016. Relative to traditional banks, FinTech credit platforms heavy digitalisation of processes and spec

24、ialised focus may lower transaction costs and entail convenience for end users. It may also increase access to credit and investments for underserved segments of the population or the business sector. Notwithstanding these benefits, there are a number of potential vulnerabilities that might impede t

25、he future growth of the industry. The financial performance of platforms could be substantially buffeted by swings in investor confidence, given their agency lending models. Moreover, financial risk in platforms may be higher than that at banks due to greater credit risk appetite, untested risk proc

26、esses and relatively greater exposure to cyber-risks. For financial stability, FinTech credit activity could present a range of benefits and risks should it grow to account for a significant share of overall credit. Among potential benefits are access to alternative funding sources in the economy. A

27、 lower concentration of credit in the traditional banking system could be helpful in the event there are idiosyncratic problems at banks. FinTech platforms may also pressure incumbent banks to be more efficient in their credit provision. At the same time, if FinTech credit achieves a significant sha

28、re of credit markets, it may give rise to systemic risk concerns. Some factors that contribute to increased financial inclusion associated with FinTech credit could also lower lending standards in countries where credit markets are already deep. Moreover, FinTech credit provision could be relatively

29、 procyclical; most notably, there is the potential for a pullback in credit to certain parts of the economy because of a loss of investor confidence during times of stress. Incumbent banks might take on more credit risk in response to increased lending competition, while an abrupt erosion of their p

30、rofitability could generate broader difficulties for the financial system, given banks provision of a range of systemically important services. Lastly, FinTech credit poses challenges to the regulatory perimeter and authorities monitoring of credit activity. 2 1. Introduction “FinTech” can be broadl

31、y defined as technologically enabled financial innovation that could result in new business models, applications, processes or products with an associated material effect on financial markets, financial institutions and the provision of financial services (Carney (2017). FinTech innovations are emer

32、ging in many facets of finance retail and wholesale payments, financial market infrastructures, investment management, insurance, credit provision and equity capital raising. This report focuses only on FinTech-enabled credit provision. In doing so, it complements a range of other studies recently r

33、eleased or being prepared by official bodies on other aspects of FinTech.1 FinTech credit has generated significant interest in financial markets, among policymakers and from the broader public. Some commentators have suggested that FinTech credit innovations could transform lending markets by reduc

34、ing costs, improving customer experience and enhancing credit risk assessments.2 An alternative view holds that future growth in FinTech credit could be constrained by business models that are vulnerable to changing financial conditions or investor and consumer protection considerations.3 This study

35、 aims to help policymakers understand the functioning of FinTech credit markets, including the size, scope and growth of these activities. It also assesses the potential microfinancial benefits and risks of these activities, and considers the possible implications for financial stability in the even

36、t that FinTech credit should grow to account for a significant share of overall credit. Conduct and prudential regulatory policies in selected countries are also outlined, but broader regulatory issues surrounding information technology (such as those related to data privacy) are outside the scope o

37、f this study. The study strives to provide as accurate a picture of the extent and nature of current FinTech credit activity as possible. Nevertheless, some findings and conclusions in this paper may be hampered by information gaps. Moreover, because the market is still in the early stages of development, FinTech credit business models and practices are likely to continue to evolve. For the purposes of this study, the term “FinTech credit” encompasses all credit activity facilitated by electronic platforms whereby borrowers are matched directly with lenders. These entities are