Peer-to-peer (P2P) risk
A named "directed by investment (hereinafter referred to as the entrusted to be cast surely)" business model is, by including Liu Jin 360's you wealth, net financial and other big Internet financial platform are widely used. But its promotion, investors threshold and limit is not for special specification, suspected to circumvent regulatory arbitrage private management approach.
Our reporter D intern reporter li Qiang ginger poetry Reporting from Beijing
After the P2P, equity and the raise pattern, marriage of Internet finance and information technology business is quietly floating.
Before the 21st century economic report survey found after several P2P network credit platform, a named "directed by investment (hereinafter referred to as the entrusted to be cast surely)" business model is, by including Liu Jin 360's you wealth, net financial, and other big Internet financial platform are widely used.
According to incomplete statistics, the pattern on early Liu Jin product launch in April 2015 by "zero ended. At the same time, some issued in the name of the product platform, butt joint venture tube products plan to share the usufruct, disguised split on private products.
A number of the personage inside course of study thinks, because such a business in its promotion, investors threshold and limit is not for special specification, therefore measures for the administration of private equity funds has avoid regulatory arbitrage.
Previously published by the state council, on the other hand, "promote the healthy development of the Internet financial guidance", only for P2P, much attention has been paid to the raise of emerging business arranged regulatory plan, is not clear such business regulation has the qualities of "the Internet information technology". And after several P2P platform to get their hands on such a business, its regulatory black holes are now being exposed by quietly amplification.
Marriage P2P information model explanation
The Internet information, are becoming the P2P, equity after the raise, the "third pole" derived from the Internet in the financial sector.
21st century business herald reporter survey found that more than the current P2P platform launched a class of products, the operation of the real path in the name of "by directional" investment, to put money include trust usufruct, assets such as information technology planning, non-standard solid market.
In the business structure, nominally responsible for P2P platform to provide intermediary information service for financial products, at the same time the introduction of a trustee company with "directed by investment" relationship set up by the broker information or fund subsidiary information plan, issued by the information technology the identity of the plan for fixed assets investment, and the scope of its investment in the deal structure building and expanding.
What Liu Jin ended its zero is earlier engaged in such business financial products on the Internet. Liu Jin official disclosed that zero ended has good mobility, can apply for withdrawal in the terms of the working day, and the lowest amount is only 1 yuan, the liquidity and threshold almost with public funds.
But in terms of earnings, zero just loads are much better than public offering products - as of December 7, zero ended seven days average yield of 4.66%, have most goods over the same period 100 BP. And the product get excess returns rely on behind, its docking by "by putting in" private open information and the special structure of tube products.
According to zero ended the project business instruction "shows that investors put money entrusted to" shenzhen gathered up asset management co., LTD. (hereinafter referred to as gathered up assets) "investing in special asset management plan" net management products (special product) off ", while the product through the "issuer" management to achieve the investment returns. But in the "special products" on the investment scope of entrusted loans, trust plan, the beneficial right of the trust subsidiary, brokerages and fund only door plan non-standard debt assets such as impressively in the column.
The personage inside course of study points out that the zero ended the docking special plan for fund subsidiary substance issued by one-to-one special information technology planning, information technology products for private class, and Liu Jin so "directed by investment" relations between the money end in any "raise", has a certain tendency of regulatory arbitrage.
"Liu Jin actually played the endowment funds the drainage pipe product platform, and the balance of treasure have substaintial distinction, pay treasure to sell goods on a commission basis for balance Po is public funds, and information technology planning is private products, in theory can't be public recommendation." Middle, according to a fund subsidiary Shanghai "general single (information technology) program legitimacy usually have money to do the investigation, if it is through the raising of the public, in violation of the big problems on compliance."
"This pattern is to play a word game, wrap business 'raise relationship in essence is entrusted investment orientation relationship." The fund subsidiary middle personage points out, if the trustee of the product was linked with Taiwan side, the implicit moral risk is bigger.
And 21st century business herald reporters access to business data, found that the entrusted gather up assets that Liu Jin its wholly owned subsidiary.
Disclosure of information asymmetry
Although compliance risks, but the business model also follow by other Internet banking platform. For example, the 360's launch platform you wealth "small ended, network finance's letter" exclusive financial product and a company called "dry yeepay platform, also used for" by putting in "business model;
In such financial business, also have the product of a fiduciary relationship with Taiwan side belong to, such as your wealth "little clown" meridian entrusted to the shenzhen sea before financial information service co., LTD. (hereinafter referred to as meridian financial), the company also for your affiliates of wealth.
Reporter verify information distribution of industry and commerce, meridian financial for natural person shareholders Lu Defu wholly-owned holding, Lu Defu another identity is the co-founder of qihoo 360 finance.
In the industry view, "by cast surely" pattern on rights, risk hidden more asymmetry, lies in its on the asset side enjoy information technology plan and other private products on the scope of investment has the flexibility, but on the money side such as site promotion "quasi public offering in the form of" drainage investment money, does not need to perform information disclosure obligation of public funds.
In zero ended in the product manual, for example, not by Liu Jin issuer identity shall be clear for special products, at the same time the product of asset holdings subsidiary, information on a regular basis is not be mastered by investors. In addition, in the scope of its asset allocation, the trust of remuneration, such as information technology program has a certain credit risk of the standardization of creditor's rights has been included in the scope of investment.
Reporters call Liu Jin customer service by trying to understand which fund subsidiary is the issuer of the foregoing information plan, but customer service said the issuer that is gathered up assets, but the company is not fund subsidiary, does not have the issue of information technology planning qualification. When the reporter asked investors to invest, it can view the information plan position, the other party say the website information shall prevail, the rest didn't know.
Some related financing projects
It is worth mentioning that zero just loads on the structure of the docking, only information technology is an open cash management plan, another part of the platform products by entrusted to decide the form of solid split the share of the class information plan, and to conduct business on a regular basis, and indirectly provide debt financing for some financiers.
To your wealth, "small treasure - wide green wealth phase 2 (hereinafter referred to as the green phase 2)" products as an example, the expected annual return of 5.7%, the product to raise 55 million yuan, the deadline for 83 days, and the initial investment threshold is 1000 yuan, only on the investment direction, the product subscribed by the assets of "fixed income classes could plan issued by financial institutions' share of profit".
"Is actually using the concept of usufruct do break up, big small, purpose is a disguised form around private way." Beijing a trust company senior trust manager thinks, "this model has some disputes, bold dare to participate."
At the same time, the green phase 2 declared in the product elements, its investment by the background of large state-owned listed companies provide a repayment guarantee, while the product manager for a company called "Shanghai yu" asset management co., LTD. "of the enterprise.
Reporter found that after verification, the parent of the company for the Shanghai Greenland group company, "" Shanghai greenbelt financial information service co., LTD.
According to industry insiders speculated that the real actors and repayment guarantee, is likely to be completed backdoor listings of green land holdings (600606. SH) or its related parties.
"Green space is likely to be financiers behind the project, in addition to the name contained in the green space, this provide a repayment guarantee 'background of large state-owned listed companies' might say is green." The trust manager said.
Be worth what carry is, according to the green phase 2 contract details, it depends on the relationship still for entrusted investment orientation, and its defined trading name for "green wide wealth 360 junan x".
In addition, also contains the name of guotai junan securities "junan" two characters. At the press, however, has not been able to prove that the product related with guotai junan securities.
21st century business herald reporter called 360 customer service to ask whether the project you wealth to provide financing for Greenland group, the other is said the project was not financing project, but the asset management.
When reporters asked 360 customer service your wealth with investors, the plan of issuers and investors, the other customer service has just introduced the "small ended before distributing human meridian, and the" treasure "" each is different," but did not mention the special information who is the issuer of the plan.
The customer service also said that information technology plan on a regular basis is "not disclosed" open structure, its guarantee to the reporter at the same time, the business "must be within the scope of the law".
Similarly, network finance's letter "Chen xin series" also USES the directional entrusted investment model, and different from the foregoing two platform, network finance is not in the product introduction, the entrusted party disclosure of information. In addition, its each product of the total investment is 1 million yuan, analysts believe that this aim to raise the size of the arrangement, means that the product information behind the docking plan for more than a pair of products.
"Each 1 million, this is the initial investment threshold stipulated in the private product, also said the product may be one-to-many connection behind plan." Subsidiaries have pointed out that the funds.
Journalists as an investor to grid letter financial customer service telephone, the other party said to raise funding, special information technology plan to the issuer and the phenomenon of every why to raise a total of 1 million have said "not clear", but they still stressed that business does not involve violations.
For the above problem, the reporter to Liu Jin, at the same time you wealth, net financial management consulting, but by the deadline, have not yet received the reply.
Or as a regulatory black hole
In the industry point of view, whether it is located in the zero just loads of cash management class, or on a regular basis to carry out the information of usufruct of the "big small", the trade structure on the compliance of all exist certain flaws.
"The problem is not in the financing project itself, from the background of the platform itself, project payment risk is not big, but this kind of product there are a lot of problems on compliance." The fund subsidiary said.
"The logic is not complicated, investors on the Internet or other public channel indirect investment in the private product such as information technology planning, and bear the risk of private products, but can't enjoy public offering standard letter wrap around." The fund unit, according to "the other is the information plan in should raise money on capital source legitimacy through verification, these funds are clearly multi-channel gathering, which violates the private management approach to the requirement of investors appropriateness management."
According to the securities and futures commission in the "interim measures for the supervision and administration of private equity investment fund" and "securities and futures business institutions to carry out the asset management business" eight line under the regulations prohibited behavior rules, information technology products belong to private property, and its investment, promote also have relatively strict restrictions, such as the individual investor's investment of no less than 1 million yuan, and investors need to meet the financial assets of not less than 3 million RMB or not less than 500000 RMB for three consecutive years annual income etc.
And in the industry point of view, the "by putting" such as model was able to appear, and the current Internet financial platform innovation demands and entity economy internal financing needs.
"Real demand is there, private bad hair products, and then use the Internet platform to get through the channel, which is information agencies and financiers of." Before the fund subsidiary who said, "like OTC privately raised company bonds split in ali platform to send, logic is the same."
More analysts pointed out that the existence of this kind of business, enriching the domestic Internet financial products and revitalize the stock has certain positive meaning.
"This type of business belongs to" play ball "type of asset securitization, to revitalize the stock has certain positive meaning." North China securities company fixed income department yet (not his real name) thought, this in the current asset securitization market growth is limited, is an attempt to encourage.
But yet also pointed out that this kind of product in flat when the strength distribution is almost zero regulation ", so in addition to its credit risk, the underlying compliance risk, policy risk and moral risk must also been paid great attention in the market.
"Regulators should further standardize on this kind of business, such as such cooperation to arrange some regulatory indicators or access, or the occurrence of risk events of one thousand, under impact or industry itself in the end." Yet advice.
It is important to note that such a "Internet information" characteristics of gold each mode by regulators and the market is not too much attention, in addition to the present scale co., LTD., also with "opinion" on Internet financial issued by the state council, to this kind of mode of "defects" was associated.
"Mutual gold" opinion "were mentioned in total lending, equity and the suggests, Internet payment, network the Internet and the Internet, the Internet trust fund sales, Internet insurance consumer finance several content, but does not relate to the information technology 'big split open a little" mode." Shanghai a P2P platform head said, "actually should do is not a complete stop, but should be conditional specification, if laissez-faire attitude of this model, the financial industry, so will soon become an Internet regulatory framework on the" black hole "."