Department of Treasury’s Plea to Understand Online lending

财政部决定如何对新市场贷款行业进行分类和分类。人们使用“Marketplace或P2P贷款”一词正如供应链金融。

根据这一点Department of the Treasury's Request for Informationon how to regulate this space, they define this space in the following manner:在线市场贷款是指使用投资资本和数据驱动的在线平台借给小企业和消费者的金融服务业的部分。

This need for regulation is driven by growth. According to Morgan Stanley’s research, Global Marketplace Lending: Disruptive Innovation in Financials, in less than a decade, online marketplace lending has grown to an estimated $12 billion in new loan originations in 2014, the majority of which is consumer lending.

In undertaking this RFI, the Treasury has three objectives:

1. understand these business models
2. assess their potential to expand access to credit to underserved markets
3. understand how the regulatory framework needs to evolve to support growth.

I can tell you from experience that each vendor that plays in the B2B working capital space have different business models, processes, structures, etc. that could end up having large regulatory differences. Regulators are looking for clearer segment definitions and regulations may be different depending upon how each business is structured.

根据这一点Treasuries current understanding, they see three general categories of lenders:

(1) balance sheet lenders that retain credit risk in their own portfolios and are typically funded by venture capital, hedge fund, or family office investments;

(2) online platforms (formerly known as “peer-to-peer”) that, through the sale of securities such as member-dependent notes, obtain the financing to enable third parties to fund borrowers and, due to the contingent nature of the payment obligation on such securities, do not retain credit risk that the borrowers will not pay; and

(3) bank-affiliated online lenders that are funded by a commercial bank, often a regional or community bank, originate loans and directly assume the credit risk.

此外，其中一些公司已采用业务模式，其中他们合作并与银行达成协议。在这些安排中，银行作为借款人在平台上担任借款人。

The Treasury knows that with respect to small businesses, a number of studies have shown that these borrowers are more dependent on community banks for financing than larger firms, and this is a worry, as the number of banks continue to shrink in the U.S. According to Federal Reserve survey data released in February 2015, “a majority of small firms (under $1 million in annual revenues) and startups (under 5 years in business) were unable to secure any credit in the prior year.” More than half of small businesses that applied for credit in 2014 sought loans of $100,000 or less.

So ultimately the Treasury wants to understand not only how to define, segment and regulate, but also understand how reliable these credit risk models really are.

If you are interested in responding to the Treasury’s RFI, visit这里.

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