"One Company, One Policy": Consumer finance co-lending cooperation tightens further

21st Century Business Herald Reporter Yang Mengxue

Recently, there have been reports that regulators have issued new documents to consumer finance companies, requiring strict control over the scale of assisted lending, guarantee-enhanced credit loans, and other areas. They also put forward related requirements regarding collection efforts and cooperation with assisted lending companies.

According to the 21st Century Business Herald, this issuance continues the previous policies related to assisted lending, and several consumer finance companies have already received relevant directives, including requirements to control assisted lending scale and guarantee-enhanced credit loan amounts, and to prohibit rigid commitment clauses in agreements with assisted lending institutions.

A senior executive from a leading consumer finance company told reporters that, this regulatory requirement is “one policy per company,” and the progress of interviews and the specific demands received may vary across different regions, but the core regulatory logic remains to encourage consumer finance companies to reduce reliance on assisted lending.

In the current industry context, on one hand, strengthening self-operated capabilities has become a consensus; on the other hand, some industry insiders mention that as regulatory requirements progressively tighten, the entire business process responsibilities will be reshaped. Consumer finance companies will need to bear primary responsibility throughout the entire loan process—pre-loan, during loan, and post-loan—without outsourcing risk.

Specifically, this regulatory requirement involves multiple aspects.

In terms of scale, it further demands that consumer finance companies control the size and proportion of assisted lending. Some companies have been asked to set December 31, 2025, as the upper limit, with the balance of guarantee-enhanced credit loans to be reduced to 35% or even lower of total loans (previously 50%). Regarding collection, the long-term goal is to keep overdue loans within M2 (loans overdue less than two months) without outsourcing collection. In terms of business cooperation, it prohibits rigid commitments such as minimum approval rates, and requires reducing the scale of credit enhancement business under the same assisted lending company and its related entities.

Overall, these requirements are extensions of the new assisted lending regulations, focusing on controlling scale, risk, and strengthening responsibility. An industry insider analyzed that the core logic of this issuance remains to encourage consumer finance companies to reduce dependence on assisted lending.

“For example, the industry has already been reducing the proportion of融担 (risk担保) models before the new assisted lending regulations were released. Previously set at 50%, now down to 35%. The goal is to further decrease reliance on融担 risk outsourcing models. The same applies to assisted lending business—different institutions have different timelines, but the principle is to only decrease, not increase. Essentially, it further quantifies previous regulations,” said the senior executive.

“Controlling the scale of assisted lending and limiting the balance of guarantee-enhanced credit loans is about weakening consumer finance companies’ dependence on external channels, reducing concentration of cooperation, and lowering leverage risks,” said Wang Pengbo, a senior analyst at Broadcom Financial Industry.

Regarding the impact on institutions, many industry insiders believe the effects will vary across different organizations.

“Assisted lending agencies are essentially intermediaries. De-intermediation has always been a regulatory requirement. The core logic is that financial institutions bear the operational risks and cannot outsource risk. But the market has already formed such an ecosystem, so progress must be gradual. Therefore, the impact on different institutions will differ, and the specific effects may vary,” said the senior executive.

Summarizing industry opinions, most agree that top-tier institutions with strong self-operated capabilities will be less affected, and may even gain more market share due to industry reshuffling. For mid- and lower-tier platforms with high融担 proportions, the pressure is greatest. “For a few institutions, reducing to 25% means cutting most of their business, which is nearly impossible in the short term,” a consumer finance insider in East China admitted.**

Wang Pengbo believes that the entire industry will shift from past efforts to chase traffic and scale to building autonomous risk control and self-operated capabilities. Small and medium institutions that heavily rely on assisted lending platforms will see their profit models disrupted, while leading licensed institutions will have a clearer advantage.

Regarding the progressive regulatory requirements, the entire business process responsibilities will also be reshaped.

“Previously, assisted lending involved collection outsourcing to assisted lending companies, as they had all customer information—from acquisition to risk control to collection—making the process smooth for them. Now, financial institutions are required to control risks themselves, meaning these responsibilities cannot be delegated to assisted lenders and must be borne internally. This is essentially a redistribution of responsibilities between consumer finance companies and assisted lending agencies,” said the senior executive.

Analyzing the key points of this regulation, it appears that prohibiting rigid commitments before loan approval essentially means consumer finance companies must retain the final decision-making authority over customer acquisition and loan approval; further restricting collection outsourcing means consumer finance companies must take primary responsibility during post-loan management.

Wang Pengbo explained to reporters that the requirement that collection within M2 cannot be outsourced essentially forces institutions to take on post-loan management responsibilities, reducing compliance and reputation risks associated with outsourcing collection. Banning hard targets like minimum approval rates or minimum disbursement volumes aims to curb institutions’ “scale impulses” from the source, preventing them from relaxing risk controls for the sake of volume.

He believes that, in the short term, institutions will need to increase investment in self-operated collection teams and systems, which will raise costs. However, in the long run, this will promote more standardized post-loan management and better protect consumer rights. Pricing and approval processes must return to risk-based pricing; reliance on scale for profits will diminish. Asset quality will become the most critical evaluation metric, and the industry’s previous broad expansion model is coming to an end.

Su Xiaorui, senior researcher at Su Xi Zhi Yan, stated that the licensed consumer finance industry is under stricter regulation, with some requirements echoing previous assisted lending regulations, such as controlling assisted lending scale and guarantee-enhanced credit loan balances, aiming to reduce dependence on external traffic platforms and guarantee “backstop” models; also, reclaiming early collection rights from institutions aims to eliminate violent collection practices at the source and promote further strengthening of risk control capabilities and the creation of a full-process autonomous risk control loop.

Under the strong regulatory environment, strengthening self-operated capabilities has become a consensus in the consumer finance industry.

“Since last year, many consumer finance companies have been enhancing self-operated functions and reducing assisted lending, mainly cooperating with leading assisted lending firms. In the era of strict regulation, consumer finance companies must strengthen self-operated capabilities to achieve high-quality growth,” said a North China-based consumer finance executive.

“Both the new assisted lending regulations and subsequent requirements essentially aim to prevent assisted lending agencies from becoming too dominant. When cooperating with assisted lenders, banks and other financial institutions need to maintain control. For example, prohibiting risk outsourcing, requiring self-risk bearing, and avoiding over-reliance on a single institution—all these ultimately mean that institutions should be self-reliant,” said the senior executive.

Regarding future business growth, the North China-based executive noted that many consumer finance companies are increasing capital for strategic reasons, and strengthening self-operated capabilities is part of that plan.

Su Xiaorui believes that overall, the licensed consumer finance industry will evolve from “traffic-driven” to “capability-driven,” developing autonomous customer acquisition, risk control, and post-loan management capabilities.

Wang Pengbo stated that the overall goal of this regulatory wave is to eliminate superficial, circuitous channel businesses, reduce leverage, and truly build up risk management and self-operated capabilities, ultimately aiming to keep risks under control and promote a more stable, healthy industry. “Institutions that rely on assisted lending and outsourcing will find it increasingly difficult to survive. Licensed institutions with real self-operated capabilities will gradually become mainstream, and the industry will enter a stage of high-quality development.”