Determine whether the online lending platform is a capital pool model or a custody model

Let's first understand the concept of pools.

The key to the so-called "capital pool operation type wealth management product" lies in the "capital pool", which means that the issuing institution (generally the bank) will collect the customer wealth management funds raised to form a large "pool", which will be operated and managed in a unified manner. The new funds are the incremental water remitted, and the funds paid (or redeemed) at maturity are the outflow water, and so on, and so on, for uninterrupted liquidity management.

The capital pool model is the core of bank operations, why has it become a problem for the platform in the P2P online lending industry? ! A prerequisite for the good operation of the capital pool, a prerequisite for the good operation of the capital pool, is that the safety of the funds must be guaranteed (to ensure that they will not be misappropriated), and at the same time, investors must have sufficient confidence (not run at every turn). The key is how we, as investors, view and respond to the pool, I think a simple and effective way is to see if there is a real borrowing target behind the platform's pool to meet the funds in these pools; In addition, since dealing with the capital pool is a big consideration for the platform, the main thing is the strength and credibility of the platform!

The concept of escrow.

The third-party escrow can realize the separation of P2P platform accounts and user accounts, and increase the risk isolation means for user funds. The easiest and most effective way to identify whether it is a fund custody is whether the investor, borrower, and platform have opened an account with a third-party payment company.

Third-party payment adopts the reserve management method and the form of advance payment, and the third-party payment does not open a separate depository account for each user in the bank like the third-party depository.

He can give you money, no matter what the model, it's a good model.

What is Funds Escrow?

The meaning of fund custody is that the flow of funds runs in a third-party escrow company without going through the platform's bank account. In order to avoid the misappropriation of transaction funds caused by poor operation of the platform, which will bring risks to both parties to the transaction.

What is the funding process of the fund escrow model.

Taking Limin as an example, when investors and borrowers register, they need to log in to the third-party Shuangqian payment through the Limin platform to open their own IPS account, and the platform will also open a merchant account in the third-party payment, but they can only do two operations: unfreezing and refunding, and cannot perform transfer and withdrawal operations. When the investor recharges, the money in the bank card is recharged to its IPS account in Shuangqian, not to the platform account of Limin.com, in fact, the user's username registered in Limin.com only plays a role in fund reconciliation, and does not involve the flow of funds, which is what we often say about the separation of information flow and capital flow.

It can be seen that in the whole process of capital flow, the flow of funds does not pass through Limin.com, but is directly transferred between the accounts of the third-party platform payment platform of investors and borrowers. The third-party payment platform account of the online loan platform will only transfer part of the funds when the due intermediary service fee is obtained, so Limin cannot use the funds of investors and borrowers during the whole process.

What is a pool?

The capital pool is to pool funds together to form a space like a reservoir to store funds, which is the capital pool. Insurers have a large pool of funds, and the outflow of claims and the income from new policies keep it in balance. Banks also have a large pool of funds, and the outflow of loans and the inflow of deposits keep this pool stable.

How to tell the difference? The method is very simple, the investor's funds in the capital pool model will first flow into the bank account of the online loan platform, and the online loan platform can use this part of the funds. In the fund custody model, the customer's funds are directly circulated on the payment platform, and the online loan platform cannot use the customer's funds without going through the online loan platform, so the customer and the online loan platform must register a separate payment account on the third-party payment platform for fund custody and hand over the control of the funds to the customer and the payment platform.

When you decide to invest in a certain platform, you must look at whether the investor, borrower, and platform have opened an account with a third-party payment company.

P2P fund custody is a third-party escrow, and the fund pool is a fund pool developed by the platform itself, which cannot be supported now.

Pooling and escrow are two completely different concepts. Pooling refers to pooling the funds raised to form a "big pool". There is a special institutional pool of funds for unified management and investment, invested in a collective asset package composed of bonds, repurchases, trust financing plans, deposits and other diversified products, and the overall income of this asset package as a unified income of a variety of wealth management products**.

In the current Internet financial management model, the typical form of capital pool is CreditEase, investors buy CreditEase's wealth management products, which is equivalent to bringing funds into the capital pool managed by CreditEase, and then have its unified investment, this model has been criticized a lot, causing the regulator to attach great importance to it. One of the CBRC's regulatory ideas on online lending platforms is that platforms cannot engage in capital pooling, mainly because this model is not transparent, investors are not clear about the flow of their funds, and creditors and debtors do not correspond one-to-one.

The CBRC's P2P regulatory thinking requires platforms to set up third-party fund custody, which makes the call for third-party fund custody very strong recently. The so-called third-party escrow, in layman's terms, means that the funds you invest are recharged to your own third-party sub-account when the platform is recharged, and no one can touch this account; At the time of bidding, it is up to the investors themselves to operate their own third-party accounts. Nowadays, many Internet platforms say that they are third-party escrow, but in fact, many of them make a third-party payment interface for you when they recharge, and the money is still sent to the account that the platform can control, which requires investors to keep their eyes open when choosing a platform.

Here Xiaorong teaches you a way to judge whether it is a third-party escrow: find a platform, go to register, and see if you are allowed to open a third-party escrow account when you recharge, if you are allowed to open it, it is a real third-party escrow. Then it depends on the popularity of the third-party custodian that the platform cooperates with.

For example, Rongtuo Financial cooperates with Huifu Payment to implement third-party account custody, and Huifu's fund custody business ranks third in the country.

P2P cannot form a wealth management pool, otherwise it is suspected of illegal fundraising.

Hello, when choosing a platform, you can pay attention to the following points to choose the right one for you:

1. Look at the registration threshold:

Looking at the registered capital of the P2P platform, finding out the details, and blocking the P2P without capital capacity can reduce the risk.

2. Look at the risk margin

Risk margin, also known as risk reserve fund and risk guarantee fund, is one of the most commonly used security guarantee methods on P2P platforms. When the investment project on the platform is overdue, the platform will withdraw the funds from the risk margin account to advance the principal or principal and interest for the investor.

3. Third-party guarantee:

The P2P platform uses a third-party guarantee company to guarantee the principal, interest or principal of the investment projects on the platform, which is a safer guarantee than the risk margin.

4. Rationally look at high returns

The annualized returns of P2P platforms are in between, and some platforms must be vigilant when the interest rate level is too high.

1. Whether the platform has a third-party fund custody.

Third-party fund custody means that all the capital flow of the platform must go through the third-party payment platform or bank, and the third-party payment platform or bank will manage the capital inflow and exit of the P2P platform, and the platform has no right to use the funds at will. The Housing Easy Loan platform has a third-party fund custodian, and the platform does not set up a capital pool.

2. Whether investment and borrowing are one-to-one.

Under normal circumstances, the investor's investment and the borrower's borrowing should be one-to-one, that is, the investor's investment funds should have a clear borrower or borrowing project.

A very simple way to determine whether the investment and borrowing object are one-to-one is to see whether the borrowing object and the borrower on the platform are unified in the loan agreement provided by the P2P platform. If the investor just hands over the money to the platform and gets the income after a few months, it seems convenient, and the investor does not have to bother with choosing the project, but in fact it increases the risk of the platform's capital pool.

3. Is there a mismatch of bids or deadlines?

The P2P online lending platform splits the long-term loan into many short-term loans and then issues bids, that is, splits the long-term bids into short-term rolling financing, and "repays the old with new ones" to meet the maturity payment.

For example, if the borrower's loan term is one year, some P2P platforms may split the one-year term into four investment projects with a three-month term, and the principal and interest obtained by the previous investor at maturity are actually the funds of the later investor. Once the follow-up funds are missing, the platform will not be able to repay the principal and interest of the investors in the early stage, resulting in the rupture of the platform's capital chain and the difficulty of withdrawal, which shows that the maturity mismatch is more likely to cause liquidity risks.

The fund trustee refers to the investor and the borrower

Both parties have opened an account with a third-party institution, and in the process of the right to transfer funds, the third-party institution must not only do a good job in the transfer of funds and ensure the normal flow of funds, but also need to supervise the ** and whereabouts of funds.

Fund depository means that the P2P online lending platform places the platform's transaction funds or risk reserves in the account of a third-party institution, and the funds are kept by the third-party institution.

Mainstream platforms such as iTou Easy Loan have adopted three types of capital flow methods: gateway third-party payment, custodial third-party payment and bank fund custody. Now let's take a look at each one.

Gateway-based third-party payments.

This model is the most common, the system is the most convenient and mature, the cost is the lowest, and it is also the most common way of capital circulation, but in this way, the funds will be collected into the platform's own account without exception, which also forms a capital pool, which is suspected of illegal fundraising. Once the amount of funds in the account is large, or the risk of capital chain breakage, the platform can easily withdraw the investor's funds, which has been generally adopted by the platforms that have run away so far.

Managed third-party payment is a fund flow method launched by a few third-party payment companies in the second half of 2013, and all fund transfers need to be confirmed by the investor himself, and directly transferred from the investor's account to the borrower's account, without anyone's control in the middle, is a fully compliant fund transfer method. Only a small number of platforms established before November 2013 have changed from gateway to hosting, and the newly established platforms have a certain late-mover advantage in this regard.

Bank custody. Many investors think that bank custody is safer, but in fact, the meaning of bank custody is to pay according to the contract, and it does not make reasonable judgments. If there is a problem with the terms of the contract, the bank is not liable. Banks have two services in terms of money flow:

Fund custody and fund supervision, capital supervision is the most rigorous, but at present, no platform has adopted capital supervision, all of which are custody, so some people say that bank custody is "only trusted", only for deposits, which is very reasonable.

Security aspect.

In terms of the security of capital circulation, third-party fund custody can prevent misappropriation of funds, prevent the risk of running away and running, and is better than bank custody, but it is recommended that investors be cautious and do not easily choose a gateway-type payment platform.