When riding a bicycle in a city, did you find any small advertisements that appeared everywhere? Can I have an impression of the content of a small ad?
Not long ago, the nation’s first case in which “Hua Hua†was illegally cashed and sentenced to jail was formally pronounced. The suspect Du Mou cashed out 4.7 million yuan in 4 days. The threshold for committing the crime was low and the sum of money was staggering. The realization of these virtual credits in the coat of “Internet†and “new finance†also brings new challenges to supervision. On the one hand, violations are more subtle, and on the other, risks are cross-linked. It remains to be seen whether the relevant parties can cooperate with the platform parties to unblock and combine them.
When "funds hackers" aim at sharing bikes
“What's so scary, I brush more than a dozen orders a day.†At 10:00 on January 16th, at the Shenzhen Bookstore Square, the reporter used the identity of a “cash player†to pass the “circle†and white bars on the shared bicycles everywhere. "The small advertisements are cashed in, and an advertiser who claims to be "without any collateral and cash in seconds" has taken over. According to the records of the other party's production of flowers, the same "face to face transaction", just in the morning on the same day, has already traded 3 orders, the amount ranging from 200 yuan to 400 yuan.
Scorpio is an internet financial consumer credit product launched by Ant Financial. Users can receive credits ranging from 500 to 50,000 yuan, and enjoy an interest-free period, but they must rely on scenarios or shops to consume. Jingdong I-bar products are similar to those of Huarong, but they can only be used when shopping at Jingdong Mall. In the gray cash chain, flower buds and white strips have been operated as arbitrage tools.
How to achieve "second to cash"? For brokerage Chinese reporters demanding different amounts of money as "cash investors", the advertiser who claims to be surnamed Li (hereinafter referred to as Li Sheng) demonstrated the different options and fee rates of flowers, white bars and even credit cards.
The first is flower buds. After asking the “cash player†to set the quota, Li Sheng took less than half a minute on the mobile phone to generate an Alipay account QR code; after the “Cover†scanned the code as required, it showed a certain domestic product. The mobile phone, worth more than 7,100 yuan, is paid for. In this case, as long as you click on the payment, you can immediately use the payment and complete the purchase transaction. Li Sheng will use cash transfer to deduct 6390 yuan after the 10% commission to cash. people". The entire cash out is completed, and the “cash player†does not need to check the purchased goods.
In the other case, “cash player†needs to check the purchased goods. For Li Sheng, “this is safer, but the cost is higher, so the processing fee must be charged 15 points (15%).†, Cashier will purchase the other party’s designated goods on Tmall or Jingdong, complete the payment and transaction with flowers or white bars and collect the goods, and then Li Sheng will return the goods at the “receipt price†to pay for the goods. The “cash player†deducted the transaction fee for the purchase price of the product. At this point, the entire cash flow was completed.
Li Sheng said, "We don't produce money. We're just porters in the renminbi." But to a certain extent, these cash-off individuals have become "money brokers" for various kinds of illegal loan assistance.
“On the surface, the entire transaction has the process of actively consuming and transferring the price, but if it is penetrated, the combination of the two steps is a process of illegal cash withdrawal.†Lawyer Luo Yang of Dacheng Law Firm in the field of mutual funds Told reporters.
This type of grey cash flow has been under the control of the government, but it has continued to be banned. Through the use of various new carriers such as urban shared bicycles, gray cash has reached a wider user base and has brought new challenges to supervision. According to the latest data obtained by the reporter from OFO, the city of Shenzhen puts 250,000 bicycles and rides 3 million vehicles/day, especially in some commuters, such as technology parks and shopping districts with large demand, user groups and cash. Credit groups are highly overlapping.
Although both Moipai and OFO have explicitly stated that bicycle advertisements have been banned explicitly, posting on small advertisements has encountered the same difficulties as urban management in clearing all types of wall “psoriasis†advertisements. fast.
Li Sheng told reporters, “In Shenzhen, where there are bicycles, there are 'flower buds and white strips'.†The reporter counted a bicycle parking spot in the densely populated central business district, and there are 8 bicycles in 20 bicycles. Cash-inducing small advertisements, of which 6 telephone numbers can be opened, the telephone end is none other than the cash withdrawals recommended by the above model, and the fee rate is between 8% and 15%.
Miscellaneous underground gray gold chain
If the transaction fee is calculated at a rate of 8% to 15% (regardless of the illegal cost), the reporter has calculated that the annualized interest rate of the capital cost of the “cash player†and the “white float†arbitrage has reached 104.35% to 211.76%.
At present, the comprehensive rates of small short-term cash loan products such as Internet giant financials such as Ants, Tencent micro-lending, and the well-known mutual fund platforms such as Pleasant Loan, Wealth, and Fun Stores are strictly 36% annualized in accordance with regulatory requirements. The following; According to the reporter learned from the cash loan industry insiders, the integrated annualized rates of some small and medium-sized cash lending platforms are still around 130% to 150%. That is, in contrast, the cost of illegal cash outflows for calyx and white bars is at a medium-high level in the industry. So, are there still people who will take the risk to cash out?
In Li Sheng’s records of flowers, the reporter saw that in the past two days cash orders were 15 to 20, except for the two sums of up to RMB 30030 and RMB 5790, the others were between RMB 200 and RMB 500. A small amount of money, many of which are realized through the purchase of electronic products, online games and other cash transactions, the daily cash flow of transactions estimated to reach 3,000 to 46,000 yuan.
Judging from the small amount of high-frequency characteristics of the transaction flow, Luo Yang's lawyers analyzed that “this aspect is conducive to the evasion of ants and Jingdong platform monitoring by the cash advanceers; on the other hand, it also shows that the cash-rolling platform customers overlap very well, even Yes, there are many similarities between the model of the team that uses the entire chain to cash out and the previous models of the small-to-medium-sized cash lending platform with no risk control system.
Li Sheng said he came from a cash-loan platform, which started in February 2016 in the circle of friends to release all kinds of small loans cash information, which involves many small and micro businesses online payment tools and small loan products. For example, one of the products losterbank, "there can be borrowed with an ID card, an identity card to take away 5,000, do not look at the credit information. Flowers, white bars, credit cards, cash seconds." The company behind this loserbank is Shenzhen Reel Credit Network Financial Services Co., Ltd., whose official website introduced and actually paid 50 million yuan, was established in 2015. It is the first pure one-to-one model online loan information integration platform in China. Only the depository bank is shown in the record information. .
Following the clues offered by another advertiser who supports advertising with cash, the reporter found out the company behind him. Registration information shows that its company address is located in Huaqiang North Road, Futian District, Shenzhen, with a registered capital of 1 million yuan, registered in 2012, the company scale of 50 to 99 people, the company's business scope is ant flower gong, Jingdong white, credit card mention modern. However, the reporter did not find the company on the site visit.
"Some companies can easily obtain the merchant's QR code, and then through the transaction operation, organized and cashed on multiple occasions, the funds that are set aside are then flowed to some P2P websites or small loan platforms, thereby earning a spread." The founder of the company stated that the anonymization of mutual exchange transactions brought about a mixed bag of practitioners. Part of the grey cash-out team is operating, and may even itself be a cash-loan platform that is on the edge of the supervision, and the business is online and offline, forming a huge underground chain.
Wind control technology "can't stop"
This kind of gray gold chain not only appeared in the local area, but the two “capital brokers†that were exposed during the survey of the reporters put the “business†into the Pearl River Delta region. Their bluntness could be introduced through “friends†in places like Jiangsu and Zhejiang. Cash business.
Moreover, because of the low implementation cost of the cash-out business, in addition to offline sharing of bicycles, a multi-platform, highly concealed method of obtaining customers and trading channels has also been developed. The reporter was informed that on a well-known second-hand idle trading platform, some small cash-rich teams of 2 to 3 people are active.
It is not difficult to find that in the entire cash out process, the complete transaction chain formed between the original consumer, the consumer financial product provider, and the Internet shopping mall, due to the involvement of “money brokersâ€, cashing appears to have become an “unprivileged†sale and purchase. . Driven by interests, the "money broker" end of cashing out the gray gold chain often involves complex subjects and a wide spread. Although it is strictly prohibited and the word "law" is on the head, it is still taking the risk.
In December 2017, the nation’s first case sentenced for criminal use of “Hua Hua†for illegal cashing was sentenced. In a four-day period, the case’s party Dumou collaborated with more than 2,500 e-commerce user fictitious transactions across the country, cashing out more than 470 million yuan from “Huahuaâ€, and collecting a total of more than 400,000 yuan in fees, posing an offence of illegal business. He was sentenced to two years and six months imprisonment and a fine of 30,000 yuan.
Regarding how to prevent the emergence of cash outbreaks on the platform, Ant Financial and JD.com all mentioned to the reporter their risk control system. Ant Financial represents smart risk control brain, anti-fraud policy engine and partners' joint defense and control mechanism through massive data; it has intercepted hundreds of thousands of suspicious transactions and intercepted most of the suspected fraudulent transactions in advance; Jingdong It is informed that it is technically monitoring the matter and managing it afterwards, the technology identifies the false and abnormal receiving addresses in real time, and identifies the business community involved in brush orders or fraudulent transactions. Once violations are found, the store is closed and the funds involved are frozen.
However, Zhang Yexia, a senior researcher at Net Loan House, analyzes that such problems are irreconcilable and cannot be stopped by technical means alone. “The speed of new methods of financial speculation tends to be faster than the speed of supervision.†She analyzed that the current part The e-commerce platform has the advantages of easy auditing and management of merchants' qualifications and low barriers to entry, and loopholes in business processes such as the monitoring of e-commerce operations status have provided convenience for illegal arbitrage.
Alienated mutual gold risk
"Flowers" and "white bars" are cashed out. Like bank credit cards, they have arbitrage space because of their interest-free design.
Credit card cash has been rigorously investigated, but it has also been banned on a continuous basis. To a certain extent, it is because of its arbitrage design that brings "black soil." “Whoever took the lead in combating the cash out, the issuer scale, loan balance, and the conversion rate of customers converted in phases will all fall.†A senior banking expert told reporters, so no one would dare to actually ban the use of cash. Other products also face the same problems as credit cards.
According to the Analysis of China's Financial Supervision Report (2017) by the National Finance and Development Laboratory of the Chinese Academy of Social Sciences, financial technology stepped into the 2.0 phase, showing the functions of cross-border, decentralization, de-intermediation, and self-servoing: financial disintermediation is deepening. The weakening of the functions of traditional financial intermediaries, or "active disintermediation," reduces regulatory costs, creates new problems for financial consumer protection, and challenges the effectiveness of traditional financial supervision models. In this context, consumer credit products such as flower buds and white bars have a more complicated attitude to their cashing violations because of their new financial attributes and associated scene trading, compared to bank credit cards.
“Even in the era of conventional POS machines, it was hard to avoid distinguishing whether payment and settlement were based on real trade scenarios or bad purposes based on cash. Not to mention the fact that in the Internet era, financial transactions became popular, the threshold was low, and links were much higher. Moreover, coupled with the anonymity of the transaction, the number of supervised entities is more and the risk point is more.†Lawyer Luo Yang said that even if the supervision is even greater, there will always be a time when one hundred secrets are sparse.
In fact, not only in the field of virtual credit cards, mutual gold risks cross and cover, but also challenge the supervision of other areas. “Internet financial fraud has almost involved all areas of finance. Under the cover of “Internet+â€, there have been numerous 'Ponzi schemes'.†In July 2017, Zhou Hongren, director of the National Gold Experts Commission, introduced the domestic Internet financial platform 3.1 More than 10,000 households, including 21 types of business such as online lending, Internet asset management, and online crowdfunding, with more than 6,000 online lending platforms, nearly 3,500 Internet asset management, 800 network crowdfunding, and active users in the second quarter of the year With 530 million people, Internet finance has been universal, but risk prevention is still a long way off.
Helping others cash out and collecting commissions may be suspected of being illegal, and there are also hidden risks for users to cash out. Previously, users used online advertising to enter the intermediary cash QQ group in an attempt to cash out, provide the intermediary account number, password, and mobile phone verification code to the intermediary for ordering, but the intermediary changed the password after purchasing the virtual product. When the user asks for cash, he is found to have been kicked out of the QQ group and blacked out by the intermediary.
It should be noted that after the user cashes in through the transaction, he still bears the responsibility of repaying his/her account or order; and when the user conducts a transaction with the “money brokerâ€, the user may steal the sensitive information of the user’s personal account, password, etc. , conduct various types of fraud.
Thinking: How to Balance Innovation and Risk
How to balance the relationship between internet financial innovation and risk prevention and supervision has always been the core issue that has been repeatedly mentioned by regulators. If regulation is not clearly defined and rules are not established, it also means that explosive growth has occurred in the past three years. The mutual gold platforms will always have a sword of Dakmus hanging overhead.
For example, in the online loan industry, beginning in 2013, the Internet's P2P innovation model has developed a hot market, and in the following years, various types of online loan platforms have ushered in explosive growth in both number and scale. With the savage growth of this period, various problems in the industry such as illegal fund-raising and run-way fraud have gradually increased. In the processing of these new gold issues, the main problem is to “find together and investigate togetherâ€. Supervision has always been considered as passive, but by the end of 2016, especially since the second half of 2017, the frequent exchange of gold regulatory actions has long been an earlier pattern.
Under the new regulatory idea, the promiscuous industry will surely attract a new round of reshuffling. The sword of Dakmus falls, so “bad news†is that some of the non-compliant platforms will be cleared out; “good news†is that after the industry's threshold is improved, high-quality platforms provide more secure and compliant services.
The ant flower scorpion and the Jingdong white bar are based on the real trade background and the payment and settlement are made. The escrow is currently a pure fund transfer. However, the background of the scorpion and white bars cannot be completely screened and the behavior is reviewed. Why? Internet finance has the characteristics of anonymity, light assets, cross-regional, cross-industry, and media. Some of these are simply not hybrids among institutions registered in the name of financial institutions, and the industry is promiscuous, making its risks more widespread and mine clearance more difficult.
The cross-cutting and complicated financial risks of the Internet have always been recognized as the difficult points for supervision. Therefore, the passive supervision before this time did not mean not to control or to know how to manage. No matter whether it is okay or not, the one-size-fits-all policy is not correct. As a result of the intensive release of regulatory documents issued in the second half of 2017, it can be found that supervision now presents the idea of ​​“subject supervision†and “behavioral supervision†in parallel.
The main feature of “subject supervision†is to establish who can do this through the threshold, qualifications, and licenses, and who is most qualified to do it. Therefore, mutual gold special rectification continues to advance, and the filing schedule has a specific timetable. It is planned to be the main tone of the development of online loan platform for a period of time in the future; the “behavioral supervision†is characterized by the prohibition of what can not be done, such as not being able to operate across geographical areas, and the annualized comprehensive rate cannot exceed 36% of the red line, such as the recent payment by some third parties. Institutions have been punished by the central bank due to business irregularities and even have been revoked license plates.
The "subject supervision" + "behavioral supervision" are parallel and intensive, intensive compliance and regulatory documents are issued. On the one hand, it reflects the "strictness" of the year of strong supervision in 2017. On the other hand, it also shows flexibility, but it is a long-term one. There is still a gap in the establishment of the supervision mechanism. Some scholars raised the voice last year and proposed to introduce "regulatory sandboxes" in the financial science and technology field. The practice of regulating sandboxes is similar to the logic of free trade practices, delineating a security space or region within which financial technology tests various innovative solutions such as financial products, services, business models, and marketing methods. At present, the mechanism still stops at the discussion stage.
The regulatory authorities took the initiative to attack and grow along with the mutual gold market, aiming to guide the industry to grow wildly into the top-level design specifications. Although as some legal experts in the field of mutual capital observe, the current subject supervision is still in a priority position. This aspect is determined by China’s financial regulatory system; on the other hand, the main body supervision has the fastest results in the investigation of leaks. Immediately, but it seems too fast and urgent.
However, one of the ideas that the supervisory level is more clear in gradually exploring is to raise the threshold and strictly comply with regulations. As market participants, we must be able to be sensitive to the changes in market water temperature, but also be familiar with where the wind blows.
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