监管摸底助贷权益类产品：拆解“服务费”障眼法

Core Viewpoint - The regulatory scrutiny on consumer finance companies and lending platforms regarding membership rights products is intensifying, focusing on potential violations such as bundled sales, false advertising, and hidden fees, particularly in the context of the "24% + rights" model that has emerged as a workaround to the 24% interest rate cap [1][4][5]. Regulatory Investigation - Regulatory bodies are conducting thorough investigations into the membership rights products offered by consumer finance companies and their partner lending platforms, aiming to understand the business models, fee structures, and any potential consumer harm [4][5][6]. - The investigation includes inquiries about hidden fees, binding conditions related to loan applications, and whether membership fees are being charged in a manner that violates existing regulations [4][7]. Market Impact - The anticipated regulatory changes are expected to significantly impact small to medium-sized lending platforms that rely on the "24% + rights" model, potentially accelerating market consolidation [2][11]. - The demand for "24%+" clientele remains uncertain, as institutions must adapt their business strategies in response to regulatory pressures [2][11]. Consumer Experience - Consumers have reported being charged additional membership fees alongside their loan repayments, leading to effective interest rates exceeding the legal limit of 24% [12][14]. - Complaints regarding undisclosed membership fees and the lack of clarity about the services provided have been prevalent, indicating potential violations of consumer rights [12][16]. Industry Trends - The "24% + rights" model has become widely adopted among lending platforms as a means to maintain profitability in light of regulatory constraints on interest rates [10][11]. - Many platforms are transitioning away from the previously common "dual guarantee" model, which often resulted in hidden fees, towards more compliant structures [10][11][18]. Compliance Challenges - The industry is facing significant challenges in achieving compliance with the new regulations, particularly for smaller platforms that may struggle to operate within the 24% interest rate cap [18][19]. - There is a call for clearer regulatory guidelines regarding the boundaries of membership fees and their integration into overall loan costs, as well as a potential transitional period for compliance [18][19].