◇ 作者：上海金融与发展实验室首席专家、主任 曾刚 ◇ 本文原载《债券》2025年10月刊 摘 要 近年来，我国中小金融机构防范和化解金融风险工作取得积极成效，风险监测预警体系不断完善，风险 处置机制日臻成熟，资本补充机制持续优化，公司治理水平显著提升。然而，面对经营环境压力、资本 约束、风险管控能力不足、人才资源短缺以及数字化转型的挑战，其转型发展仍面临诸多困难。展望未 来，建议完善差异化监管框架，拓展资本补充渠道，推进兼并重组与市场化退出，强化公司治理，支持 数字化转型。中小金融机构自身需要明确差异化发展定位，优化业务结构与风险管控，持续推动数字化 转型，加强人才队伍建设，提升服务能力和客户体验，朝着高质量方向发展。 关键词 中小金融机构 金融风险防控 数字化转型 差异化监管 2025年的《政府工作报告》提出"积极防范金融领域风险""一体推进地方中小金融机构风险处置和转型 发展"。这体现了新时期金融风险防控与机构发展并重的政策导向。 中小金融机构作为我国金融体系的重要组成部分，承担着服务地方经济、支持中小微企业、促进普惠金 融发展的重要使命。当前，在经济转型升级、利率市场化深化、金融科技快速发展的大背景下 ...

Core Viewpoint - The Shanghai International Investor Conference emphasizes the theme of "Value Leading, Open Empowerment - New Opportunities for International Capital Investment and Mergers and Acquisitions" [1] Group 1: Financial Environment and Opportunities - Shanghai aims to enhance market vitality through higher quality reforms and innovations, improving the effectiveness of financial services for the real economy [1] - The city is focused on attracting global investment by creating a market-oriented, law-based, and international business environment [1] - There is a commitment to better coordinate openness and security, participating in international financial regulatory exchanges to strengthen financial risk prevention capabilities [1] Group 2: Support for Financial Institutions - Shanghai will create more market and development opportunities for domestic and foreign financial institutions, enterprises, and talents [1] - The city extends a warm welcome to institutions to establish and develop their businesses in Shanghai, contributing to the construction of an international financial center [1]

Core Viewpoint - The Beijing People's Procuratorate, in collaboration with the National Financial Regulatory Administration's Beijing Bureau and China University of Political Science and Law, has issued a joint initiative to combat financial black and gray industries, aiming to create a safe and trustworthy financial ecosystem [1][2]. Group 1: Financial Black and Gray Industries - Financial "black and gray industries" exploit consumers' urgent needs for rights protection, disguising illegal activities as "legitimate rights protection" to gain undue profits [1]. - Typical examples include improper debt collection, illegal loan mediation, malicious debt evasion, illegal insurance claims processing, false credit repair, and illegal stock recommendations [1]. - These activities disrupt financial management order and infringe on consumers' property safety [1]. Group 2: Multi-Party Collaborative Prevention System - A comprehensive prevention system involving judiciary, regulation, industry, platforms, and the public is necessary to combat these illegal financial activities [1]. - Strengthening information sharing and establishing a collaborative mechanism are essential for effective risk prevention [1]. - Financial institutions are required to report high-risk information proactively, while regulatory bodies should regularly conduct clue assessments and organize special rectifications [1]. Group 3: Consumer Rights Protection - It is crucial to enhance consumer rights protection to prevent illegal actors from exploiting consumers' eagerness to defend their rights [2]. - Improving complaint and reporting standards will ensure that consumers' reasonable demands are addressed promptly, preventing malicious complaints from consuming resources [2]. - Responsibilities of all parties must be clarified, particularly for online platforms regarding the verification of the qualifications of their members, information dissemination, and risk event management [2].

Core Insights - Chengdu Bank's Q3 2025 report highlights its robust asset quality and strategic positioning as a key financial support for the construction of the Western Financial Center and the Chengdu-Chongqing Economic Circle [1][2]. Asset Quality and Risk Management - Chengdu Bank maintains a low non-performing loan (NPL) ratio of 0.68% and a provision coverage ratio of 433.08%, placing it in the top tier of the banking industry [2]. - The bank's NPL ratio has remained at a historical low of 0.66% for six consecutive quarters, with a provision coverage ratio of 452.65%, significantly exceeding industry averages [2]. - The bank employs a refined risk control system, utilizing a comprehensive industry research framework and intelligent risk control technologies to predict and manage credit risks effectively [2]. - As of September, the bank's capital adequacy ratios are well above regulatory requirements, with a core Tier 1 capital ratio of 8.77%, Tier 1 capital ratio of 10.52%, and total capital ratio of 14.39% [2]. Credit Investment and Regional Development - Chengdu Bank's credit issuance aligns with the national policy to enhance financial support for the real economy, with total assets reaching 1.385 trillion yuan, a 10.81% increase year-on-year [3]. - The bank's loan and advance total reached 847.48 billion yuan, growing 14.13% from the previous year, thus contributing significantly to regional credit growth [3]. - The bank's deposits totaled 986.43 billion yuan, with an increase of 100.57 billion yuan, reflecting a growth rate of 11.35% [3]. Strategic Development and Growth - Chengdu Bank's strategic layout is closely aligned with the Chengdu-Chongqing financial collaboration policies, focusing on expanding its core business areas while developing new growth avenues [4]. - The bank has seen explosive growth in its cross-regional business, with over 30% of new deposits and loans coming from this segment, including personal deposits surpassing 100 billion yuan [4]. - The retail banking sector has shown significant progress, with over 5 million mobile banking users and a notable increase in personal consumption loans, reflecting a strong alignment with macroeconomic policies [4]. National Strategy and Financial Services - Chengdu Bank integrates its development with national strategies, focusing on technology finance, green finance, inclusive finance, pension finance, and digital finance [5][6]. - The bank has provided substantial funding for major projects, including over 45 billion yuan in special bonds and more than 16 billion yuan for local infrastructure [6]. - The bank's focus on key industries and innovative financial products has led to significant loan issuance to strategic emerging industries, with over 80% coverage for specialized enterprises [6]. Future Outlook - Chengdu Bank aims to leverage opportunities from the Western Financial Center and the Chengdu-Chongqing Economic Circle, focusing on high-quality development and expanding its business footprint [7].

Core Insights - The 2025 Financial Street Forum held in Beijing focused on the governance of financial black and gray industries, which has garnered attention from both domestic and international financial practitioners as well as the general public [1] Group 1: Financial Black and Gray Industries - Financial black and gray industries include illegal activities such as improper debt collection, illegal loan mediation, malicious debt evasion, illegal insurance claims, and fraudulent credit repair [2] - These industries are described as a "tumor" hidden within the financial system, posing significant threats to the rights of individuals and financial institutions, as well as to the order and security of the financial market [2] Group 2: New Characteristics and Risks - The rise of AI has introduced new characteristics to financial black and gray industries, including a complete chain of "customer acquisition - traffic generation - implementation - profit sharing" facilitated by online platforms [2] - Illegal stock recommendations utilize new media platforms to attract followers under the guise of financial education, subsequently converting them into "private domain customers" [2] Group 3: Joint Initiative for Governance - A joint initiative was launched to establish a comprehensive prevention and control system involving judicial, regulatory, industry, platform, and public participation to combat financial black and gray industries [3] - The initiative emphasizes the need for information sharing, mechanism improvement, rights protection standardization, and accountability among stakeholders [3] - It also outlines obligations for platforms to verify the qualifications of entities, manage information dissemination, and enhance content review to prevent the spread of black and gray industries online [3]

Core Insights - The "Financial Risk Prevention and Collaborative Governance in the Era of Digital Intelligence" parallel forum was held in Beijing as part of the 2025 Financial Street Forum annual meeting, gathering guests from various sectors including finance, law, technology, and education [1][3]. Group 1: Government Initiatives - The Vice Mayor of Beijing, Sun Shuo, emphasized the importance of the financial industry as a key pillar of Beijing's economy and outlined four key strategies for enhancing financial risk prevention: strengthening regulatory collaboration, legal protection, technological empowerment, and open cooperation [3][4]. - Sun Shuo proposed three work suggestions for building a collaborative governance system in the digital intelligence era: leading with the rule of law, embracing technology, and promoting open and inclusive cooperation [3]. Group 2: Judicial Perspectives - The Chief Prosecutor of Beijing, Zhu Yafeng, highlighted the integration of financial prosecution branding with the implementation of a digital prosecution strategy to enhance the effectiveness of financial prosecution [4][5]. - The Deputy Chief Prosecutor of the Supreme People's Procuratorate, Ge Xiaoyan, noted the importance of high-quality prosecution services in safeguarding financial security in the digital intelligence era [4][5]. Group 3: International Cooperation - Leaders from judicial authorities in Vietnam, Italy, and Singapore discussed the challenges and strategies for preventing financial risks in the digital intelligence era during the forum [5]. - The Deputy Chief Prosecutor of Vietnam's Supreme People's Procuratorate focused on the theme of combating financial crimes and international cooperation [5]. Group 4: Research and Development - A joint initiative to combat financial black and gray industries was released by the Beijing People's Procuratorate, Beijing Financial Regulatory Bureau, and China University of Political Science and Law [7]. - The Beijing People's Procuratorate also published the "Financial Prosecution White Paper (2024-2025)" and showcased typical cases of high-quality prosecution in financial matters [7].

Core Insights - The core viewpoint emphasizes the dual role of artificial intelligence in transforming banking operations while simultaneously introducing new risks and challenges [1][2] Group 1: Risks in Banking - Banks face increasingly diverse risks, with AI-driven risks embedded in technology architecture, differing from traditional IT risks [1] - The effectiveness and safety of AI applications depend on data quality, model design, and algorithm soundness; flaws in any of these can lead to erroneous user profiles or decision-making, resulting in new financial risks [1] - The complexity of risk forms has increased, highlighting the importance of data security and personal information protection, as well as rising legal compliance risks due to cross-border data flow [1] Group 2: Risk Management Strategies - Banks must enhance their risk prevention systems and capabilities, focusing on improving the convenience and safety of financial services while protecting the rights of vulnerable groups [2] - Emphasis on serving the high-quality development of the real economy, supporting modern industrial systems, and promoting rural revitalization and consumer welfare through innovative financial services [2] - Strengthening risk control systems through technology, improving data collection quality, managing models comprehensively, and ensuring cybersecurity to protect customer information [2] - Encouraging optimization and innovation in business processes, establishing risk disposal mechanisms, and creating a collaborative risk prevention community with third-party cooperation [2]

Core Insights - The financial industry is facing new challenges in the digital era, necessitating the evolution of regulatory frameworks to manage risks while fostering innovation [2][3] - Digital technologies are transforming financial services, leading to new types of risks that require a comprehensive approach to risk management [4][5] Regulatory Evolution - Experts emphasize the importance of advancing financial legal frameworks to enhance regulatory management and risk coordination [2][3] - The People's Bank of China highlights the need to address risks such as technology, compliance, and financial stability in the context of digital finance [2] Digital Transformation in Finance - Digital empowerment is increasingly evident in financial institutions, with technologies like AI and big data driving a shift towards intelligent service models [4] - JPMorgan Chase plans to invest $18 billion in technology research this year, demonstrating the impact of sustained technological investment on risk control capabilities [4] Risk Management Strategies - Experts propose a multi-faceted approach to tackle emerging risks, focusing on technology as a core support for risk control upgrades [4][5] - Recommendations include strengthening AI technology frameworks, improving data quality, and ensuring cybersecurity to protect financial systems and customer information [4][5] Compliance and Legal Frameworks - The establishment of a robust compliance and legal framework is deemed essential for effective risk prevention, with suggestions for revising laws to clarify AI applications in finance [5] - Financial institutions are encouraged to integrate compliance throughout their operations and maintain ongoing communication with regulatory bodies to adapt to evolving requirements [5]

Core Viewpoint - The "14th Five-Year Plan" emphasizes the construction of a strong financial nation, focusing on serving the real economy, deepening reform and innovation, and preventing financial risks [1] Group 1: Development of Financial Sectors - The plan highlights the development of five key areas: technology finance, green finance, inclusive finance, pension finance, and digital finance [2] - In technology finance, banks and securities firms are encouraged to support innovative enterprises through loans and equity investments [2] - Green finance aims to align standards with international practices and explore carbon financial derivatives, supporting industries like energy storage and hydrogen [2] - Pension finance focuses on building personal pension product offerings and encouraging the development of long-term, stable pension products [2] - Inclusive finance should leverage digital transformation to create online financial products for small and micro enterprises and rural areas [2] - Digital finance requires financial institutions to invest in digital infrastructure and enhance service efficiency and risk control through technology [2] Group 2: Optimization of Financial Institutions - The plan calls for optimizing the financial institution system, encouraging institutions to focus on their core businesses and improve governance [3] - The financial system has developed into a comprehensive support service structure, with banks as the main service providers [3] - Large banks are expected to transition towards comprehensive and international development, while small and medium banks will focus on niche markets [3] - Non-bank financial institutions will play a more significant role in asset and wealth management [3] - Regulatory authorities will guide institutions to find their positioning and promote differentiated competition [3][4] Group 3: Strengthening Financial Regulation - The plan emphasizes the need for comprehensive financial regulation, enhancing collaboration between central and local regulators [5] - A robust risk prevention and resolution system is to be established to ensure financial stability [5] - Financial institutions are advised to strengthen risk management frameworks and utilize digital tools for comprehensive risk control [6] - There is a focus on improving compliance management and ensuring adherence to regulatory requirements [6]

Core Insights - The forum emphasized the need for regulatory bodies to adapt to the digital era while managing risks and fostering financial innovation [1][2] - Digitalization is transforming financial services, necessitating a robust legal framework and collaborative governance to address new risks [1][3] Regulatory Adaptation - Financial institutions face new challenges in the digital age, including technology risk, compliance risk, and financial stability risk [1] - Strengthening the legal framework and enhancing regulatory awareness are crucial for effective risk management [1][2] Digital Empowerment - The effectiveness of digitalization in financial institutions is becoming evident, with technologies like AI and big data driving a shift towards intelligent service models [2][3] - Financial institutions are increasingly integrating AI in core operations, enhancing customer identification, loan assessment, and fraud prevention [2][3] Investment in Technology - JPMorgan Chase plans to invest $18 billion in technology research this year, with over 500 AI applications already implemented, showcasing the impact of continuous tech investment on risk management capabilities [3] - Experts highlighted the need for a solid AI technology framework and improved data quality to bolster risk control [3] Compliance and Legal Framework - A robust compliance and legal framework is essential for risk prevention, with suggestions to revise laws governing AI applications in finance [3] - Financial institutions should integrate compliance throughout their operations and establish ongoing communication with regulatory bodies to adapt to evolving requirements [3]