出品 | 妙投APP 作者 | 董必政 编辑 | 关雪菁 头图 | AI制图 这是一片助贷的灰色地带。 那些网贷平台上标着"年化利率5.4%起"的贷款产品，很可能是包装出来的"高利贷"。 不少用户冲着利率低点进去，可当真正贷款时，平台会强制绑定各种会员费、担保费、服务费堆上去，算下来实际年化可能高达30%以上。 你很可能不知道的是：法律对年化利率24% 以内的贷款予以明确保护，而超过36%的部分则被认定为无效，而24%~36%的贷款由双方协商。 而不少网贷平台，玩的，就是这片灰色地带。 众多消费金融公司和助贷机构利用复杂的费用结构掩盖高利率的真相，让消费者在不知不觉中踏入债务陷阱。 最近，监管终于对此出手了。 2025年4月3日发布的《关于加强商业银行互联网助贷业务管理提升金融服务质效的通知》（以下简称"助贷新规"），明确综合融资成本区间。 也就是说，以后所有收费都必须算进综合年化利率里，不能超过司法保护上限24%。 助贷新规从2025年10月1日起开始执行，给了消金公司、助贷平台、提供资金的商业银行等近6个月过渡期。 这次，24%~36%的高利贷真的会消声灭迹吗？ # 01 一、行业出清的信号 众怒，是推行 ...

Core Viewpoint - The "New Lending Regulations" have impacted the performance and strategies of leading lending institutions, with each showing distinct growth trajectories and challenges. Group 1: Company Performance - Xinyi Technology reported a net income of 3.578 billion RMB for Q2, a year-on-year increase of 12.94%, and a net profit of 751 million RMB, up 36.35% [1] - Q2 loan facilitation service fees contributed significantly to revenue growth, reaching 1.515 billion RMB, a 36.45% increase year-on-year, driven by expanded transaction volume and higher average service fees [1] - Q2 loan balance for Xinyi Technology was 77.5 billion RMB, a year-on-year growth of 18.1%, with domestic loans at 75.4 billion RMB (up 17.4%) and overseas loans at 2.1 billion RMB (up 50.0%) [1][3] - Q2 revenue for Qifu Technology was 5.216 billion RMB, a 25.38% increase year-on-year, with a net profit of 1.731 billion RMB, up 25.72% [2] - Qifu Technology's total loan facilitation and issuance reached 84.609 billion RMB, a 16.1% increase year-on-year [6] - Lexin's total revenue for Q2 was 3.587 billion RMB, down 1.5% year-on-year, while net profit increased by 126% to 511 million RMB [2][4] Group 2: Market Trends and Strategies - The "New Lending Regulations" have led to tighter funding supplies and increased costs for lending institutions, prompting Lexin to adjust its business model by shifting from light capital to heavy capital modes [7][8] - Lexin's light capital model accounted for 20% of GMV in Q2, down from 27% in Q1, while heavy capital mode increased from 73% to 80% [7] - Qifu Technology's user base grew significantly, with over 60 million borrowers, a 12.3% increase year-on-year, and a high repeat borrowing rate of 93.8% [2] - Xinyi Technology's international business revenue reached 796.7 million RMB in Q2, a 41.5% increase year-on-year, representing 22.3% of total revenue [2][3] Group 3: Risk Management - Lexin's non-performing loan rate was the highest among the three companies at 3.1% [5] - Both Lexin and Qifu Technology have increased their provisions to enhance risk buffers, with Lexin raising provisions by 13.6% to 1.04 billion RMB, achieving a coverage ratio of 270% [9] - Qifu Technology's provision coverage ratio reached a historical high of 662% [9]

Core Viewpoint - The implementation of the new regulations on internet lending by the National Financial Regulatory Administration is causing a significant shift in the lending landscape, with banks and consumer finance companies reallocating resources towards compliant platforms while trust and commercial insurance funds are stepping in to fill the funding gaps left by traditional lenders [2][4][6]. Group 1: Regulatory Impact - The new regulations require banks to clearly define service fees and comprehensive financing costs in their agreements with lending platforms, directly addressing the high-cost lending issues in the industry [4][5]. - The regulations have led to a clear segmentation in the lending market, with high-interest lending platforms facing rejection from banks and consumer finance companies, while those with lower rates are experiencing intense competition [6][7]. Group 2: Funding Sources - Trust funds, previously sidelined due to cost disadvantages, are becoming increasingly active in the consumer finance market as traditional funding sources tighten [9][10]. - Trust companies are focusing on high-quality asset packages, particularly those associated with leading lending platforms, as they seek to mitigate risks while capitalizing on competitive returns [11][12]. Group 3: Alternative Financing Channels - In addition to trust funds, commercial factoring and financing leasing companies are being considered as alternative funding sources, although their capacity to fill the gaps is limited due to regulatory constraints [14][15]. - The regulatory environment is tightening around commercial factoring and financing leasing, which may further restrict their ability to engage in consumer lending activities [16][17].

今年10月1日，国家金融监管总局发布的《关于加强商业银行互联网助贷业务管理提升金融服 务质效的通知》将正式实施。这份被业内称为"助贷新规"的政策激起的涟漪，正在金融生态链 中悄然扩散。 21世纪经济报道记者调查发现，在距离新规正式实施不足2个月的当前，一场助贷行业的资金 迁徙正在悄然进行： 在监管明确要求控制综合融资成本、严管收费行为并推行名单制管理的 背景下，银行与消费金融公司正优化布局，将资源向头部合规平台倾斜；在助贷行业资金面临 收缩的背景下，信托、商业保理等资金提供方，正在成为填补助贷机构资金缺口的重要选项。 首先，最直接的冲击落在了高息资产端。 年化综合成本达36%的助贷机构几乎全部被银行、 消费金融机构拒之门外。 一位华北地区城商行零售业务负责人对21世纪经济报道记者坦 言："这类资产信用风险与监管压力双高，基本不做考虑。" 但年化利率24%以上资产的资金供给目前并未消失，但成本出现明显抬升。华南某助贷公司从 业人士对记者透露： "很多24%以上的资金还没完全撤出，但银行，尤其是中小银行、民营银 行资金端停止供给，让助贷机构不得不转向其他资金渠道，市场价格比去年涨了2—3个百分 点，部分甚至高出5 ...

距离"助贷新规"全面实施还有不到50天的时间。 新规要求，商业银行应当在合作协议中明确平台服务、增信服务的费用标准或区间，将增信服务费计入借款人综合融资成本，明确综合融资成本区间。 这一规定实质上将助贷服务的年化利率上限锁定在24%以内，也意味着传统"双融担"模式将退出历史舞台。 为迎合新规要求，有的机构开始转向"24%+权益"，有的则转向"24%+公证"。还有一些机构，尚未做出符合新规的实质性改变。 这其中，笔者注意到，成立十年的知名腰部助贷机构，且在航旅金融场景下占据龙头地位的信用飞，依然执行年化利率36%的上限标准，而如果开通会员， 用户的综合借贷成本远超36%。 这样的高利率也让其在饱受用户投诉。 01 测试综合借贷成本35.99%，利率仅占5.5% "我2025年在信用飞平台借款，综合利率达到35.99%，属于高利贷，我现要求退还超过国家利率部分，并调整利率至合法范围。" "信用飞平台收取高额担保费，和不合理不合规的高额利息，利率达到36%，早已超出正常合法利率，诉求退还我全部结清的担保费和高额利息，维护我作 为消费者的合法权益！" …… 在黑猫投诉上，针对信用飞高额利率的投诉比比皆是。那么，这些投 ...

Core Viewpoint - Beijing's financial regulatory authority has issued a notice to strengthen the management of assistive lending businesses, signaling a crackdown on the "membership rights" model that obscures borrowing costs [1][2][5] Group 1: Regulatory Changes - The notice requires clear agreements on comprehensive financing cost ranges between platform operators and credit enhancement service providers, ensuring compliance with the Supreme Court's regulations on maximum loan costs [2][6] - The regulatory focus is on eliminating the use of "membership rights" and "value-added rights" to indirectly increase financing costs, which has been a common practice among many consumer finance companies and assistive lending platforms [2][4] Group 2: Industry Impact - The "membership rights" model has been criticized for becoming a means to hide hidden fees in online loans, leading to numerous consumer complaints regarding forced payments and lack of transparency [4][5] - The implementation of the new regulations may lead to a consolidation of the assistive lending market, with smaller institutions potentially being eliminated due to their inability to adapt to the new compliance requirements [6][7] Group 3: Future Outlook - The regulatory framework aims for complete transparency and compliance in financing costs, which may limit the operational space for assistive lending platforms that cannot meet the 24% interest rate cap [6][7] - The new regulations are seen as a starting point for balancing compliance and profitability in the assistive lending industry, rather than a turning point [7]

Core Viewpoint - The traditional "dual financing guarantee" model is being phased out as the "new lending regulations" come into full effect, leading to a significant reshaping of the lending industry [1][2] Group 1: New Lending Regulations - The new regulations set a cap on annualized interest rates for lending services at 24%, effectively rendering the previous "dual financing guarantee" model ineffective [2][8] - The regulations will be implemented on October 1, and the transition to compliance has been challenging for many institutions [2][8] Group 2: Shift to New Models - Many small and medium-sized institutions are transitioning to a "24% + notarization" model, particularly in the equipment rental sector [1][2] - Some rental platforms are bundling additional fees such as notarization and insurance, which increases the actual cost for users [3][4] Group 3: Notarization Practices - The notarization fees are often used for "strong notarization," which allows creditors to bypass lengthy litigation processes, thus improving recovery rates [3][5] - A new "composite notarization" model is being explored, which includes measures like deposit guarantees and evidence chain notarization to balance costs [4][6] Group 4: Challenges in Implementation - The industry faces challenges such as the judicial system's capacity to handle small, high-frequency cases and rising customer complaints regarding hidden fees [7][8] - The sustainability of the new business models is questioned, as institutions may need to forgo previous profit margins of 24%-36% to comply with the new regulations [8][9] Group 5: Industry Transformation - The industry is undergoing a critical transition from tentative adjustments to substantial changes, with many institutions initially attempting to repackage existing high-rate products as compliant [8][9] - The current asset scale of products with interest rates above 36% still exceeds 50%, indicating potential systemic risks if abrupt changes are made [9]

Core Viewpoint - The traditional "dual financing guarantee" model in the lending industry is being phased out due to the upcoming implementation of the "assisted lending regulations," leading to a significant reshaping of the industry as companies explore new compliance strategies to avoid regulatory pitfalls [1][2]. Group 1: Regulatory Changes - The "assisted lending regulations" set a cap on annualized interest rates at 24%, effectively rendering the previous "dual financing guarantee" model obsolete [2]. - The regulations require clear disclosure of service and guarantee fees in cooperation agreements, impacting the overall financing cost for borrowers [2]. Group 2: New Business Models - Companies are shifting towards a "24% + notarization" model, particularly in the equipment rental and auto loan sectors, as a way to navigate the regulatory landscape [1][2]. - Some rental platforms are bundling additional fees such as notarization and insurance, which increases the actual cost for users [1][3]. Group 3: Challenges in Implementation - The new notarization models face three main challenges: the judicial system's capacity to handle small, high-frequency cases, rising consumer complaints about hidden fees, and insufficient motivation for institutions to adapt under profit pressure [1][7]. - The effectiveness of "strong notarization" is being questioned, leading to the exploration of a "composite notarization" model that balances costs and risks [4][5]. Group 4: Consumer Experiences - Consumers have reported being charged additional fees on rental platforms, significantly increasing their overall costs, with one individual noting an extra cost of approximately 5,317 yuan for a rental transaction [3]. - Complaints about hidden fees are rising, with some platforms charging between 200 to 500 yuan for notarization fees [3][7]. Group 5: Industry Outlook - The industry is undergoing a critical transition from exploratory adjustments to substantial changes, with many small institutions initially attempting to repackage existing high-rate products as compliant offerings [8][9]. - The current asset scale of products with interest rates above 36% still exceeds 50%, indicating potential systemic risks if abrupt regulatory changes are enforced [9].

Core Viewpoint - The "24%+ equity" model in the lending industry is facing significant challenges as regulatory scrutiny increases, potentially leading to stricter regulations on equity services and fees [1][27]. Group 1: Overview of the "24%+ Equity" Model - The "24%+ equity" model allows borrowers to obtain consumer loans at an annual interest rate of 24% while also purchasing equity services from lending platforms or licensed consumer finance institutions [3][13]. - This model has become popular as lending institutions seek to increase non-interest income through equity services amid difficulties in earning interest spread [1][27]. Group 2: Regulatory Concerns and Industry Response - Recent regulatory notifications have prompted concerns among lending platforms and licensed consumer finance institutions about the sustainability of the "24%+ equity" model [5][6]. - The introduction of the "New Lending Regulations" in April has restricted platforms from charging interest fees in any form, raising fears that equity service fees may be viewed as disguised interest rate increases [7][11]. - Many lending institutions are preparing to exit the "24%+ equity" model, focusing instead on high-quality customer segments with interest rates below 24% [8][28]. Group 3: Financial Implications and Market Dynamics - The "24%+ equity" model has allowed some lending platforms to generate substantial revenue, with some platforms collecting hundreds of thousands of yuan in equity fees monthly [17]. - However, the model has also led to issues such as bundled sales and forced purchases, which have raised consumer complaints and could lead to increased regulatory scrutiny [19][20]. - The potential for regulatory changes has caused many lending institutions to reconsider their business strategies, with some halting plans to expand the "24%+ equity" model [25][26]. Group 4: Future Outlook - The future of the "24%+ equity" model remains uncertain, with industry players awaiting regulatory decisions that could significantly impact their operations [28]. - If the model is deemed unsustainable, lending platforms may need to adjust their focus to maintain profitability, potentially leading to a reduction in overall business scale [28][29].

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].