22 May 2017
FinTech credit
Market structure, business models and financial stability implications
Report prepared by a Working Group established by the
Committee on the Global Financial System (CGFS) and the Financial Stability Board (FSB)
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ISBN 978-92-9259-051-2 (online)
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Preface
FinTech credit – that is, credit activity facilitated by electronic platforms such as peer-to-peer
lenders – has generated significant interest in financial markets, among policymakers and from
the broader public. Yet there is significant uncertainty as to how FinTech credit markets will
develop and how they will affect the nature of credit provision and the traditional banking
sector.
Against this background, a group of representatives from the membership of the Committee on
the Global Financial System (CGFS) and the Financial Stability Board (FSB) Financial
Innovation Network, together with the Secretariats of the CGFS and FSB, undertook this study
of FinTech credit. The study draws on public sources and ongoing work in member institutions
to analyse the functioning of FinTech credit markets, including the size, growth and nature of
activities. It also assesses the potential microfinancial benefits and risks of these activities, and
considers the possible implications for financial stability in the event that FinTech credit should
grow to account for a significant share of overall credit. Conduct and prudential regulatory
policies in selected countries are also outlined.
This report provides several key messages. The nature of FinTech credit activity varies
significantly across and within countries due to heterogeneity in the business models of FinTech
credit platforms. Although FinTech credit markets have expanded at a fast pace over recent
years, they currently remain small in size relative to credit extended by traditional
intermediaries. A bigger share of FinTech-facilitated credit in the financial system could have
both financial stability benefits and risks in the future, including access to alternative funding
sources in the economy and efficiency pressures on incumbent banks, but also the potential for
weaker lending standards and more procyclical credit provision in the economy. These
considerations are explained in more detail in the report.
The emergence of FinTech credit markets poses challenges for policymakers in monitoring and
regulating such activity. Having good-quality data will be key as these markets develop. We
hope that the information and analysis contained in this report will assist policymakers with
their efforts.
William C Dudley
Chair, Committee on the Global Financial System
President, Federal Reserve Bank of New York
Klaas Knot
Chair, FSB Standing Committee on Assessment of Vulnerabilities
President, De Nederlandsche Bank
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Table of contents Page
Executive Summary ... 1
1. Introduction .... 2
2. Factors influencing the development of FinTech credit ......... 3
2.1 Drivers3
2.1.1 Supply factors . 3
2.1.2 Demand factors .......... 4
2.2 Other factors affecting growth potential ........ 5
3. Size and structure of FinTech credit markets . 6
4. Description of FinTech credit activity ......... 10
4.1 FinTech credit platforms ...... 11
4.1.1 Traditional P2P lending model ......... 11
4.1.2 Notary model13
4.1.3 Guaranteed return model ...... 14
4.1.4 Balance sheet model . 15
4.1.5 Invoice trading model ........... 16
4.2 Lenders ......... 17
4.3 Borrowers ..... 20
5. Micro assessment of FinTech credit activity21
5.1 Pricing .......... 21
5.2 User convenience ..... 23
5.3 Accessibility . 24
5.4 Potential vulnerabilities of FinTech lending activity ........... 25
(a) Leverage and liquidity risk ....... 25
(b) Operational risks .......... 26
(c) Quality of credit risk assessments ........ 26
(d) Business model incentives ....... 26
(e) Reliance on investor confidence for new business ....... 27
(f)Low barriers to entry .... 27
(g)Platform profitability risks ....... 29
6. Financial stability implications of FinTech credit .... 30
6.1 Greater share of FinTech credit ........ 30
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6.2 Securitisation32
6.3 Potential response by incumbent banks ....... 33
7. Financial regulatory architecture for FinTech credit35
7.1 Rationale for the regulation of FinTech credit markets ....... 35
7.2 Regulation of FinTech credit within existing frameworks ... 36
7.3 Examples of regulation dedicated to FinTech credit36
7.4 Policy changes to promote FinTech credit ... 38
Box A: Data sources used in the report..11
Box B: Scandals at FinTech platforms...28
Box C: Interactions between banks and FinTech platforms…...34
Box D: China’s regulatory framework for internet finance……38
References ........ 41
Members of the Working Group .......... 43
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