At present, the governance of campus loans has achieved phased results. Whether some traditional banks return to the campus market to meet the normal loan needs of college students or most online lending platforms suspend campus loan business, it shows that the governance effect is remarkable. However, judging from the media disclosure, there are two phenomena that need to be paid great attention to: First, after the three ministries and commissions informed that "all online lending institutions suspend campus loan business at this stage", there are still online lending platforms that can lend to college students, that is, they have not complied with the "suspension order". Second, some online lending platforms are very smart, transforming campus cash loans into e-commerce shopping and installment repayment business.
On the surface, these online lending platforms are not directly engaged in campus loans, but in essence, because many college students borrow money for shopping; Judging from the high late payment fee, there is no substantial difference from the previous campus loan. The reason why these platforms keep appearing campus loans with a new look is not only to avoid the ban of national ministries and commissions, but also because campus loan business is profiteering.
Campus loan has not been completely banned. Although it is related to the Notice on Further Strengthening the Standardized Management of Campus Loan issued by the three ministries at the end of May this year, it is still in the implementation stage, but the main reason is that the governance measures are not perfect. For example, for online lending platforms that still illegally lend to college students, there must be both perfect supervision measures and strict punishment measures. However, there is no corresponding arrangement in this notice. It seems to be strict, but it is actually a paper tiger, so some online lending platforms do not pay attention to it.
For another example, this notice also lacks preventive arrangements for the transformation of campus loans into e-commerce shopping and installment repayment, and some online lending platforms exploit policy loopholes. From the common sense, because campus loans are a kind of "profiteering loans", online lending platforms will not give up this "fat meat" easily, either directly committing crimes against the wind and taking risks to make profits, or operating in disguise in an attempt to evade supervision. Only when strict measures such as prevention, supervision and punishment are formulated and strictly implemented can it be expected to form an effective binding force.
We cannot expect the online lending platform to consciously implement the "campus loan suspension order", but rely on strict regulatory measures to enforce it. In other words, the continued existence of campus loans is also a test of regulatory wisdom:
First, test the wisdom of supervision. Whether strict orders can be implemented depends on supervision, that is, whether regulators can find violations and then severely punish them. In order to find violations, regulators should not only make unannounced visits to collect evidence like journalists, but also encourage college students and insiders to report.
Second, test the wisdom of punishment. Any decree or prohibition, if there are no supporting punishment measures, will lack actual binding force and will easily become waste paper. "At this stage, all online lending institutions will be suspended from carrying out campus loan business" is no exception. Judging from the relevant notices, there is also a lack of punitive provisions. So, how to punish such illegal institutions? Not only can unqualified online lending platforms be directly punished, but also a "blacklist" system can be established to include illegal online lending platforms in the "blacklist".
Third, test the wisdom of prevention. The reason why campus loans are changed to installment shopping lies in the lack of preventive measures. Without preventive measures, campus loans will continue to change. In order to prevent the campus loan from changing its face, on the one hand, it is necessary to start from the supply side and prohibit the campus loan on the online lending platform from appearing in other forms; On the other hand, from the demand side, education guides college students to reject all kinds of temptations of online lending platforms. The above notice has actually been deployed, and I hope to implement it as soon as possible.
Supervision must be in place, do more publicity, and let students distinguish the essence of campus loans.