，而银行理财产品的承诺收益率往往要高于银行存款利率，二者之间存在较高的利差，即便理财产品预期收益率有所下滑，但其回报率依然高于同期限存款利率，从而导致银行理财产品备受投资者追捧。 With the increase of the income level of residents, residents' willingness to maintain and increase their assets continues to increase. Due to the low deposit interest rate in China, the benchmark interest rate on three-year time deposits is 1.3% , and the promised return rate of bank wealth management products is often higher than that of banks. There is a high interest rate difference between the two deposit rates. Even if the expected return on wealth management products has fallen, the return rate is still higher than the deposit interest rate of the same term, which has led to the popularity of bank wealth management products by investors. 年底，我国银行理财账面余额为29.1万亿元，同比增长23.8% ，自2012年以来，银行理财产品规模已增长4倍多，年均增速达42.8% ，其在资管行业中的地位愈发重要。 Due to strong demand and continuous innovation of banks' wealth management product business, the scale of China's banking wealth management products has continued to increase. As of the end of 2016 , China's banking wealth management book balance was 29.1 trillion yuan, a year-on-year increase of 23.8% . Since 2012 , bank wealth management The size of the product has increased more than 4 times, with an average annual growth rate of 42.8% , and its position in the asset management industry is becoming increasingly important. Bank wealth management products have played an important role in promoting the transformation and upgrading of banking business and meeting the investment and financing needs of residents and enterprises. However, while the rapid development of bank wealth management business has also exposed many problems, bank wealth management has deviated from its original asset management essence. , Gradually transformed into "off-balance sheet deposits and loans", and risks continue to accumulate in the system.
I. Status analysis of bank wealth management products
年6月末，无论是发行规模还是发行数量，我国银行理财产品均以非保本浮动收益类产品为主，占理财产品资金余额的比例为76.79% ，发行数量占总产品的72.3% ；保本浮动收益类产品占资金余额和发行数量的比例分别为14.69%和11.23% ；保证收益类产品占比分别为8.52%和16.47% 。 From the perspective of income types, as of the end of June 2016 , regardless of the issue scale or the number of issuances, China's banking wealth management products are mainly non-capital-guaranteed floating income products, accounting for 76.79% of the balance of wealth management products, and the number of issuances accounts for the total products 72.3% of the total ; principal-guaranteed floating income products accounted for 14.69% and 11.23% of the balance of funds and issuances; guaranteed income products accounted for 8.52% and 16.47%, respectively . 年6月末的预期年化收益率可达3.92% ，分别高出保证收益类产品和保本浮动收益产品0.53个百分点和0.77个百分点。 Generally speaking, the risk level of non-capital-guaranteed floating income products is relatively high, which corresponds to a high expected annualized return rate. The expected annualized return rate at the end of June 2016 can reach 3.92% , which is higher than the guaranteed income product. And the principal and guaranteed floating income products were 0.53 percentage points and 0.77 percentage points.
（利率债占6.92% ，信用债占28.96% ），而信用债的投资主要以高信用评级的债券资产为主体，风险相对较低，其中投资于AAA债券的资金占信用债资金的55.7% ，投资于AA+债券的资金占信用债资金的25% ；现金及银行存款占17.74% ；非标准化债权类资产占16.54% ，其中收/受益权、信托贷款、委托贷款和非标准化债权类投资为主要投资品种，分别占到非标准化债权投资的33.18% 、 16.45% 、 13.88%和15.77% 。 From the perspective of investment channels of wealth management products, bank wealth management products are mainly invested in bonds and money market instruments that are permitted by regulation and are relatively standardized. Bond investment accounts for 40.42% of investment in wealth management products (interest rate bonds account for 6.92% , credit bonds account for 28.96% ) The investment of credit bonds is mainly based on high-rated credit bond assets with relatively low risk. The funds invested in AAA bonds account for 55.7% of the credit bond funds, and the funds invested in AA + bonds account for 25% of the credit bond funds. ; Cash and bank deposits account for 17.74% ; non-standardized debt assets account for 16.54% , of which the main types of investment are collection / benefit rights, trust loans, entrusted loans and non-standardized debt investments, which respectively account for 33.18% of non-standardized debt investment , 16.45% , 13.88% and 15.77% .
和56.82% 。 From the risk level of wealth management products, since wealth management products are mainly invested in standardized assets, bank deposits and government bonds have the lowest risk level due to bank credit and national credit guarantees, while funds invested in the interbank lending market and bond market The market's risk is low, and the professional and decentralized investment of the fund company further reduces the risk. Therefore, the risk of wealth management products is relatively low. The low-risk level financial products and the low-risk level financial products account for the total funds raised. 25.85 and 56.82% .
However, not all banks' financial products have the same level of risk. Different types of banks have different investment levels due to different risk appetites, and thus have different levels of risk. Among them, state-owned banks prefer low-risk currency market tools, and urban business. Banks and rural commercial banks often prefer bond-based products in order to pursue higher returns, while joint-stock commercial banks have a larger number of non-standard debt products than other types of banks.
Hidden risks of bank wealth management products
The essence of bank wealth management should be "trusted by the client and managing wealth on behalf of the client". The investment management fee is collected through a pre-agreed method. The manager does not need to bear liquidity risk and credit risk. The source and application of asset management products are clear and non-existent. "Fund pool" problem, and China's wealth management products agree with investors on the rate of return, the rest of the arbitrage space (excess reserve) belongs to the bank, there are hidden concerns about rigid redemption, and some wealth management products also use the "fund pool" operating model The form of management is the same as the on-balance-sheet loan business. China's bank wealth management business has been distorted and deviates from the nature of bank wealth management. Part of the wealth management business has significant risks. If the risks are not effectively controlled, it will lead to systemic financial risks.
(1) Mismatch in maturity of wealth management products of banks is likely to cause liquidity risks
个月至3个月，一般不超过1年，待理财产品期满后再发放新的理财产品，以滚动的形式来保持资金的流动性，容易产生“资金池”的运作模式，资金池的模式具有滚动发售、集合运作、期限错配、分离定价的特点，通过将滚动发售的理财产品的资金汇集，统一配置到各类资产上来完成理财产品的投资。 In order to match longer-term loans, bank wealth management products usually issue short-term products first. Common wealth management products have a term of 1 to 3 months and generally do not exceed 1 year. New products will be issued after the expiration of the wealth management product. Wealth management products, in a rolling form, maintain liquidity of funds and easily generate a "fund pool" operation mode. The fund pool model has the characteristics of rolling sale, collective operation, term mismatch, and separate pricing. The funds of wealth management products are pooled and allocated to various assets in a unified manner to complete the investment of wealth management products. However, once the liquidity of the market is tight, especially when some wealth management products are due to issue new wealth management products, it is easy to cause insufficient funds, and then the problem of maturity mismatch of wealth management products will be magnified, which will cause market liquidity risks.
(II) Implicit guarantees in bank wealth management products
银行-信托-客户的流程，以中介人的身份将风险转移至投资者和金融中介，如果银行无法兑现理财产品而出现流动性资金短缺，则投资者将面临损失，虽然市场上大部分理财产品为非保本产品，银行不承担任何资金损失的风险，但会造成投资者对银行声誉的丧失，银行将失去部分客户，而银行声誉的丧失在一定时间内很难恢复，也会给银行经营带来很大压力，因此银行对理财产品会施行隐性担保，即使面临亏损也可能借用其他资金弥补亏损缺口。 Some banks use cooperation with financial intermediaries to operate wealth management products. For example, through the process of wealth management products - bank - trust - customers, the risk is transferred to investors and financial intermediaries as intermediaries. If the bank fails to cash out the wealth management products, it appears If there is a shortage of liquid funds, investors will face losses. Although most wealth management products in the market are non-capital-protected products, banks do not bear any risk of capital losses, but it will cause investors to lose their reputation with the bank, and the bank will lose some customers. The loss of the bank's reputation is difficult to recover within a certain period of time, and it will also bring a lot of pressure to the bank's operations. Therefore, banks will implement implicit guarantees on wealth management products. Even if they face losses, they may borrow other funds to make up for the loss gap. The existence of such rigid redemption will distort market behavior and reduce the efficiency of resource allocation. At the same time, it will also promote the overall risk-free rate of return to a certain extent, exacerbating the disconnection between finance and the real economy, and difficulties in financing and expensive financing for SMEs. In addition, banks "issue new payments to repay old ones" to ensure the rigid payment of maturity products also easily lead to the development of bank wealth management products in the direction of "Pang-type scams."
(3) Underestimation of risks in bank wealth management products
Although the regulatory authorities do not allow bank credit to invest in real estate, local financing platforms, and “two highs and one surplus” in macroeconomic regulation and control, with the continuous innovation of financial products, bank-trust cooperation and bank-securities cooperation can still be bypassed. Supervision. ，同时不能超过银行总资产的4%来限制非标总量的规模，但仍有部分银行通过非标资产转化为标准债券的形式来规避监管。 Even if the CBRC restricts the scale of non-standard total assets by stipulating that wealth management funds should be invested in non-standard assets not exceeding 35% of the total wealth management, and not more than 4% of the bank's total assets, there are still some banks that convert non-standard assets into standard bonds. Form to circumvent regulation. This part of the wealth management fund lacks reasonable capital buffer funds, and its risk control ability is relatively weak, which easily leads to an underestimation of the risk of the banking system.
(IV) Rising credit risk for bank wealth management products
On the one hand, wealth management funds are mainly invested in bond-type products, which are mainly credit bonds. The repayment ability of credit bonds is mainly related to the operating status of the operating entity. Compared with interest rate bonds, credit bonds have greater credit risk. On the other hand, some wealth management products are also invested in high-risk areas such as real estate, local financing platforms, and "two highs and one surplus" through non-standard assets. Due to stricter control of real estate in China, local government financing platforms and "two highs and one surplus" In other areas, the investment period is long and the return on capital is low, so non-standard assets also face the problem of excessive credit risk. Especially under the circumstances that China's economic downward pressure is still large, corporate economic benefits are not high, and monetary policy has changed from "stable and loose" to "stable and neutral", the number of bond defaults has increased, which has led to the credit of bank wealth management products. Increased risk.
(5) The problem of “deconsolidation to deception” of wealth management products has intensified
年底的67.09%下降至2016年6月末的60.74% ，很有可能在一系列加杠杆的金融运作后，变成“钱生钱”、“内部循环”的虚拟游戏，如部分银行理财资金投向债券市场时为了获取更高的收益会采取“加杠杆”的方式，资金在各个金融机构间循环往复获利，无形中提高了实体经济的融资成本，而且由于资金链过长以及“加杠杆”行为的存在将进一步放大金融风险。 With the continuous expansion of the scale of wealth management products, the proportion of wealth management funds entering the real economy has declined, from 67.09% at the end of 2015 to 60.74% at the end of June 2016. It is likely that it will change after a series of leveraged financial operations. A virtual game of "money-generating money" and "internal circulation". For example, when some bank wealth management funds are invested in the bond market, in order to obtain higher returns, they will adopt a "leveraged" method. The financing cost of the real economy is virtually increased, and financial risks will be further magnified due to the length of the capital chain and the existence of "plus leverage" behavior.
(VI) Lack of uniform standards for risk assessment of wealth management products
Although the CBRC stipulated in the "Measures for the Administration of the Sales of Financial Products of Commercial Banks", the results of the risk rating of financial products should be reflected in the risk level, including at least five levels from low to high, and can be further subdivided according to actual conditions. However, the current risk ratings of bank wealth management products are internally assessed by various banks, and the method of assessing risk levels has not yet been made public. The industry lacks a unified evaluation standard. Because each bank has different evaluation standards for risks, it has caused the same type. The risk rating of different wealth management products in different banks is different, and it causes customers to increase the actual risks when purchasing wealth management products.
Reasons for Banking Financial Risks
(I) Inadequate risk assessment of customers
The customer risk assessment is too formal, and the customer's financial status is not strictly evaluated based on the customer's risk appetite, risk awareness and tolerance. Even if the customer's risk assessment is low and he cannot purchase high-risk products, he can re-evaluate until the customer Meeting the requirements for purchasing high-risk wealth management products, which often leads to the sale of high-risk products to risk-averse customers, leading to mismatches between wealth management product risks and investor risk tolerance, which violates the "sale of appropriate products to appropriate The principle of "customer" does not meet the requirements of "responsible sellers" of the regulatory authorities.
(II) Improper sales behavior
In the face of the fiercely competitive banking wealth management product market, in order to pursue benefits and complete annual assessment indicators, bank sales staff often overstate the benefits of related wealth management products, deliberately ignoring the product's investment direction, investment ratio, risk-reward realization form, and early redemption mechanism. And other risk warnings, thereby misleading investors. Because customers' risk awareness is not high, bank wealth management products are generally regarded as deposit products with higher interest rates, and expected yields are considered as determined yields. This leads to the fact that the wealth management products purchased by investors are not really zero-risk, high-yield bank wealth management products, but rather private debt with a higher risk level. When the product expires and cannot fulfill the promised income, it will increase the bank's commercial dispute .
(3) Insufficient information disclosure
Some wealth management products only have information disclosure at the time of establishment and expiration, lack of information disclosure in operation, and lack of follow-up research and analysis. For example, the information disclosure of some bank wealth management products only includes simple investment types and approximate proportions, lack of information on portfolio changes, income, expenses, and asset valuations, and risk assessment and review of borrowers' credit status and solvency analysis. Did not do well. This inadequate information disclosure also reflects the formalization and simplification of the bank's post-investment management, the existence of unfulfilled funding conditions, inadequate monitoring of capital flows, the risk assessment of borrowers and projects, and the failure to guarantee legal and timely repayment sources Adequate value, insufficient sensitivity to policy risks and market risks, etc.
(4) Insufficient coordination and supervision of various departments
Due to the large number of institutions involved in banking wealth management products, not only banking financial institutions, but also non-bank financial institutions such as securities, trusts, and funds. There is a large amount of cross-exchange between businesses. When banking financial institutions are subject to stricter supervision It will promote further innovation of financial products through new channels such as non-bank financial institutions to bypass the original regulatory rules to meet the purpose of investment and financing. 年间银监会连续发布10篇公文以加强银信合作的监管，而其他部门在2012年的券商创新大会上却对相关行业的管制放松，使券商资管、基金子公司、期货公司资管等均被允许当通道使用，这就造成了新的理财产品可以绕过银监会的监管，导致银监会之前发布的监管成为一纸空文。 For example, during the period of 2008-2011 , the CBRC successively issued 10 official documents to strengthen the supervision of bank-trust cooperation, while other departments relaxed the control of related industries at the 2012 Securities Dealer Innovation Conference, enabling brokerage asset management, fund subsidiaries, and futures companies. Asset management is allowed to be used as a channel, which has caused new wealth management products to bypass the supervision of the CBRC, which has resulted in the previous regulations issued by the CBRC becoming a dead letter.
Fourth, policy recommendations
完善银行理财业务的风险管理体系建设，规范业务的风险管理，明确风险要点，强化风险管控，做好压力测试和各种风险管理预案，确保理财产品面临流动性危机时有充足的资本缓冲。 The first is to improve the construction of the risk management system of banking wealth management business, standardize the risk management of the business, clarify the key points of the risk, strengthen the risk management and control, do a good job of stress testing and various risk management plans to ensure that wealth management products have sufficient capital buffer when facing liquidity crisis. .
加强销售人员的专业能力和职业素养，提高销售风险的管理能力，确保把适当的产品销售给适当的客户，真正做到“卖者有责”的要求，同时加大对投资者风险意识的宣传力度，帮助投资者识别虚假的销售行为。 The second is to strengthen the professional ability and professionalism of sales staff, improve the management ability of sales risks, ensure that the appropriate products are sold to the appropriate customers, and truly fulfill the requirements of "responsible sellers", while increasing awareness of investor risks Publicity efforts to help investors identify false sales.
完善信息披露机制，加强对理财资金流向及资金账户等内容的后续监管，定期披露产品的运作信息，确保投资者能够充分了解理财产品的收益及风险状况。 The third is to improve the information disclosure mechanism, strengthen the follow-up supervision of wealth management funds flow and fund accounts, and regularly disclose product operation information to ensure that investors can fully understand the income and risk status of wealth management products.
The fourth is to strengthen the coordinated supervision between various departments, strictly restrict related party transactions, regulate financial innovation in a timely manner, prevent the mutual transmission of risks between different institutions, and eliminate the gray area of regulatory overlap.