中國式影子銀行－－緣起、特色與出路

The Shadow Banking System in China

影子銀行是指在傳統銀行之外進行信用轉換、期限轉換和流動性轉換的一套間接金融體系。中國大陸的影子銀行體系非常複雜，其主要是通過理財產品完成信用轉換的，在這一過程中通常會採用「資金池」形式。該影子銀行模式在很大程度上受到大陸獨特政經監管環境（如嚴格的金融牌照制度和信用政策控制）的影響。資金的需求端和供應端均時有創新，例如地方政府融資平臺和P2P (Peer to Peer)借貸。監管機構對這些金融創新也進行了回應及干預，影子銀行的市場運作和監管在相互博弈的過程中不斷進化，不過目前的監管思路仍有必要調整。

The shadow banking system is the one that conducts credit, maturity and liquidity transformation outside regular banking mechanisms. Chinese practices largely fit into this concept. However, unlike their foreign peers, Chinese shadow banking institutions have been intertwined into a complex whole and have achieved credit intermediation usually through wealth management products, often using the problematic asset-pool model. They are also substantially influenced by the unique political economic dynamics in China, such as the rigid financial licensing regime and credit policy control. Both the supply and demand ends of funding have provided those activities with new features, for instance, the P2P lending marketplaces and local government financing vehicles. Chinese government agencies have interplayed responsively and proactively with the market via rule making and enforcement, in particular recently, with the aim to fix loopholes, level the playing field and limit regulatory arbitrage. However, further efforts are imperative in order to develop moderate and appropriate regulation and draw clearer legal boundaries.