揭秘代扣江湖灰色利益链

近日,中国人民银行办公厅发布了《关于加强小额支付系统集中代收付业务管理有关事项的通知》(银发办【2017】110号),几乎是一纸叫停了集中代收付业务。通知规定:集中代收付中心将严禁向公用事业类和公益类以外的其他机构提供代收付服务,对于已为其他机构提供代收付服务的集中代收付中心,应于2017年12月31日前断开上述机构的而连接,停止为其提供服务。

而自2017年6月30日起,集中代收付的金额也将制定上限,为5万元/笔。而就仅剩的公用事业类和公益类单位,集中代收付中心提供代收付服务时也应逐步采取免收费政策,自2019年1月1日起一律不得向代收付业务的委托人收取费用。除此以外,该通知要求集中代收付中心不得将核心业务外包,集中代收付中心与委托人新增、变更或终止业务合作关系,应报所属人民银行分支机构同意。

事实上,这项被央行一纸叫停的集中代收付业务长期以来一直是支付江湖的灰色地带,藏匿着一个巨大而隐秘的灰色产业链。

一位接近监管层人士向经济观察报透露称,央行之所以动议整肃代收付业务,源于此前山西同城清算系统的一起风险事件,有客户在不知情的情况下被陆续扣款数千万。

“在这起大额风险事件之前,代扣业务的乱象已经持续了多年。诸如套现、包装户等收单市场的违规行为,代扣市场一样不少。”上述接近监管的人士称,“这次整治并非清算总中心出手,而是以央总行发文的形式,这一点上,事态严重性已可见一斑。”

支付江湖的“灰色之地”

集中代收付到底是一个什么样的业务?顾名思义,该业务上分为两块,对消费者的代扣和对商户的代收。而事实上,对于该项业务,业内有一个更直白简洁的称呼,谓之“代扣”——基于持卡人与商户签订的业务委托协议,授权商户向持卡人指定账户发起并完成指定款项扣钱的业务,不需要持卡人再次确认和输入密码,甚至在每一次扣款时,无需再度提醒持卡人。

特别值得提醒的是,代扣服务本身不一定拘泥于银行卡,也可以是银行虚拟账户等,代扣服务分为:对公代扣、对私代扣两类。相较于银联只能对私扣款的功能,集中代收付中心的代扣接口功能似乎更为强大。

在拥有协议书的情况下,需要商户发起的扣款指令要素只有卡号(必送),姓名、证件号、手机号(可选)等,并不包括密码和其他验证要素。

一位第三方支付机构副总裁说,通常而言,代收付业务有三种玩法:

一是,支付机构可以一家家谈银行,但这种做法存在一个致命缺陷,根据2016年《国务院办公厅关于印发互联网金融风险专项整治工作实施方案的通知》规定,非银行支付机构不得连接多家银行系统,变相开展跨行清算业务。其实现在这个做法在市场上仍属于主流,但这个事情属于人民银行直接参与管理,一旦监管机构认真落实检查,被处罚的可能性很大。而除此以外,对于一些规模较小的支付机构而言,与银行单点连接做代扣业务,效率太低,难成气候。“这种模式的可持续性应该不会很强,趋势来看,未来将会被网联统一收编”;

二,支付机构也可以通过银联触达各家银行实现代扣,这样做效率很高,但是成本也很高。银联目前所采取的是阶梯费率,单笔在0.7元到1.7元不等,银联自己留0.2元,其余给发卡行;而面向银行理财等大额代扣,则根据金额大小收取2元/笔到8元/笔的费率;实时代扣则更高一些,采取相当于POS收单的费率;

三,通过集中代收付中心实现代扣,同样高效,可以一次性打通国内所有银行。“但这个通道是稀缺资源,不是每家支付机构都能拿到,拿到接口的支付机构可以把接口继续对外放,多放一道就多一重溢价。”“相较而言,集中代收付中心的代扣接口是最好的通道,比银联通道好用很多。首先,便宜。代扣不以费率计价,按笔数计价,单笔几毛到几块不等,对大额支付而言,特别划算;其次,方便。POS收单只能做对私的银行卡,且需要密码、验证等手段,代扣则不同,只要持卡人账号就可以做代扣业务,不需要密码、验证等手段,且对公对私不受限制,操作便捷。走POS收单的,你玩‘套冒绕’,银联天天盯着查你,代扣则不同,代扣走的是集中代收付中心的代扣接口,属于中国人民银行清算总中心的业务,而后者是中国人民银行直属的、实行企业化管理的事业法人单位。”上述第三方支付机构副总裁告诉经济观察报。

在这位第三方支付机构副总裁看来,某种程度而言,集中代收付中心的代扣接口很容易为不法分子所利用,成为“法外之地”。从最终的结果来看,也正是风控的缺失导致了这条灰色产业链最终走向末路。

利益链

事实上,集中代收付业务在公开场合很少被业内人士提及。其原因在于,一者,集中代收付业务属于清算总中心管理,后者是央行直属单位,在央行没有出手监管的前提下,没有哪个职能部门有资格动议监管;二者,在集中代收付中心代扣接口拥有绝对价格优势的前提下,利益链庞大,寄生在该利益链上的群体人数众多。“在这个江湖的人,都很清楚这是一个无法公开化的商业模式。大家都为求财,就不要声张。难就难在,集中代收付中心本身并不精于对风险的判别,更无论风险的追偿机制。风控的责任和主动权完全掌握在支付机构的手中,因此风险很容易就失控了。”上述接近监管人士称。

一家第三方支付企业CTO告诉经济观察报,理论上,只要掌握了代扣渠道,要实现不法目的几乎不存在任何技术上的难度,“在信息倒卖的这个灰色产业链里,持卡人信息根本不是什么秘密。而持卡人的银行卡号、身份证号等基本信息一旦泄露,通过代扣就可以在没有密码的情况下轻易扣完卡内资金并转移。”

除了为不法分子牟利带来便利以外,集中代收付中心本身的牟利行为也是代收付业务为行业诟病的重要原因。

上述接近监管层人士透露,全国而言,中国人民银行深圳中心支行的接口规模相对较大。

提及中国人民银行深圳中心支行,则不得不提一家名为深圳金融电子结算中心有限公司的企业。

经济观察报通过天眼查发现,该公司注册成立于2014年6月,第一大股东是其工会委员会,其余12个股东中,除平安银行和招商银行为总行持股以外,另10家基本都是四大行及全国股份制商业银行的深圳分行工会委员会。

“这家企业的存在是因为一些历史问题,为了解决同城结算的问题而设置的,虽然股权关系上和央行深圳中心支行没有关系,但公司领导基本都是后者指派。”深圳当地一位支付机构副总裁告诉经济观察报。

经济观察报从公开资料中查询获悉,该公司董事长曲显斌此前担任人行深圳中支支付结算处处长。

通过天眼查,经济观察报同时发现,该公司通过旗下全资子公司深圳金融电子结算科技有限公司持股深圳市快付通金融网络科技有限公司(下称“快付通”)20%的股份,快付通是一家持牌的第三方支付机构。

“所以在放代付接口的产业链上,上下游就这么打通了。”上述人士评价,“当然,这并非一定是个人或某一个利益团体的牟利行为,但央行自身扮演着监管角色,职能部门却在业务链条中牟利,始终是说不过去。”

就全国而言,到底各集中代收付中心涉及多少灰色产业规模,这是一个难以量化的数字。“在代扣业务上,集中代收付中心的整体代扣规模应该是大于银联的。代扣属于无卡业务,不属于银联管,银联也没有能力管。”一位股份制银行的交易银行部人士告诉经济观察报,“但因为是一个灰色产业链,有些地方敢放通道,有些地方不敢。有些地方放得多,有些地方放得少。而在放出的通道中,哪些是合规,哪些是违规,也很难辨别。因此没人说得清到底规模也多大,即使是监管机构,可能也只有一个概念,没有准确的数字。”

影响几何

“就监管思路上而言,央行是监管机构,确实不应该自己下场参与到运动员角色中。把代扣接口这个事情停掉,等于也是对集中代收付中心放通道的盈利行为一次性切断,同时也消解了一大片法外江湖,是一件推动行业正向发展的好事。”一位接近监管的人士评价称,“后路被堵死之后,资金的流转划拨不得不回到体系内运转了。这则消息无论对银联还是网联而言,都应当是一个利好。”

但同样需要提及的是,对于许多正常经营的商业机构而言,也可能会因为接口的关闭而影响到其原本的商业模式。“比如视频、音乐、游戏公司,在充钱时一般会提醒你是否按月按时缴费,你点确认,那么之后的每个月你不需要再去进入缴费页面,会员费的钱就会被授权从银行卡内扣除。如果这些机构此前走的是集中代收付中心的代付接口,那么一旦代付接口被关,对这些企业而言,每个月久需要再度营销老客户,此间的销售成本、成交率都会受到很大影响,客户的粘性也会变弱。与此类似的车贷、房贷、保险、信用卡自动还款等代扣业务,在代扣业务停了之后,虽然安全性可能得以提高,但也可能在很大程度上引起不便。”一家股份制商业银行交易银行部的人士告诉经济观察报。

上述银行人士表示,“原有的商业模式会不会受影响,关键在于它背后走的是哪一种通道,不过所幸,央行给了一段缓冲的时间,商户及支付机构只要把原先通过集中代收付中心走的交易转向银联来对接各家银行,原有业务应该不会受到影响。”

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