我国小额贷款公司规制评估:CEE体系构建及其应用

The Regulation Assessment of Small Loan Companies:CEE System Construction and its Application

作为新一轮农村金融改革的"拟制产品",小额贷款公司运营绩效与其规制密切相关。建立全面、科学、公正的规制评估体系是对小额贷款公司进行规制评估的关键。运用包含规制内容、规制效率、规制效果的三维评估体系(CEE)对小额贷款公司规制进行综合评估,结果发现:现行小额贷款公司规制不合法,缺乏规范性、稳定性、协调性和可操作性;规制效率总体不高,监管水平较低;规制效果与规制目标之间存在较大差异,既难以满足农村金融需求,也不能推动其自身可持续发展。提升小额贷款公司的规制效率和规制效果,必须改革现有"政策+暂行规定"的制度供给模式,实现小额贷款公司规制内容的科学化、规制模式的法治化。

The actual operating condition of small loan companies which is the prepared product of the new rural financial reform is related to its regulations. It is key to develop regulation evaluation by establishing a comprehensive,scientific and fair assessment system. The three-dimensional evaluation system contains the regulation content assessment which mainly assesses the text of regulation system,the regulation efficiency assessment which is a cost-benefit analysis based on regulatory inputs and outputs,and the regulation effect assessment which pays attention to the achievement of regulatory objectives and social intervention. The study finds that: on the regulation content,the system is illegal and is lack of specifications,stability,coordination and operability; on the regulatory efficiency,the resource allocation efficiency is not high because of the high cost and low income of regulation; on the regulatory effect,it's difficult to achieve the goal since it's difficult to meet the needs and promote the effective competition of the rural financial market,and it can hardly alleviate rural financial repression and support their own sustainable development. In order to enhance the efficiency and effect of regulation,it's necessary for small loan companies to change the existing regulation supply mode supported by the policy and Interim Provisions to a regulation supported by scientific content and legalization mode.