Loan facilitators under our coverage reported decent earnings in 3Q21 and provided more detailed plans on business process modifications to be in compliant with the latest regulations.

We believe potential PBOC approval of some of the new business procedures in 1Q22 could be a catalyst.

Healthy 3Q21 earnings trend for loan facilitators under our coverage despite concerns on regulations and macro uncertainty. QFIN, LU and LX all reported healthy loan volume and stable credit quality trends. Take rate declined modestly at LX due to efforts to reduce IRR on facilitated loans to below 24% by June 2022 but slightly higher for QFIN. While we do expect some profit pressure in 2022 for QFIN and LX, as they shift their borrower bases and take a more prudent strategy on loan volume during the early stages of their new business cooperation model with credit scoring firms, we believe the lower risk profile of the new borrower base could reduce earnings volatility in the future with still reasonable net take rates of around 3%.

Business process modification to be compliant with credit scoring regulations could be approved by PBOC as early as 1Q22. Management of QFIN, LU and LX all outlined work plan schedules to comply with new credit reporting rules, the final regulatory change, and expect to seek PBOC approval in 1Q22. The firms will test different types of cooperation model with licensed credit score agencies with a key difference centered around where the joint risk modeling process will be housed including 1) solely at credit score agencies, 2) separate models at loan facilitators and credit score agencies, and 3) separate models at credit score agencies and financial firms built and maintained by loan facilitators. We believe option 2 is the most likely option. While the first option is less favorable to loan facilitators, they could still maintain the key value proposition, which includes the combination of client acquisition, risk screening, borrower reactivation and other post lending services for small financial firms, and loan facilitators could still effectively turn that into option 3, which would give them a greater value proposition. We believe QFIN and LU are better positioned on the regulatory front with LX facing more of a challenge.