Yesterday, China's central bank and the CBRC issued a set of rules for the burgeoning online lending market. My initial thoughts:

1. The rules seem harsher than I had expected.
2. It covers both P2P and online microcredit lending. There will be no new online microcredit licenses but the existing ones are safe. P2P platforms as a form of business are safe and viable.
3. It bans asset-backed securities (ABS) and sales of loan packages to third parties via an asset exchange. That will hurt some online lenders' funding source.
4. It may lead to a liquidity squeeze in the industry but P2P funding seems permissible. But we should work harder to explore corporate treasury as a new source of funding.
5. It could encourage more borrowers to default as the regulatory crackdown and confusion continues.
6. The 36% cap on interest rates is going to hurt the industry at large but some players are planning separate entities (with the same shareholders) to do the data verification, servicing and collection in order to comply with the new rule.
7. The banks and trust companies are likely to be more cautious in dealing with the online lending industry.
8. Given the new political reality, it will be harder in the future for the online lenders to continue to use trust structures or entrusted loans to conduct business.