Major shake-up in the collection industry: Are illegal "credit repair" practices the final straw crushing internal collection teams?

Questioning AI · Why does the违规“信修”触碰监管红线在逾期初期就触碰监管红线？

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Recently, news of leading platforms’ collection teams and major collection companies being lawfully taken away has caused a shock in the post-loan collection industry, also ringing a compliance alarm for financial institutions’ post-loan management.

Multiple sources indicate that one involved internal collection team’s violation focus is that they used “信修” methods during the M1 overdue stage (i.e., 1-30 days overdue), crossing regulatory red lines. Currently, against the backdrop of increasing profitability pressure on financial institutions, “seeking profit from post-loan” has become an industry consensus, and improving collection efficiency has been prioritized (see “Profit Pressure Leads to ‘Seeking Profit from Post-Loan’ as a Key Strategy”). But this industry upheaval clearly shows that compliance is a prerequisite for improving post-loan collection.

Cai Jin Jie has learned that currently, various financial institutions are urgently reviewing their data and operational rules in light of the latest collection regulations, with a focus on compliance standards for key post-loan collection activities, especially the repair of lost contact information.

Industry Shock as a Wake-up Call: Violating “信修” Crosses Red Lines, Compliance Boundaries Must Be Clarified

What is “信修”? Industry insiders typically define it as “restoring contact with lost contact persons.” As an important means of reconnecting with delinquent borrowers in post-loan collection, this business model has clear boundaries.

Specifically, this activity relies on legitimate data from the three major telecom operators, mainstream logistics platforms, and others, ensuring privacy security through encryption and data masking techniques to restore valid phone numbers or addresses of lost contact persons, providing outbound calls, SMS, or document mailing services.

“Under normal circumstances, 信修 services are only activated at the M4+ stage (over 120 days overdue), and the core compliance principle is ‘user authorization’,” a senior post-loan practitioner revealed. Any unauthorized contact restoration operations without the debtor’s legal consent are considered clear violations, which is one of the main reasons for the recent investigation of involved organizations.

According to the latest industry standards, the compliance boundaries for lost contact repair have been further clarified. It can only be initiated after the debtor is confirmed lost, and it is strictly forbidden to contact third-party contacts in the debtor’s address book. This aligns closely with the requirements in two authoritative documents that “strictly prohibit ‘exploding contact lists’ and only contact necessary parties.”

Cai Jin Jie has learned that previously, big data companies and collection agencies commonly collaborated on lost contact repair by signing entrusted agreements. With tightening compliance requirements, this model must now strictly follow the “triple authorization” and data encryption and masking regulations.

Recently, multiple financial institutions such as CITIC Bank, Guangzhou Bank, China Post Consumer Finance, CCB Consumer Finance, and Changsha Bank have publicly announced procurement notices for lost contact repair vendors. Against the backdrop of industry upheaval, how to select compliant vendors and standardize cooperation models has become a core focus for financial institutions to establish a solid compliance foundation for lost contact repair.

Two Authoritative Documents Clarify Boundaries: Clear Comparison of Compliance Requirements for Lost Contact Repair

A review shows that there are already clear authoritative guidelines to follow within the industry.

Among them, the national standard “Guidelines for Post-Loan Collection Risk Control” (GB/T 45251—2025), issued in March 2025, and the China Banking Association’s “Guidelines for Collection of Personal Consumer Loans by Financial Institutions (Trial)” published in 2026, although they do not explicitly use the term “lost contact repair,” both documents focus on contact recovery in lost contact scenarios and provide clear, actionable compliance regulations, defining precise operational boundaries.

Based on the guidance from these two authoritative documents and the latest industry standards, the core compliance premise for lost contact repair is that the debtor is truly lost contact, and it is strictly forbidden to contact third parties in the debtor’s address book. The key points for compliant operation mainly include three aspects:

First, regarding initiation conditions, it must strictly meet the “unable to contact the debtor directly” standard, such as invalid phone numbers or three consecutive failed connection attempts over three days, with the sole purpose of restoring contact with the debtor himself. It is forbidden to initiate when contact with the debtor is still possible.

Additionally, regarding authorization, the debtor must have authorized the loan at signing, and the process must meet the “triple authorization” standard: the debtor authorizes the financial institution, the financial institution authorizes the collection agency (with additional bank approval), and the debtor authorizes the three telecom operators, ensuring legal information flow.

In operational procedures, after obtaining legitimate authorization, the financial institution and collection agency must transmit encrypted ID information to the telecom operators, who then provide masked phone numbers and outbound call, SMS services; all qualified participants in these steps can carry out related activities.

From industry development trends, the proactive disclosure of compliant vendors by financial institutions indicates that the normalization of compliant lost contact repair has become an irreversible trend. In the future, with the implementation of these two authoritative documents and ongoing industry self-discipline, the operational boundaries of lost contact repair will become clearer, and compliance will be a core barrier in industry competition.