The 48% cap and the 36% threshold are two different rules
One makes a loan unlawful. The other lets a court reopen it years later. Lenders who treat them as a single number tend to price against the wrong one.
RegulationLending operations
Lending news
What changed for Hong Kong lenders this week.
Short briefings on regulation, credit data and lending operations, written for the people who run the book rather than for a policy audience. A new one every few days, each with its sources.
What phase two of Credit Data Smart would actually change for a money lender
RegulationCredit data
The proposals are specific about who submits, how often, and what counts as in scope. Here is the short version, and the part most lenders underestimate.
Earlier briefings
Money lenders are not covered by the AML Ordinance. The duties still apply.
A common misreading: because Cap. 615 does not list money lenders, some operators conclude the obligations are lighter. They arrive by a different route, with an offence attached.
Regulation
The low-income lending conditions put the burden on your evidence, not your policy
A debt servicing ratio cap and a repayment-period limit are easy to state. Proving, months later, what income you relied on is where files fall apart.
RegulationLending operations
eKYC is not finished when the HKID is photographed
Capture is the easy half. The half that decides whether a file survives review is what happens to exceptions.
TechnologyLending operations