After the global financial crisis, more lending platforms were established by non-banker.

in major
countries. In 2017, global P2P lending amounted to US$ 87 billion, an increase of about 42.6% over 2016,
but only accounting for 0.13% of global bank lending to the private non-financial sector in the fourth
quarter of 2017.

P2P lending - dominated by SME financing - is now a big business. The World Economic Forum (WEF)
also predicted in 2015 that Fin Tech would bring changes to the SME financing. The emergence of
technology and innovative operating models will effectively reduce their financing costs, and platforms
will become a reliable source of funds for them, easing their financing difficulties. OECD also pointed out
in its 2016 SME Financing Survey Report that there has been a tendency towards more diverse SME
financing, and online finance is the main emerging trend. In recent years, digital financing platforms in
the Asia-Pacific region (excluding China) have also seen the largest P2P corporate loan transactions and
the fastest growing financing model.

United States
Well known US P2P lending platforms indude Prosper, Lending Chub, and Kiva. Prosper and Lending Club
are for-profit while Kiva is a nonprofit intermediary. Statista estimates the total turnover of alternative
loans in the US in 2019 at US$ 8495 billion, with an average transaction amount per user of US$ 15.283.
It forecasts it to grow at an annualized rate of 1.5% to US$ 9031 billion by 2023 with 1700 users. The
Central Bank (2018) pointed out that the US has not established new law specifically for PP lending. The
main regulations in force for business in lending and securities are the Securities Act of 1933, Bank
Secret Act (including money-laundering regulations), Electronic Funds Transfer Act, Electronic Signatures
Act, Fair Lending Act, Fair Debt Collection Practices Act, and Dodd-Frank Wall Street Reform and
Consumer Protection Act, focusing on functional management. The main relevant regulators are the
Securities and Exchange Commission (SEC), the Consumer Financial Protection Bureau (FPB), and state
financial supervision agencies.

US supervision of P2P lending focuses on several points.

1. P2P lending platform operators must register with the SEC and state securities regulators.

2. P2P lending platform operators who issue securities to transfer creditor's rights to investors should
follow the Securities Act.

3. Ensuring fair borrowing and enhanced disclosure.

4. Protecting the rights and interests of financial consumers.

United Kingdoms
The UK is the birthplace of online lending. There are currently three main P2 lenders:

Zopa, Ratesetter, and Funding Circle. Among them, Zopa was established in March 2005 and is the
world's first and the UK's largest P2P lender.

Statista's estimates the total value of alternative loan transactions in the UK in 2019 at

US$ 4.24 billion, and it is forecasts it to grow at an annualized rate of 3.1% to US$ 4.787
billion by 2023. It estimates SME P2P loan transaction volume at US$ 2.441 billion, with an average loan
amount of US$ 117,195, and total personal P2P lending transactions at USS 1.8 billion, with an average
transaction amount per user of US$ 7,218.

The Central Bank (2018) noted that the UK's Financial Conduct Authority (FCA)

supervises P2P lending platforms and proposes relevant regulations, with the following key points.

(1) Establishment is subject to approval. The minimum capital requirement is GBP 50,000 or 1% of the
loan amount, whichever is higher.

(2) Risk management and consumer protection of P2P lending platforms (with full risk notifications).

(3) Client funds must be deposited with a third-party account.

(4) Closure plans.

(5) Full information disclosure.

(6) Transaction dispute mediation mechanisms.

In addition, the UK, assisted by the P2P Financing Association (P2PFA), has set guidelines for the
operation of the P2P lenders, focusing on the following.

(1) Disclosure of bad debts should be comprehensive and comparable, stipulating the remuneration that
investors may receive.

(2) Disclosure of liquidity and capital risks.

(3) Evaluating platforms' stress resilience and publishing the results.

Australia
Statista's estimates the total value of Australian alternative loan transactions in 2019 at

USS 539 million, and forecasts it to grow to at an annualized growth rate of 4.1% to US$ 632 million in
2023,. It estimates its total SME P2P lending transactions in 2019 at US$

337 million, with an average loan amount of US$ 66,900, and total personal P2P loans at

US$ 202 million, with an average transaction amount per user is of US$ 13,900.

According to the Central Bank (2018), Australia's Securities and Investment Commission (ASIC) is in
charge of P2P lending platforms and has an Internet Lending Business Guide, with a regulatory focus on
the following points.

(1) Financial and credit licenses.

(2) The net value of assets must be more than AUD 150,000, and they must be delivered to the
designated custodian.

(3) Platform operators must be separate from investors.

China
China's first lending platform was PPDAI (also known as PPDF), which was established in June 2007. As
with Prosper, it uses bidding to implement lending. Lending rates are determined by supply and demand
from borrowers and bidders. Borrowers set their own rates through the guidance of credit ratings
published on its website. The lender comprehensively judges the risk level of the borrower based on
their credit ratings and uploaded data, then decides whether or not to invest. The website conducts final
fraud detection review. The website rejects applications by borrowers suspected of fraud for the purpose
of protecting lenders.

Statista's estimates the total value of alternative loan transactions in China in 2019 at US$ 224.204
billion, and forecasts it to grow at an annualized rate of 11.3% to US$ 341.219 billion by 2023. It
estimates China's total SME P2P lending at US$ 163.917 billion, with an average loan amount of US$
4,417, and China's total personal P2P lending transactions in 2019 at US$ 58.486 billion, with an average
loan amount of US$ 2,359.

Chinese P2P lending regulation is headed by the Banking Regulatory Commission of the State Council.
According to Huasheng Securities (2019), the P2P lending regulatory policy in China is the "1 + 3 policy
framework," with several regulatory policies: The Interim Measures for the Management of Business
Activities of Internet Lending Information Intermediaries' issued by the China Banking Regulatory
Commission (CBRC) and other departments on August 24, 2016 (the Interim Measures), the November
2016 Guidelines for the Administration of Filing and Registration of Online Lending Information
Intermediaries, and CBC's November 2016 Guidelines for Online Lending Fund Custody Business and
August 2017 Guidelines for Information Disclosure of Business Activities of Online Lending Information
Intermediaries. On December 19, 2018, the Office of the Leading Group for Special Rectification of
Internet Financial Risks and the Leading Group for Special Rectification for P2P Online Loan Risks issued
the Opinions on Classified Disposition and Risk Prevention of Online Loan Institutions, referred to as
Circular 175.

Taiwan's Central Bank (2018) believes that the Interim Measures define online lending as an information
intermediary business, establish relevant rules and a supervision system, and strengthen supervision of
online lending business activities regulated by the CBRC (now the Banking Regulatory Commission of the
State Council). The Interim Measures also specify business management and risk control norms and
strengthen consumer rights protection and information disclosure. For example, customer funds must be
delegated to financial institutions for management. The Interim Measures limit single borrowers
borrowing limit, prevent platforms from taking public deposits, providing guarantees, promising investor
guarantees, or selling wealth management products.

In addition, China's Guidelines for Online Lending Fund Custody Business require separate management
of platforms own funds and customer funds to prevent the risk of misappropriation. Document No. 175
of 2018 specifically classified P2P online loan institutions, requiring provinces and cities to check lenders
within their jurisdictions, classify them based on their risk status, draw a risk map and clarify task lists.

Japan
Japan's first P2P lending platform was Mane, established in 2008. Statista estimates that Japan's total
alternative loan transactions in 2019 were US$ 455 million, and it forecast them at an annualized rate of
2.2% to US$ 495 million by 2023. It estimated Japan's total

SME P2P lending in 2019 at US$ 452 million, with an average loan amount of US$ 57,935, and its total
personal P2P lending at US$ 2 million, with an average transaction amount per user of US$ 7,227.

According to the Central Bank (2018), Japan's Ministry of Finance is responsible for supervising P2P
lending platforms. They are regulated in accordance with the Lending Industry Law and Financial
Commodities Takeover Law, focusing on several points.

(1) The platform must be registered with the local or central government (when the business spans
separate administrative regions).

(2) Standardizes the qualifications of the person in charge, operations with integrity, to transfer funds to
third parties for safekeeping, regularly disclose financial and business information, prohibit use by
members of violent groups, procedures for transfer of creditor's rights, inform lenders of relevant risks,
and dispute resolution mechanisms.

(3) The "Financial Product Query Method" applies for those involved in financial services and the
issuance of marketable securities.

(4) Lenders are also self-regulated and managed by the government-recognized Lending and Credit
Industry Association and Financial Commodity Collection and Trade Association.

Korea
Statista estimates that Korea's total alternative loan transaction volume in 2019 was US $

158 million, which it projected to grow at an annualized rate of 5.2% to US$ 193 million by

2023. It estimated Korea's total SME P2P lending at US$ 74 million, with an average loan amount of US$
99,933. It estimated its total 2019 personal P2P lending transactions at US$ 84 million, with an average
transaction amount of US$ 387.

According to the Central Bank (2018), P2 lending in Korea is jointly managed by the Financial Services
Commission (FSC) and the Financial Supervisory Service (FSS). South Korea has P2P Lending Guidelines
which focus on several points.

(1) The P2P lending platform must be registered at the FSC.

(2) The average individual investor's annual investment in each borrower is restricted to

KRW 5 million won, and KRW 10 million in each platform.

(3) Borrowers are required to submit guarantee documents to strengthen the security of claims.

(4) Platform operators are not allowed to keep their own funds. They should be kept by third-party
banks.