The finance companies should focus on fully and diversifying 3 important basic distribution channels successfully implemented in 2014-2019, including POS, DSA, Telesales, strongly deploying the distribution channel through the parent bank, researching and deploying modern distribution channels according to the business strategy and capacity. + For POS development: the finance companies need to establish a network of selling points in the first place, quickly expand and diversify directly distribution channels. It is necessary to rely on the strengths of the parent bank to focus on developing relationships with partners closely associated with the parent commercial banks such as telecommunication corporations, electronic corporations to increase the power of negotiation and achieve development goals of selling points each period. The finance companies should base on financial resources and the support of the parent bank to reasonability distribute in building their distribution network in each stage of development, avoiding overheating development to ensure the quality of the company's operations. + For the distribution channel through the parent banks: the parent banks have a large network of branches and transaction offices nationwide, having large amount customers with transaction relations. The finance companies can take full advantage of the network of available transaction points of the parent commercial bank to promote and sell their consumer credit products to customers of banks such as: Payroll customers of banks with good credit score need to borrow unsecured cash loans with small amount but do not have bank loan products; Current account customers of banks didn’t paid wage via bank and aren’t eligible to borrow at banks but have demand for consumer loans; Customer group is not eligible for commercial banks, but they are currently working in enterprises that have close relationships with commercial banks
                
              
                                            
                                
            
 
            
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 credit in terms of the quality of the financial company for the 
purpose of developing safe and effective consumer credit is shown in the following contents: implementing 
an effective and effective credit risk management model, credit policies and credit process. 
- Credit risk management model: According to international practices, there are two common 
models being applied by finance companies, including centralized risk management model and differential 
risk management model. The centralized risk management model is a model that clearly separates the 
business and risk management functions with the main advantage of systematic risk management on a 
company-wide scale, ensuring competitiveness Long-term competition, establishing and maintaining a 
synchronous risk management environment, consistent with the management process associated with the 
operation of business departments, improving capacity of risk monitoring and measurement, policy 
development unified risk management for the whole system. The distributed risk management model does 
not have a separation between business and risk management, in which the Business Center fully implements 
all stages of the loan from appraisal, disbursement, and control to settlement debt relief. This model, thanks 
to its simplicity and simplicity, has been adopted by independent, small-sized finance companies. 
 - Credit policy: In order to ensure that consumer credit activities are implemented according to the 
risk management model and business strategy from the Board of Members / Board of Directors of Finance 
Companies, the finance companies should develop and implement a credit policy and a series of internal 
documents to coordinate and control the activities of consumer credit activities of finance companies. 
 - Credit process: Regulating all principles and operational flow of professional divisions of the 
financial company from the time of accessing loan application of Invidual Customers until deciding to lend, 
disburse or collect money debt and contract liquidation. The credit process is built according to an end-to-
end standard and has full of control points in the direction of automation to help the financial company 
ensure that there are no omissions in the lending process, helping defining the functions of professional units 
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in the financial company participating in the credit flow flow is transparent, clear, understanding the method 
of coordination and fully grasping its roles and responsibilities. 
- Credit policy: In order to ensure that the Consumer Credit operation is implemented according to 
the risk management model and business strategy from the Board of Members / Board of Directors of The 
finance companies, directly under The finance companies need to develop and enact credit policies and a 
series of internal regulations to coordinate and control the activities of consumer credit of The finance 
companies . 
- Credit process: regulates all principles and workflow of the operational departments of Consumer 
Finance Companies from the time of approaching loan application of Individual Customers until lending 
decision, disbursment, debt collection and contract liquidation. The credit process is built according to an 
end-to-end standard having full of automatic control stages to help the the finance companies ensure that 
there is no fault in the lending process, helping to define functions of the operational departments 
participating in the credit flow is apparent, explicit, understanding the method of coordination and fully 
perceiving their roles and responsibilities. 
2.1.3. Criteria to assess consumer credit development level of the finance company 
2.1.3.1. Indicators for development of consumer credit in quantity 
- Consumer credit products’s annual growth. 
- Consumer credit distribution channels’s annual growth. 
- Customer volume’s annual growth 
- Consumer credit market’s annual growth. 
- Growth rate of annual consumer credit outstanding. 
- Growth rate of consumer credit market share. 
- Growth rate of profit. 
2.1.3.2. Indicators for development of consumer credit in quanlity 
NPL (bad debts) ratio 
NPL ratio in year n = 
Balance of NPL Consumer Credit year n 
x 100% 
Total Balance of Consumer Credit in year n 
Minimum Capital Adequacy Ratio 
CAR = 
Equity 
Total assets at risk 
 In addition, the development of the finance companies’ consumer credit is also evaluated through the 
contribution of companies to the results, position, prestige ... parent commercial bank, in implementing the 
goal of limiting black credit in the national socio-economic development strategy etc. 
2.1.4. Factors affecting the development of the finance companies 
2.4.1.1. Factors belong to the finance companies 
- Development strategy. 
- Organizing product development capacity. 
- Human Resources. 
- Information technology capacity. 
- Responsible lending factor. 
- Service Quality. 
2.1.4.2. Factors belong to commercial banks owning finance company 
 For the finance companies, factors belonging to parent comercial banks have certain implications for 
the development of consumer credit. The following are factors of a commercial bank that owns a finance 
company that impacts on the development of consumer credit of the finance companies: Development 
strategy of commercial banks, prestige and brands of commercial banks. 
2.1.4.3. Factors belong to borrowers 
Factors that belong to borrowers include customer needs, ethical risks, customer insights and customer 
information. 
2.1.4.4. The elements belong to the business environment 
- Economic, legal, and political environment. 
- Competitors: the finance companies are under impact of the competitors directly including banks 
and consumer finance companies in Vietnam, Fintech Company (platform peer lending), other lending 
institutions are not recognized by law. 
2.3. INTERNATIONAL EXPERIENCE ON CONSUMER CREDIT DEVELOPMETN AND 
LESSION LEARNED FOR VIETNAM 
2.3.1. International experience on consumer credit development 
2.3.1.1. About ways to develop consumer credit 
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- Santander Consumer Finance Company: the leading company was established in 1963, is active in 
15 countries in Europe. Santander is owned by Banco Santander Bank, one of the largest banks in the world by 
market capitalization. Santander provides a wide range of basic consumer credit products such as unsecured cash 
loans, installment loans and credit cards. Because Santander focuses strongly on installment loan products, the 
company mainly uses traditional distribution channels to provide services including service introduction places, 
branches, telesales centers and receiving loan requests via website. So far, Santander has been serving 20 million 
customers with 130,000 service introduction places in cooperation with retail partners in many countries and 
15,300 employees. 
- Capital Car Finance: Capital One Group is a US-owned commercial bank, listed on the New 
York Stock Exchange. Ranked by Forbes in 2017, on the activities of consumer credit consolidation, Capital 
One was ranked second behind American Express among the world’s top 10 largest consumer finance 
companies according to 4 combined criteria including revenue, profit, asset and market value. In 2001, 
Capital One Group acquired PeopleFirst Finance LLC and changed its name to Capital One Car Finance 
(hereinafter referred to as Capital One) in 2003. For auto loan segment, Capital One provides installment 
loan products for buying new cars and used cars or refinancing customers' car loans provided from other 
financial institutions. Capital One implements the Auto Navigator system, which allows potential borrowers 
to apply for a loan and view a vehicle in the same application on Capital One's website or APP. Thus, 
although Capital One provides consumer CREDIT product which is basically car installment loan, it has 
applied technology to receive and process documents online, combined with traditional distribution channel - 
dealers - to complete providing loan to customers. 
2.3.1.2. Development strategy 
- APLUS FINANCIAL Co., Ltd of Shinsei Bank, Japan: Shinsei Bank is one of Japan's leading 
financial institutions, formerly The Long-Term Credit Bank of Japan, Ltd owned by Japanese Government. In 
2000, Shinsei Bank was privatized and sold to an American company and renamed Shinsei Bank. Shinsei Bank 
issued shares to the public in 2014 and collected 230 billion yen. Shinsei Bank's operations focus on three main 
areas of activity including retail banking, wholesale banking and consumer finance. Based on the science and 
technology database that has been used for payments or loans for many years, Shinsei Bank has cross-sold its 
existing customer base with consumer demand for loans to Aplus via digital platform. 
2.3.1.3. State management of Consumer Credit development by Consumer Finance Companies 
- Experience of Japan : Before 2006, the market of consumer credit witnessed the strong growth 
peaked in 1990 with credit size reached 12.000 billion yen to 14,000 companies operating in the field of 
lending, interest rates peaked in the cap of 109 , 5 % according to Capital Registered Law. By 2007, the 
Japanese Government decided to increase the penalties for borrowing at high interest rates while increasing 
requirements for control and complementary properties with consumer finance companies. These tight 
control measures in Japan have led to a negative impact on the domestic consumer credit market. As a result, 
in the period 2007-2009, the number of domestic Consumer Finace Company decreased sharply, many 
foreign consumer finance companies such as Citi Group, GE, etc. leave Japan one by one. The market exits 
of consumer finance companies bring enormous business opportunities for black credit. The state could not 
solve the problems caused to consumers from illegal lending activities, and also faced the problem of 
unemployment and declining tax revenues when consumer finance companies leave the market. 
- Experiences from countries in Community General Europe: Interest rate restriction is the solution to 
be recognized and applied in different countries in the EU. According to the results of a European Commission 
survey on interest rate restriction in the EU, there are 3 countries including Greece, Ireland and Malta are still 
applying interest rate restriction completely, there are 12 countries applying Use interest rate restriction relatively 
and 13 countries do not apply interest rate restrictions. Survey on a large scale has been undertaken to assess the 
impact of interest restriction to the development of consumer credit and obtained the following results: It leads to 
limited access to consumer credit, the size of consumer credit decreased in countries where the interest rate 
restriction was applied and fell sharply in the countries where the absolute interest rate was applied, consumer 
finance companies restricted their operation or gradually exited from the loan market. 
2.3.2. Lessons learned for Vietnam 
2.3.2.1. Lessons for finance companies 
 Firstly, the finance companies need to exploit individual customers’ profiles that are in relationships 
with parent banks. This is the fast and effective solution for the finance companies to introduce and 
constantly update consumer loan products to customers trading and using services of commercial banks APP 
mother. Customers who are using the APP are also the channels to 
introduce potential consumer credit products of subsidiary the finance companies when customers know the 
products and introduce the products to their relatives and friends. 
Secondly, the finance companies should choose the business model with the consumer credit và 
channel distribution accordingly, constantly improve the utilities of the products of consumer credit to 
maintain existing customers and attract new customers. Besides the strategic diversification of consumer 
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credit products, the finance companies should focus on a number of consumer credit products with 
advantages, creating added value on products such as create a loan and receive online applications, notify 
loan results of emails, loan queries on mobile applications etc. Clarifed product strategy also helps the 
the finance companies to develop righteous and effective distribution channels, contributing to sustainable 
of consumer credit growth. 
Thirdly, the finance companies need to build a modern information technology system to provide 
credit to individuals conveniently and effectively. Thereby providing credit products applied new technologies 
to encourage and attract customers. 
2.3.2.2. Lesson for state management on consumer credit development 
Firstly, consumer credit activity should be considered in correlation with consumer credit demands 
of individual customers, the Government when developing consumer restriction tools should be carefully 
evaluated to ensure consumer credit limitations not lead to a black credit boom, affecting low-income 
subjects but in need of consumer loans. 
 Secondly, the restriction of consumer credit should be flexibly applied to each of the finance 
companies which have clear applying conditions. The finance companies have financial potential, ability to 
control risks better and ensure that the targets set by government regulations such as the Capital Adequacy 
Ratio, bad debt ratio, capital minimum charter etc should be encouraged to grow consumer Credit at a higher 
rate than those do not meet the requirements for credit growth. Thus, the finance companies can maximize the 
role of funding for consumers with low incomes and become a tool of positive black society credit restrictions. 
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CHAPTER 3: REAL SITUATION OF CONSUMER CREDIT DEVELOPMENT OF FINANCE 
COMPANIES UNDER COMMERCIAL BANK IN VIETNAM 
3.1. OVERVIEW OF THE FINANCE COMPANIES IN VIETNAM 
3.1.1. Establishment and development process of the finance companies in Vietnam 
The period 2007-2010 is a period with a strong participation in credit operations of a type of non-bank 
credit institutions as a financial company. There were 3 foreign finance companies and 9 domestic finance 
companies licensed to establish in this period. As of December 31, 2019, there are 16 finance companies in 
Vietnam, including 4 finance companies with 100% foreign capital, 6 finance companies under commercial 
banks and 6 finance companies under economic groups. and other shareholders. 6 finance companies under 
commercial banks including Community One-member Finance Company, Post and Telecommunication 
Finance Company, Vietnam Fe Credit, HD Saison, and MCredit, SHB Finance. 
3.1.2. Management and organizational model of finance companies under commercial banks 
The finance companies all have relatively similar organizational structures, including the Members' 
Council, the Supervisory Board, the General Director, the Business/business Center Division, Risk 
Management Division, Internal Auditing Department, Legal Department, Operations Division, Human 
Resources Division, Financial Accounting Department, Treasury Department, Information Technology 
Center. Depending on the model of the finance companies and the size of personnel in each unit, the names 
of functional units will be specified in the form of Block or Board or Center. 
3.2. CURRENT SITUATION OF CONSUMER CREDIT DEVELOPMENT IN VIETNAM 
3.2.1. Current situation of implementing consumer credit development methods 
3.2.1.1 Actual situation of developing consumer credit products 
Table 3.1 The development of new consumer credit products by the finance companies 
No. 
Number of consumer credit 
product groups 
2014 2015 2016 2017 2018 2019 
1 FE Credit 3 3 4 4 5 6 
2 HD Saison 3 3 3 3 3 3 
3 MCredit N/A N/A N/A 3 3 3 
4 SHB Finance N/A N/A N/A N/A 1 1 
Source: Fiingroup 
In the 2014-2019 period, the finance companies focused on deploying basic consumer credit product groups to 
meet the consumer loan needs of individual customers. FE Credit is the only financial company providing FE Credit Plus 
+ Master Card in the market. FE Credit is also a pioneer finance company deploying digital consumer credit products. In 
the period of 2014-2019, HD Saison only focused on deepening customers and expanding lending purposes under 03 
basic consumer credit product groups but not deploying credit cards, and digital consumer credit products. MCredit and 
SHB Finance also focus on basic consumer credit products right from the official operation phase and not further 
development, in which MCredit deploys 03 consumer credit products similar to HD Saison in In the period of 2017-2019, 
SHB Finance only focused on cash loans in the period of 2018-2019. Thus, consumer credit development through the 
method of consumer credit products has the differences between the 4 finance companies under the commercial banks in 
the period of 2014-2019 as follows: FE Credit implements the development of consumer credit by a mixed consumer 
credit product category including basic consumer credit products and numbers but with a focus on the basic consumer 
credit product group. The remaining finance companies are focusing on developing consumer credit by the group of basic 
consumer credit products, there has not been a shift to digital consumer credit products. 
3.2.1.2. Current situation of development of distribution channels 
Table 3.2 Development of distribution channels during 2014-2019 
No. 
Number of 
distribution channels 
2014 2015 2016 2017 2018 2019 
1 FE Credit 4 4 4 4 5 5 
2 HD Saison 4 4 4 4 4 4 
3 MCredit N/A N/A N/A 4 4 4 
4 SHB Finance N/A N/A N/A N/A 4 4 
Source: Fiingroup 
In the period 2014-2019, all the finance companies have deployed basic distribution channels 
including POS, Telesales, DSA, and Partners. FE Credit grew one more distribution channel in 2018 thanks 
to the deployment of loan application and automatic approval on mobile APP. In fact, although most of the 
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distribution channels are implemented by the finance companies, the differences between the finance 
companies are reflected in the number of POS and DSA that the financial firms provide. subordinate has 
grown. Developing the number of POS and DSA distribution channels, either qualitatively or quantitatively, 
has a positive impact on the growth of consumer credit of finance companies. In general, in the period of 
2014-2019, the finance companies implemented the strategy of developing traditional distribution channels, 
focusing resources on developing POS / DSA channels and developing diversified distribution channels. 
Other, step by step developing a new distribution channel through the parent bank. 
3.2.1.3. Market share 
Table 3.3. Level of market growth geographically during 2014-2019 
No. SL TT TDTD 2014 2015 2016 2017 2018 2019 
% Average 
growth 
1 FE Credit 63 63 63 63 63 63 0% 
2 HD Saison 43 51 63 63 63 63 8% 
3 MCredit N/A N/A N/A 36 53 63 33% 
4 SHB Finance N/A N/A N/A N/A 33 37 22% 
Source: Fiingroup 
Geographic market development plays an important role in the development of consumer credit and has 
been well-aware and strategically covered by finance companies in the short time since its establishment. 
3.2.1.4. Sales promotion 
Until the end of 2017, FE Credit and HD Saison focused on promoting and introducing consumer credit 
products to customers through the POS network and retail partners that have signed cooperation contracts. 
However, with the emergence of partners providing intermediary payment services and online payment platforms 
and e-wallets, the finance companies are tending to gradually shift marketing activities through platforms. linking 
and reducing targeted marketing campaigns via POS as before. According to the results of interviews with 
professional officials of the finance companies, sales promotion activities were implemented by the finance 
companies during 2014-2019 including: POS, DSA, Telesales, SMS , magazines, headquarters and affiliates, 
media, Website, and Mobile APP (FE FE only), other promotion programs. Newly joined finance companies such 
as SHB Finance and MCredit are also implementing these programs. 
3.2.1.5. Current situation of lending interest rates of finance companies under commercial banks 
Depending on the policy of each financial company, the lending interest rate is either published 
according to the basic consumer credit product or the interest rate announced by the consumer consumer 
credit products. Lending interest rates of the finance companies range from 29.99% -64.99% / year. Thus, 
compared with the interest rate for individual customers of some parent commercial banks for the purposes 
of buying houses and cars with the lending interest rates ranging from 12% -14% / year, the target credit 
interest rate is Use rate is quite high compared to the lending interest rate of commercial banks. Currently, 
most finance companies have not implemented online lending products, so there is no clear difference in 
interest rates of traditional lending products and online lending products. 
3.2.2. The situation of consumer credit quality management of the finance companies in Vietnam 
3.2.2.1. Actual situation of credit risk management model 
Currently in Vietnam, a popular consumer credit risk management model that has been chosen by 
the finance companies is a risk management model similar to the centralized risk management model of domestic 
commercial banks, in which the model has a clear separation of risk management functions and business 
functions. The following is a typical consumer credit risk management organization structure of the finance 
companies built to ensure the quality of consumer credit: Member Council, Risk Management Committee, Board 
of Directors control, Executive Board, Credit Risk Council, Risk Management Division, Legal Department, 
Agency or Internal Control Department, Internal Audit Department. In terms of operational history and annual 
financial indicators, FE Credit and HD Saison are currently two finance companies that have implemented 
consumer credit risk management organization models. use professionally and effectively, in accordance with the 
model and common risk management policies of the parent bank. For finance companies in the early stages of 
business establishment and implementation such as MCredit and SHB Finance, immediately deploy a professional 
risk management model with full of specialized functional units such as FE Credit. and HD Saison is not the best 
choice. However, with the development strategies of SHB Finance and Mcredit, both towards the Top 5 safe and 
effective consumer finance companies, these finance companies are in the process of completion and 
standardization of in-depth risk management model in which strong investment in systems and resources for 
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successful implementation of risk management projects is indispensable. 
3.2.2.2. Actual situation of credit policy, credit process 
 Credit policy 
For the finance companies, credit policies or credit risk management policies are issued annually by 
the Board of Members according to the same standards as the parent commercial banks. The purpose of 
issuance is to guide credit operations at finance companies, to agree on basic principles to identify, measure, 
monitor, control and minimize credit risks for the loan portfolio. and each loan, assigning tasks and defining 
roles and responsibilities of units at the finance companies in credit risk management. With an effective 
safety development strategy, credit policies of the finance companies are also built to ensure that consumer 
credit development is accompanied by strict control of credit limits for customers. Bank, the authorities 
decide in credit activities and monitor the capital adequacy ratio continuously and promptly with adjustments 
in the lending scale to ensure the capital adequacy ratio as prescribed by the State Bank. 
 Credit processes 
In general, the consumer credit process of the finance companies is often simpler than the credit 
process of commercial banks stemming from the nature of the loan and the borrower. According to the 
results of interviews with the experts of the finance companies and information from the websites of the 
finance companies, the standard credit process of typical finance companies such as FE Credit and HD 
Saison is applying to customers including 5 steps including: Loan information consultancy - Collecting loan 
documents - Loan evaluation and approval - Disbursement - Tracking loans and loan recovery. With regard 
to the requirement of compliance with the credit pr
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