文：David Thomas 唐明达 / 翻译：强涛

都发生了什么？

2016年4月至5月，澳洲主要银行均宣布收紧对海外人士购房贷款的审批。这一系列的举措毫无意外的引发了公众的忧虑，并遭到了批评。尽管澳洲声明“澳大利亚商业开放”，但该调整仍然反映出了澳洲金融机构对外国投资根深蒂固的抵触情绪，尤其是针对中国的投资者和买家。一些评论人士预测来自中国购房者的贷款申请将始终无法获批，从而造成地产市场毁灭性的结果，然而正是中国买家极大的推动了地产市场特别是公寓楼花的繁荣。

客观的讲并不是所有银行都完全停止了针对外籍人士或海外收入的贷款业务。比如，NAB宣布针对外籍人士的贷款比例上限为房产估值的60％，同时只承认最多60%的海外收入。ANZ将不再向纯海外收入的外籍人士发放贷款，而且也采取了更严格的文件要求。而Westpac以及子公司都将不再向外籍人士发放贷款。

为什么会这样？

监管政策变化背后的诱因来自于多个方面。澳洲在经受住了全球金融危机之后，房地产市场稳步增长的需求推动了房屋供给的增加，地产开发商获得了更多的建造许可，开发和销售了更多的项目。史无前例的低利率以及利率的持续下行，和对市场持续繁荣的预期，使得越来越多的购房者和投资者入市并掀起了房地产市场的购买热潮。银行也借由买家的大量涌入增加了借贷资金以抢占自己的市场份额。这些都使得房价达到了前所未有的高度。

然而这种趋势已经大大放缓。疯狂的购买导致了一些弊端甚至欺诈，一定数量的海外贷款申请人被发现提供了伪造和虚假的文件。一些投机者在支付10%的预付款用以购买楼花之后，根本没有打算收房却直接将楼花转手而获取利益。作为银行的监管机构，APRA已经向银行施压要求严管审批流程，剔除此类贷款申请。与此同时政府也通过提高FIRB申请费，印花税和限制外籍人士可购买房屋类型等措施来使市场降温。

好事还是坏事？

没有人想要看到这些贷款人因为无法如期还款而带来的巨大风险，因此毫无疑问银行应该严格限制虚假申请和加强审批流程管理，而且也可以使处于失控危险中的市场得到一个调整的机会。

然而这样的举措就像在释放明确信号，澳洲正在向海外投资关上大门。这些政策调整被曲解后出现在不同的中文媒体和媒介中，宣称银行完全停止对外籍人士发放贷款，引发了公众的焦虑，不满和抵触情绪。

这揭示了什么？

近来的事件揭示了一个广泛值得考虑，探讨和解决的问题，那就是商业文化和经营方式的差异。中澳银行机构间的环境，文化和架构截然不同，规则，法规和流程也差异巨大。众所周知，澳洲银行以严格的申请和审批流程著称，特别是对难以认可和评估的海外资产。申请者需要就一个看似简单的要求而提供大量的文件。而中国银行的流程则灵活的多，使得申请能够得到快速和顺利的审批。

还有一个需要考虑的是就业差异和这些对贷款和信贷申请的影响。澳洲银行要求所有申请者提供工资单以支持他们的信贷和贷款需求，然而在中国，要求提供工资单并不常见，因为富裕的中国投资者和私营企业主有多元化的收入来源，比如国内和国际的投资组合收益。我们的经验证明，双方因为都不了解对方的流程和出发点，所以造成彼此之间的不满。中国申请人不理解为什么需要提供如此大量的文件，而澳洲银行因为申请人不愿或者无法提供这样的信息而倍感无奈。

我们要做什么？

从近期的事件来看，期待银行为了某类客户而改变流程是不切实际的，然而在灵活性上是有待提高的。如果澳洲希望继续利用涌入的中国投资和亚洲世纪所带来的机遇，我们的银行机构必须以创新的方式来解决这些问题。

对管理层而言，应该接受更多的培训与学习去了解中国的监管架构，以及为什么与我们不同，何处不同。也许是时候去突破性的思考用于评估贷款人资格、真实性及还款能力的方法。一种可行的方法是使用澳洲银行在中国的分支机构。很多澳洲银行在中国都设立了分支机构以推广业务，但并没有开展什么评估贷款申请人的工作。有没有这样一种可能性，调配具有语言和文化背景的本地员工去评估这样的申请，核实资料并与申请人面谈，从而建立对申请人的全面了解。

从一线员工来讲，也需要接受更多的培训与学习，从而可以向讲中文的客户介绍和说明银行的流程，就像他们为讲英文客户提供的服务一样。

当然，这并不只是澳洲银行的责任。中国投资者需要明白，恰恰正是严格的制度保护了市场，银行以及客户，才使得澳洲成为安全和有利可图的投资市场。

我认为最近的这些事件让我们对于下一步中澳之间持续的经济往来动向有了一些感知。文化差异将永远是阻碍国际业务发展的重要因素之一，因此需要双方共同推动去更好的了解学习彼此之间的差异。一旦房地产市场恢复到正常水平，我们的银行应当采取更加创新和不同的思维方式去思考如何继续借助中国在澳投资的东风。银行业将成为其他机构，商业和社会团体的标杆，依托思维模式的调整与改变，更加灵活的经营方式，在迎接亚洲世纪的机遇和挑战中发挥领导作用。

唐明达 （David Thomas）

思环顾问公司(Think Global Consulting) 创始人，澳大利亚中国中小企业协会(ACSME)会长，著名的金砖四国事务专家，同时也是一名具有远见卓识的演讲家和思想领袖。 唐明达30年来活跃于伦敦、香港和悉尼商界，致力于分析、建立与促进发达国家和新兴国家之间的商业和投资往来，积累了丰富的经验并建立了广大的人际网络。

A new era for Australian Banks?

What happened?

In April and May 2016, all major Australian banks announced that they had tightened the rules for lending to foreign nationals buying residential properties. The succession of announcements has undoubtedly caused much alarm across the community, with many claiming that despite Australia being ‘open for business’, these changes reflect entrenched anti-foreign investment sentiment, particularly towards Chinese investors and buyers, in our banking institutions. Some commentators have predicted that applications made by Chinese investors and buyers, who have largely been driving the property market boom particularly for off-the-plan apartments, will be consistently denied, resulting in a devastating crash in the property market.  

To be fair, not all banks have completely halted foreign lending. For example, NAB announced that it will only lend up to 60% of the value of the property to foreign nationals and recognise only 60% of their income earned offshore. ANZ will no longer grant loans to borrowers who generate 100% of their income offshore and will introduce stricter documentation requirements. Whilst Westpac and its subsidiaries say they will no longer lend to foreign nationals.

Why did it happen?

The reasons behind the regulatory changes are multi-faceted. After Australia weathered the Global Financial Crisis, a gradually increasing demand in the property market created an impetus to increase supply. This saw a flurry of activity amongst property developers, with more approvals, more projects and the sale of more stock. Combined with record-low and falling interest rates and an expectation that the market would continue to rise, more and more buyers and investors entered the market creating a buying frenzy. In addition to property prices reaching unprecedented heights, the banks also increased their lending to capitalise on the influx of buyers and investors and to capture their market share.

This, however, has considerably slowed down. The buying frenzy has resulted in some malpractice and even fraud with numbers of foreign loan applicants being found to have provided forged and fraudulent support documentation.  In addition, it has been found that many speculators who purchased off-the-plan properties were only paying a 10% deposit with a view to transferring them to other buyers with no intention of completion. APRA, the banking regulator, has put serious pressure on the banks to clamp down on their approval processes to squash such applications. In addition, the Government has slowed things down by changing the rules under FIRB to limit the type of properties foreign nationals can purchase and the increasing application fees and stamp duty they must pay.

Is it good or bad?

It is unquestionable that the banks needed to clamp down on fraudulent applications and tighten up their approval processes. It is in nobody’s interest to encourage disingenuous buyers and investors who are at serious risk of defaulting on their loans. Also, it brings about a much-needed pause in the market that was in danger of getting out of control.

However, announcements like this are perfect fuel to the fire that Australia is closing its doors to foreign investment. These announcements have been misconstrued and translated to the Chinese (via media and other channels) that the banks have completely halted all lending to foreign nationals, creating much animosity, anxiety and frustration.  

What has been revealed?

These recent events have exposed a broader issue that needs to be considered, addressed and tackled – major differences in business culture and practices. The environment, culture and framework of Chinese and Australian banking institutions are vastly different. Their approaches to rules, regulations and approval processes, as well, differ greatly. Australian banks are notorious for their rigorous application and approval processes, particularly in regards to their inability to recognise and value overseas assets. Applicants are also obliged to supply huge amounts of documentation for a seemingly simple request. Whilst processes in Chinese banks are more flexible so applications are often approved swiftly and seamlessly.

There is also a need to consider employment differences and the effects these have on loan and credit applications. Banks in Australia require all applicants to supply pay slips to support their credit and loan requests. However, in China, providing employees with pay slips is not as common as it here. It also does not help that many wealthy Chinese investors and entrepreneurs are self-employed and generate their income from a variety of sources such as other domestic and international investment portfolios. It has been our experience that both sides do not understand one another’s processes and the reasons behind them, creating immense frustration – Chinese applicants do not understand why they need to provide huge amounts of supporting documentation and Australians get frustrated with their aversion and inability to provide such information.

What can be done?

It is unreasonable to expect banks to change their processes for one group of borrowers, especially in light of recent events, but there is a growing need for flexibility. If Australia wants to continue to capitalise off the influx of Chinese investment and the greater opportunities arising from the Asian Century, our institutions have to look at solving these issues in new innovative ways.

On an executive level, there needs to be greater education and training about China’s regulatory frameworks and how and why they differ to ours. Perhaps it is time for executives to think innovatively about the methods they use to assess a borrower’s eligibility, level of seriousness and commitment? One possible method could be the utilisation of their China branches. Many Australian banks have established branches in China with the aim of promoting Australia to local market but have very little to do with assessing loan applications. Could it be possible that their local staff (all with the necessary language ability and cultural understanding) could be mobilised to help assess such applications, verify the relevant documents and interview potential clients to establish the full picture?

And on a front-line level, staff need to have the education and training to better inform and advise Chinese-speaking customers about the bank’s processes, just like how they assist and advise their English-speaking customers.  

Of course, the onus is not just on Australian banks. Chinese investors need to understand that what makes Australia the safe and profitable investment market it is, is our stringent and strict regulations that protect the market, our institutions and their customers.  

I think these recent events have been a taste of what is to come as Australia and China continue to do business with each other. Cultural differences will always be one of the biggest obstacles in cross-border deals so there needs to be a concerted push to better educate both sides about these differences. Once the property market has returned to “normal” levels, I urge our banks to think differently and innovatively about how they can continue to ride the wave of Chinese investment into Australia. If they can do this, our banks could be the paradigm of change for our other institutions, businesses and communities to modify and adapt their mindsets, adopt more flexible practices and play a leadership role in embracing the opportunities and challenges of the Asian century.

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