Legal Analysis on Whether 'Unbundled Loans' Constitute Predatory Competition

Based on relevant information retrieved, this article analyzes whether “Unbundled Loans” constitute predatory competition from the perspectives of legal compliance and market competition.

It should be noted first that I was unable to find specific public information about the company “Guoxia Technology”. However, from the perspectives of financial regulation and anti-unfair competition, I can analyze the business model of “Unbundled Loans”:

typically refer to loans provided by financial institutions without requiring customers to purchase other financial products or services. The opposite practice is , which forces customers to purchase insurance, wealth management products, funds, etc., while taking out a loan.

According to regulations issued by the China Banking and Insurance Regulatory Commission (CBIRC) and other authorities, the following actions are deemed non-compliant [1]:

Non-Compliant Practice	Specific Manifestations
Loan-Deposit Linkage	Making deposit a prerequisite for loan approval
Mandatory Bundled Sales	Forcing customers to purchase insurance, wealth management products, funds, etc., when granting loans
Fee Charging Tied to Loans	Collecting fees through unreasonable intermediary services

From a legal perspective,

[1]. Regulators explicitly require that:

• Enterprises shall not be forced to purchase insurance, wealth management products, etc., during credit approval
• Products and services shall not be bundled against customers’ will

According to Article 2 of the Anti-Unfair Competition Law [2]:

Business operators shall, in their production and business activities, abide by the principles of voluntariness, equality, fairness, and good faith, comply with laws and business ethics, and participate in market competition fairly.

If “Unbundled Loans” are provided on a voluntary and equal basis and do not involve dumping at prices below cost, they

.

• Pricing Below Cost
  : Providing loans at prices significantly below cost, disrupting market order [3]
• Price Wars
  : Competing to lower interest rates, resulting in “floor-level rates” [3]
• Cross-Subsidization
  : Subsidizing losses from lending business with profits from other businesses

Judgment Dimension	Compliant Practice	Potentially Non-Compliant Practice
Interest Rate Pricing	Reflects capital cost and risk cost	Significantly below cost
Sales Method	Voluntary choice	Mandatory bundled sales
Market Competition	Differentiated services	Homogeneous price wars

The banking industry is currently facing the issue of “involutionary competition” [3]:

• Consumer loan interest rates once generally fell below 3%, with some products offering rates starting with “1”
• “Floor-level rates” have emerged on the lending side, deviating significantly from policy rates
• Pressure from narrowing interest margins continues to mount

Regulators have taken multiple measures to rectify industry irregularities [3]:

• The Guangdong Banking Association released the “1+3+N” institutional framework
• Multiple banks have held promotional meetings against “involutionary competition”

; instead, they are a compliant practice that meets regulatory requirements. To determine whether such lending involves predatory competition, attention should be paid to the following:

1. Rationality of Pricing
   : Whether the loan interest rate is below cost and whether it leads to unfair price wars
2. Compliance of Sales Methods
   : Whether the principle of customer voluntariness is followed
3. Market Order Disruption
   : Whether it causes unfair competitive harm to other business operators

: If Guoxia Technology is indeed engaged in lending business, it should ensure that:

• Loan interest rates are priced rationally to cover costs and risks
• All regulatory rules for lending business are strictly implemented
• It avoids participating in predatory price wars within the industry

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[1] Notice of the China Banking and Insurance Regulatory Commission on Regulating Credit Financing Fees (http://www.cbirc.gov.cn)

[2] Anti-Unfair Competition Law of the People’s Republic of China (http://www.npc.gov.cn/npc/c2/c30834/202506/t20250627_446247.html)

[3] Xue Hongyan: The Banking Industry Sounds the Trumpet Against “Involution” (https://finance.sina.cn/zl/2025-08-01/zl-infimwyy8288607.d.html)