Credit information service agencies in the United States are all private credit information agencies (or private credit information agencies) independent of the government, and they are credit information service entities established in accordance with the modern enterprise system and operating in accordance with the principle of marketization.
American credit service agencies have some obvious characteristics. From the perspective of institutional composition, it is mainly composed of private and corporate investments. Their information comes from a wide range of sources, not only from banks and related financial institutions, but also from credit associations and other associations, finance companies or leasing companies, credit card issuing companies and commercial retail institutions. And the information content is comprehensive, not only collecting negative credit information, but also collecting positive information. In addition, these institutions provide credit information services to the whole society.
When it comes to credit reporting, it will inevitably involve the law. American credit information legislation began with a series of problems caused by the rapid development of credit information industry in the 1970s, and went through a process of development and standardization. So far, the United States not only has a relatively perfect credit legal system and government supervision system, but also has formed an independent, objective and fair legal environment with the development of market economy. The government is basically outside the social credit system, mainly responsible for legislation, justice and law enforcement, and establishing a coordinated market environment and market order. At the same time, it has become the rating object of commercial credit information companies, which ensures that credit information companies can ensure their independence, neutrality and impartiality. The development of credit information industry in Europe mainly adopts the government-led model, also known as the public model or the central credit registration model. This model is based on the "Central Credit Registration System" established by the central bank and the social credit system of folk credit institutions. Its credit information system consists of two parts. Part of it is managed by central banks, mainly collecting bank credit information with a certain amount or more, with the purpose of serving the supervision of central banks and the credit business of commercial banks. The other part is composed of market-oriented credit reporting agencies, which are generally engaged in personal credit reporting business.
Europe's legislation on credit reporting stems from the protection of data and personal privacy, so compared with the United States, Europe's laws on personal data protection are stricter. 1995 10, the European parliament passed the EU personal data protection plan, which is the first public law in the EU involving personal credit reporting. The legislative purpose and basic principle of this law is to strike a balance between protecting human rights and opening up data. In February, the European Union issued the second data protection guide, 1997. According to the laws passed by the European Parliament, EU countries have perfected their own legal systems of credit management.
The difference between the European government-led credit reporting model and the American market-oriented model is reflected in three aspects: the credit reporting service agency is established as a department of the central bank, not initiated by the people; Banks need to provide relevant credit information to the credit bureau according to law; The central bank undertakes the main supervisory function. Japan's credit information system is obviously different from that of the United States and western European countries, and adopts the membership credit information model, which is mainly due to the great influence of Japanese trade associations in Japan's economy. In this mode, the trade association is the main body of establishing the credit information center, which provides a platform for the members of the association to exchange credit information between individuals and enterprises, and realizes the purpose of collecting and using credit information through the internal credit information sharing mechanism. Under the membership mode, members are obliged to provide credit information of individuals or enterprises held by members to the Association Information Center, and the Association Credit Information Center is limited to providing credit information inquiry services to members of the Association. This kind of association credit center is not for profit, but only charges costs.
At present, Japan's credit reporting agencies can be roughly divided into three categories: banking system, consumer credit system and sales credit system, which correspond to banking association, credit industry association and credit industry association respectively. Members of these associations include banks, credit card companies, guarantee companies, other financial institutions, commercial companies and retail stores. The credit service of the three major industry associations can basically meet the needs of members for the collection and review of personal credit information. For example, the Japan Banking Association established the National Bank Personal Information Center. The information in the information center comes from member banks, which require individuals to provide real personal credit information when signing consumer loan contracts with individuals. These personal information centers are responsible for collecting credit information of consumers or enterprises.
At the same time, there are some commercial credit companies in Japan, such as Imperial Data Bank, which has the largest corporate credit database in Asia, with 4,000 listed companies and 2.3 million unlisted companies.
Consumer credit information in Japan is not completely open, but is exchanged among members of the association. In this regard, there was no clear legal provision before, but before the bank issued credit, the borrower needed to sign a contract allowing him to disclose his personal information to other banks. In addition, the internal regulations of Japanese trade associations also play a very important role in credit management activities.