Current-law scope and cautions
- The State Council Regulations on Non-Bank Payment Institutions took effect in 2024 and are implemented by PBOC rules.
- Customer reserve funds are subject to centralized custody/deposit requirements and may not be misappropriated.
- Do not invent a universal “net assets to customer reserves ratio” without checking the current implementing rule and institution category.
Use: This is a screening/estimation tool, not a legal opinion. Confirm the latest primary authority, regulator practice, local rules and transaction documents before acting.
