Legal analysis: (1) Clearly define the path of hidden debt generation: since the "No.43 Document" and the new budget law in 214, local governments have used the city investment and financing platform and PPP to expand their debts in violation of regulations. In the process of cooperation with local governments, bank insurance institutions have also increased local government debts or implicit debts in a variety of direct or indirect, obvious or detour ways. Some bank insurance institutions require or accept commitments or letters of guarantee from local governments or relevant departments, and require or accept after-sale leaseback and after-sale repurchase; Some require to provide financing with expected land transfer income as the source of debt repayment funds for enterprises. In the fields of PPP, industrial guidance fund, government purchasing services, etc., implicit liabilities are added in the form of promised principal repurchase and promised social capital loss. "Circular 15" clearly defines and prohibits the illegal increase of local implicit debt in the financing of platform companies and PPP entities, and controls the increase of implicit debt from the source and path. (2) Clear criteria for judging implicit debt platform companies: Circular 15 requires banks and insurance institutions to use the monitoring platform of the Ministry of Finance to check whether the counterparty is a platform company involved in implicit debt. For customers who do not involve the hidden debts of local governments, bank insurance institutions grant credit according to the principle of marketization. For customers who bear local implicit debts, bank insurance institutions shall not provide liquidity loans or financing with the nature of liquidity loans, and shall not provide supporting financing for their participation in local government special bond projects. At the same time, new project financing and projects under construction are allowed to continue financing. The financing of new projects has been reported to the people's government at the same level by the platform company for written examination and confirmation, and the bank insurance institution takes this confirmation as the premise of financing approval. Project financing under construction refers to the necessary projects under construction, which continue to provide project financing without expanding the construction scale. (3) Clarify the requirements for orderly withdrawal of hidden debts in stock: Circular 15 encourages banks and insurance institutions to provide debt financing in a market-oriented way in compliance with the premise of taking risks and taking responsibility for their own profits and losses. Its basic principle is to give priority to solving debts with short term, wide stakeholders, high interest rate and strong expectation of rigid payment; The basic tool is to extend the term appropriately and use the financial instruments of enterprise turnover convenience.

Legal basis: Law of the People's Republic of China on Commercial Banks

Article 6 A commercial bank shall protect the legitimate rights and interests of depositors from any unit or individual.

article 7 when conducting credit business, a commercial bank shall strictly examine the credit standing of borrowers, implement guarantee and ensure the timely recovery of loans. Commercial banks recover the principal and interest of loans due from borrowers according to law, which is protected by law.