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贷款人关联责任制度在消费金融市场较为发达的国家或地区受到广泛关注,并在世界范围内形成宽严不同的三个层次,即以英国为代表的贷款人连带责任、以美国为代表的抗辩延伸制度以及以欧盟指令为代表的贷款人补充责任。对于正处于消费信贷市场发展初期的我国而言,刺激消费与消费者保护必须兼顾。基于这样的考虑,我国未来不妨借鉴美国创设的抗辩延伸制度来作为维护消费金融可持续发展的法律保障措施之一。
The lender-affiliated liability system has been widely concerned in the more developed countries in the consumer finance market and has formed three different levels of strictness around the world, namely, the joint responsibility of lenders represented by Britain, the defense represented by the United States Extension system as well as the European Union directives represented by the lender to supplement the responsibility. For our country, which is in the early stages of the development of the consumer credit market, stimulating consumption and protecting consumers must be balanced. Based on this consideration, our country may wish to draw lessons from the extended defense system created by the United States in the future as one of the legal safeguards for the sustainable development of consumer finance.