Archive for: regulation in microfinance

Financially Inclusive Ecosystems: The Roles of Government Today

by Tilman Ehrbeck : Monday, February 6, 2012

Financial inclusion today is about financial markets that serve more people with more products at lower cost. The term “microfinance,” once associated almost exclusively with small-value loans to the poor, is now increasingly used to refer to a broad array of products (including payments, savings, and insurance) tailored to meet the particular needs of low-income individuals. Two separate but related developments have spurred this more holistic approach to financial inclusion. First, a growing body of research is demonstrating that poor people use and need a wide array of financial products, not just credit. Second, innovative lower cost business models—especially electronic and agent banking models—hold the promise of reaching unbanked populations with a fuller range of products better suited to their needs.

Different products present different risks and delivery challenges, and it is unlikely that a single class of service providers will effectively provide all the products poor people need. Financial products have delivery, intermediation, and risk mitigation challenges that often can be more efficiently managed through a number of specialized institutions acting together rather than one institution acting alone. Skill sets, capacities, and tools needed to deliver products on the liabilities side of a bank’s balance sheet are different than those needed to deliver products that fall on the asset side. As a result, businesses tend to develop specialties on either side of the balance sheet. Further, businesses providing the service to the end consumer are often not specialized in managing other parts of the value chain.

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SHGs for the Poor; MFIs for the Non-Poor

by Aloysius P. Fernandez : Thursday, January 6, 2011

SHGs (Self-help groups) need to return to their original fundamentals of being strong grassroots institutions and the market for credit needs to be segmented

The focus of concern in the recent past, and leading up to the Andhra Pradesh microfinance crisis, has been the risk to commercialized microfinance organizations or MFI-NBFCs. Very little has appeared in the media on the risk borne by the clients, until the reported suicides in October brought their risk squarely into the political domain. This post focuses on the risk borne by clients.

First I would like to distinguish between two groups of clients: The first group is the poor who need credit and other opportunities for livelihood activities to survive. The second group is not poor; their livelihood strategy largely includes non-farm activities but they cannot grow to meet their aspirations without access to credit even at market rates.

My position is that the poor need substantial investment, besides credit, for them to move beyond survival and increase their incomes.

This investment includes institutional support- like the self help groups (SHGs) at the base – which provides the poor with the space to set their agenda to support their livelihood strategy. The services required to support livelihood strategies of the poor and to build these participatory institutions like SHGs need subsidy.

In short, this requires a long term perspective.

I do not think the business model of the MFI-NBFCs, which is driven by venture/private capital, quick disbursements, weekly repayments, high profits and remunerations for senior staff, a focus on valuations and IPOs and a quick exit, is appropriate for this group. Short term credit at commercial rates cannot help improve lives of the poor.

In fact, this business model increases the poor’s risk, often beyond a level that they can bear.  The SHG model with links to banks (as it was originally conceived) is the appropriate strategy for this group.

Weekly repayments increase the borrowers risk and vulnerability to local power groups.  Incomes from agriculture are lumpy not weekly; incomes from animal or dairy farming are usually monthly.

In order to repay the MFI loans weekly, clients are forced into activities that can help them earn daily, like wage-labor, or push them into a cycle of multiple borrowing, where they have space to borrow from one and repay to another.

The second group, the non-poor, who cannot get credit from banks because they do not have land records or fixed assets to provide collateral, are better suited to be clients of MFIs.

This group does not have the confidence and skills required to negotiate with banks if they need credit for activities in the non-farm sector and do not have access to working capital from formal financial institutions.

The business model of MFIs can meet the needs of this group provided profit is not maximized to an extent where there is little difference between them and the moneylenders. Good governance of MFIs can play a greater role than regulation; but evidence indicates that good governance is in short supply.

The SHG model is not an effective model for fast disbursement of credit. Therefore, it is not appropriate for this second group which needs credit.

Risk and the official policy promoting inclusion 

Inclusion of the poor (the first group) into the formal financial system of the country involves considerable risks and costs on their part.

The SHG model was an attempt to lower this risk and costs for the poor by providing an intermediary institution which the poor managed. The banks that lent to them were satisfied even though the profits were low because their loans were categorized under “priority sector” lending and repayments far exceeded those from rural development programs in the past.

Between 2003 and 2008 the Reserve Bank of India (RBI) carefully managed India’s integration into the global financial system. Unfortunately the RBI did not take the same careful approach with the MFI-NBFCs in their rapid growth on the grounds that it was urgent to integrate the poor into the international financial sector.

Its focus was pushing the official financial system further into the interior on one hand and, on the other, a “hands off” approach as far as the MFI-NBFCs were concerned, encouraging them at most to self-regulate.

The MFI-NBFCs have not included the marginalized into the country’s financial system but instead included them directly into the international financial system which is not only inappropriate as a first step but raises the level of risk that clients have to bear.

Moreover, the emphasis on credit disbursement to SHGs increased when they were adopted by the Andhra Pradesh Government as part of its official strategy to mitigate poverty. Fortunately, high profits and remunerations were not part of the Government’s strategy.

The SHG Bank Linkage Model had grown till 2000 with adequate investment in building the institutional capacity. When it became part of AP state government policy in 2000, pressure was exerted by dedicated Government officers at the district levels to grow fast and achieve targets.

As a result, the quality of SHGs declined and their earlier emphasis on mobilizing savings, managing repayments and building a supporting environment for a livelihood strategy, considerably weakened.

Instead, SHGs were formed to achieve targets, with the wives of the Panchayat president and secretary dominating proceedings. They borrowed from banks and lent outside the groups at higher rates, at the cost of neglecting their own members.

Official reports focused on disbursements; corrective measures were taken to balance the spread of credit in areas where growth was slow. However, no investment was made to add value or to support increases in productivity and diversification.

Investment in institutions, the very essence of SHGs, was no longer a priority. Instead, the Government was in a hurry to disburse and increase financial inclusion.

Risk and interest rates

MFIs argue that high interest rates are justified because the risk of lending to small borrowers is high, the cost of delivery at the doorstep is high and finally the rates are far less than those of the private moneylenders.

However, high interest rates when offered by MFIs increases risk for the poor.

The State of the Sector report 2010 (N. Srinivasan) indicates that out of 60 MFIs which reported on profitability, six had ROAs over 7%; thirty five had ROAs over 2%.

In contrast the public sector banks in 2009 had average ROAs of 0.6% with the best being 1.6%, while the best private bank had ROAs of 2%. The yield on portfolio confirms this picture; in the case of 23 MFIs it was above 30 %(the highest being 41.29%).

The report also says that economies of scale have not led to lower interest rates or lower yields. This implies that MFIs maximized their profits and competition did not decrease rates as it was expected to.

The largest MFI recorded a 116% jump in net profit at Rupees 81 crores ($18 million) in the second quarter ending September 2010 as against the corresponding period last year.

The level of profit required to meet all costs, cover risks and expand operations is lesser than the level of profit required to meet all these costs and, in addition, attract venture and private capital, and pay salaries higher than the remunerations of the CEOs of the largest private banks.

What should be the interest rate? The figure of 24% is floating around in official circles. The problem is that the effective interest rates of MFIs are far from clear. There appears to be a difference of 5% to 10% between the rates as provided by the MFIs and the rates that emerge from an analysis of the books of clients.

MFIs also argue that the cost of credit from banks is high and that they should be allowed to mobilize public deposits if interest rates are capped. Interviews with clients show clearly that they do not have an idea of what they actually pay over and above the capital.  They are satisfied if credit keeps coming.

In fact interviews with those clients who had succumbed to the temptation of multiple borrowings showed clearly that they wanted to borrow from several MFIs to maintain a cash flow to cope with repayments as well as their expenditure. This increases their risk substantially. In contrast, interest rates of SHGs in Myrada stabilize after two years or so between 12% and 14%, which is about 3% -4% above cost of credit from banks.

Non-profit MFIs who do not pay high salaries but still pay adequately enough to attract experience and capital from banks manage to make a surplus at interest rates between 17% -19%, where the average cost of credit is around 9%-10% and annual growth rates are 40% -50%.

For-profit MFIs should be able to manage their affairs and attract sufficient capital (not venture capital and high valuations) by charging effective rates ranging from 15%-17% above the average cost of credit. This would enable them to charge interest rates in the range of 24% -29% instead of their current rates which are 20%-30% above the average cost of credit.

The poor in SHGs are able to manage interest rates of 12% -14%. They have also managed with interest rates higher than 14% in the initial period of group formation until they have built up their group’s common fund. In my experience, they can cope with interest rates of around 17%. The risk involved is manageable and the cushion provided by the SHG can help them tide over urgent needs.

The non poor in the second group can cope with higher interest rates levied by for profit MFIs but the rates should not exceed 30%.

Competition among MFIs has not reduced rates, neither has self regulation.

Interest rates, commissions, salaries, profits have to be regulated by the board of an MFI.  A decision by the Board to opt for an IPO will force management to focus on quarterly figures because the logic of financial markets dictates that it should.

This will further integrate the marginalized into the free market system increasing the risk of the clients who are particularly vulnerable.

SHG is not a good model for speedy disbursement of credit; but it is a good model for lowering the risks of borrowers as well as lenders. SHGs have savings which they use to cushion irregular cash flows; they are able to adjust to urgent and unexpected situations. Myrada’s analysis of its SHGs shows that their common fund increases year on year.

The SHG model, with lower interest rates and risk, is most appropriate to financially include the poor, while the product offered by for profit MFIs is appropriate for the non-poor who are in need of credit.

Aloysius P. Fernandez, Chairperson, National Bank of Agriculture and Rural Development (NABARD) Financial Services, India and Founder of Myrada; the views expressed here are personal.

For more information on the history of the SHG movement in India, click here.

A longer version of this post was published by Microfinance Focus on December 13, 2010.

This post is the next in a special blog series on the microfinance crisis in Andhra Pradesh, India. Over the coming weeks we’ll be featuring a variety of voices on the issues raised by this crisis and what it means for the future direction of microfinance. We welcome your participation in this discussion through comments.

Was SKS Ready for the IPO?

by Moumita Sen Sarma : Tuesday, October 12, 2010

This week, as I met several social investors in the Netherlands, inviting them to provide subordinated debt to Cashpor, a nonprofit MFI in North India, on whose Board I volunteer as Vice Chair, the discussions invariably veered towards SKS and its spectacularly successful IPO. What are its commercial, ethical, and regulatory implications?

It would be unfair to start without first acknowledging the tremendous achievement of SKS in pulling off a truly remarkable feat. Having known and served a very young and nascent SKS as a banker since 2004 and closely followed its growth, there is even a sense of pride in its achievement. But of course, that doesn’t take away from any of the uncomfortable questions surrounding it.

Without repeating those questions or proffering a not-so-original perspective, it may be interesting to instead look at why being a listed company for an MFI may be a far bigger practical challenge than ‘simply’ getting listed.  It’s particularly relevant now, as the next chapter of post-IPO SKS saga is being scripted, very unfortunately, as a courtroom drama.

This is not the first time in the history of Indian microfinance institutions that the Board has sacked its CEO nor will it be the last. Basix, one of the most respected MFIs, has had to part ways with its CEOs in the past, more than once. Though being Basix, it perhaps handled it in a very different manner. Without getting into propriety of the action of SKS’s Board in sacking its CEO, the events unfolding thereafter certainly raise the big question of public scrutiny that a listed company is subject to and how well the MFIs, even a trailblazing SKS, is geared to anticipate and deal with it.

Because of the heightened public and regulatory oversight, the rules of the game change dramatically once a company gets itself listed on the stock exchange. Individuals are also provoked into reacting very differently as a lot more is at stake, financially or otherwise.

Irrespective of the reasons, “sacking” of the CEO after an evidently spectacular spell may appear incorrect but the truth is that SKS would have easily got away it, had it not been a publicly held and listed company. But now, the amount of time and resource that it would have to employ to deal with the consequences of its actions would be enormous and would certainly detract from its core business of serving the unbanked.

While this incident, one may even argue, will only lead to better corporate governance and transparency, the question really is whether our MFIs are truly ready for an IPO yet. And for now, the answer unfortunately is a ‘no’.

With an already nervous RBI (Reserve Bank of India) and Ministry of Finance wary of the path being charted out by the Indian MFIs and now SEBI (Securities and Exchange Board of India), the market regulator asking SKS unpleasant questions, it’s perhaps a time to pause and introspect. In the end, shouldn’t the true measure of an MFI’s success be when people on the street instead of asking in surprise “So is microfinance really that profitable?” as they did in the wake of SKS IPO, ask rather “Is microfinance really that impactful?” We need to shift our focus away from the means and on to the end. And that remains as big challenge as ever.

–Moumita Sen Sarma

Watch this space for a new post every week on the SKS IPO. Next week we feature Chuck Waterfield.

This post is the third in a special blog series on the SKS IPO. Over the coming weeks we’ll be featuring a variety of voices on the issues raised by the IPO. We welcome your participation in this discussion through comments.

The New CGAP Financial Inclusion Regulation Center

by Jennifer Chien : Thursday, August 19, 2010

After over a year’s worth of research and preparation, I’m excited to announce the launch of the new Financial Inclusion Regulation Center on CGAP’s website this week.

As the microfinance industry has evolved in recent years to encompass a number of different types of institutions offering a wide range of financial services to the poor, enabling regulatory environments have become increasingly important.

However, it is often difficult to find information on financial inclusion laws and regulations. In fact, until I began working on this project, I had not fully realized how difficult it can be to find any accurate and timely legal information in developing countries. I’ve come to appreciate the importance of the freedom of legal information, particularly when that information is available online, easily accessible, and reliable.

The Regulation Center includes detailed profiles of nearly 30 countries across the globe. These profiles provide an overview of the financial inclusion regulatory environment, and a selection of laws and regulations related to microfinance and banking, branchless banking, and consumer protection for each country. Each law or regulation is briefly summarized, and a copy of the legal text is provided. Links to government regulatory bodies and recommended reading related to financial inclusion are also included in the country profiles.

My hope is that the Regulation Center serves as a tool for the industry, and is shaped by the industry. The main value that this unique resource provides is in gathering in one place an extensive collection of legal texts and objective information on financial inclusion regulation and sharing this information across the globe to facilitate comparative analysis. The Regulation Center is meant to serve as an expanding repository that will only grow through industry contribution and input from those on the ground. Therefore, we highly encourage the use of links placed throughout the site that allow users to submit information on new regulatory developments related to financial inclusion.

Jennifer Chien

Dakar Dispatch: Mobile money and financial inclusion

by Sarah Rotman : Monday, June 21, 2010

CGAP and the Alliance for Financial Inclusion (AFI) just cosponsored the first branchless banking seminar for Francophone Africa in Dakar. The seminar was for high-level policymakers, and featured delegations from Burundi, Cameroun, Côte d’Ivoire, Democratic Republic of Congo, Madagascar, Mali, Mauritania, Niger, and Sénégal. The first day of the two-day seminar was also open to the private sector and included representatives from mobile network operators, banks, MFIs and technology providers.
 
This seminar was a timely one given the flurry of activity going on in the region. Orange Money is now active in Côte d’Ivoire, Sénégal and Mali. MTN Mobile Money is available in Côte d’Ivoire and Benin. Société Générale is on the verge of offering some type of branchless banking service in Sénégal. Zain is preparing to launch Zap in Burundi.  All three mobile operators are knocking on the central bank’s door in Madagascar. And there are three technology companies (in Sénégal, Côte d’Ivoire and Burkina Faso) that have been given the approval of the regional central bank (the BCEAO) to function as electronic money issuers. It is clear that the subject of branchless banking is on the minds of policymakers in Francophone Africa.
 
The last session of the seminar was a forum for debate among policymakers regarding specific issues of branchless banking which had been discussed and presented over the course of the seminar. The questions guiding the debate were:

  • Does financial regulation and financial inclusion always go together?
  • Should regulators be one step behind market innovators?
  • Are the objectives of AML-CFT and branchless banking always compatible?
  • Are non-bank based regulatory models more advantageous to clients than bank-based regulatory models?

For most of the questions, the policymakers were somewhat divided. Some people saw a conflict between financial regulation and financial inclusion, while others were convinced that the two always went hand in hand. Some participants eloquently argued that policymakers should not “regulate simply for the sake of regulating” and therefore should respond to innovations in the market.  But others argued that there was danger in trailing the market. Most participants were confident that the objectives of AML-CFT were compatible with branchless banking, but doubt remained in a few specific cases. Finally, while some policymakers were willing to argue that non-bank based regulatory models may be more advantageous for clients (in terms of ease of access and use), many were not comfortable with the model unless a bank had a stronger presence.
 
The regulatory questions around branchless banking are often not black and white, but usually gray. What is quite clear, however, is that the private sector is raring to go in many Francophone African markets, and policymakers need to be informed now more than ever on the appropriate ways to respond. The recent seminar in Dakar was hopefully one step closer to getting there.

Microfinance in 2010

by Alexia Latortue : Monday, May 17, 2010

Once a year, CGAP’s membership and governance body, the Council of Governors, meets to set CGAP’s broad policies and strategic direction, provide inputs to our annual workplan and budget, and debrief one another on the latest trends in financial inclusion. That meeting is underway this week in Nairobi, Kenya, and began with remarks from acting CEO Alexia Latortue on the state of the industry and how CGAP has changed since its inception in 1995.

2010 marks CGAP’s 15th anniversary, providing an opportunity to reflect on the state of microfinance today and CGAP’s role within it. Is microfinance a mature industry, or one still experiencing growing pains? Are the ripples of the financial crisis still spreading, and what new forces are shaping the direction of microfinance in years to come?

Today, there are many more microfinance clients than there were in 1995.  Between 2004 – 2008, the average compounded growth rate of microfinance institutions (MFIs) reporting to the MIX was 43%.  There are now between 100 and 150 million clients. What breakthroughs will help us reach much more massive scale responsibly?  How can providers be ambitious about growth objectives while staying focused on the quality of client services?

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Should big MFIs be prudentially supervised even if they don’t take deposits? Are they “too nice to fail”?

by Xavier Reille : Wednesday, April 14, 2010

In a recent post David Roodman questions the role of funders and particularly lenders in the microcredit delinquency crises in Bosnia, Morocco, Pakistan, and Nicaragua. The exuberant growth seen in these four countries was indeed fuelled by lenders eager to place capital.  A Bosnian MFI manager was blunt: “Some funders started lending to second and even third tier MFIs.  They just dumped the money; they did not look at the market at all.” Why did these lenders take such risks?

Microfinance investors, asset managers, and maybe rating agencies have tended to underestimate MFI risk for a long time.  But maybe regulatory issues form part of the problem?

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Towards a Definition of Responsible Finance: Day One of “Responsible Finance: Making it Work in Microfinance”

by Rafe Mazer : Tuesday, April 13, 2010

CGAP has been hosting a two-day online Virtual Conference “Responsible Finance: Making it Work in Microfinance” on April 12-13. The event is bringing together MFIs, policymakers, NGOs and individuals from across the world for a rapid-fire online debate and discussion.

Day one of the conference focused around the question “what is responsible finance, and why is it needed?” and featured guest moderators from four continents and nearly 300 participants commenting and following along with the debate. Hot topics of discussion included:

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