Some microfinance policy considerations for the Reserve Bank of India beyond the Malegam committee report.
By Sasidhar Thumuluri , Habitat for Humanity International
“No central bank can be a bank which moves with the flavor of the moment……(for making) any changes (in regulation) it has to look at (those changes) cautiously and think about what the long term implications are…” Prof. Raghuram Rajan in an interview with NDTV
The ongoing microfinance regulatory policy formulation exercise should not be a missed opportunity. The resulting framework should enable greater financial inclusion and lead to a more integrated financial system.
Mr. Yezdi Malegam and his high profile committee will adorn a special place in the annals of Indian microfinance. The report produced by this Reserve Bank of India (RBI) board committee is touted as a major milestone and some even called it a savior of the sinking sector. It has received as many accolades as criticisms. The microfinance community at large welcomed some key recommendations that would go a long way in offering much needed legitimacy to microfinance institutions (MFIs) and subject the industry to higher levels of accountability and disclosure standards. Serious concerns were however raised almost in unison with respect to provisions that could pose practical challenges of enforcement, stifle competition, raise entry barriers and limit customer choice. RBI is currently seeking public opinion on the report and will hopefully take these reactions into account before declaring the rules of the game.
The purpose of this article is to offer some thoughts over and beyond Malegam committee’s work as the RBI prepares to formulate the policy framework that would define the future course of the sector. Given the time constraint and circumstances under which the committee delivered the report it has done a commendable job but, understandably, it had a limited mandate or opportunity to look into the issue more comprehensively. RBI should nevertheless consider long term implications while formulating the policy that would enable greater financial inclusion and lead to a stronger well integrated financial system. Same applies to the finance ministry which is about to table new microfinance bill in the parliament.
Following suggestions may be considered in addition to the Malegam committee report and other expert opinions:
1. Include a wide spectrum of basic financial services in microfinance definition:
Poor people require access to all kinds of financial services just like everybody else. Thus far the emphasis has been on frequent cash flow income generation loans primarily offered through group mechanisms. Money is fungible and these loans tend to be diverted for consumption and asset building many a times in the absence of suitable loan products. A good policy environment should enable financial institutions to design and deliver customized products that fit varied financial needs of the target market. Hence it is important to recognize this fact and keep in mind credit requirement for other vital needs such as housing, agriculture, education, health, water & sanitation etc., as well as the unmet need for savings, remittances and insurance services while ascertaining the boundaries of microfinance regulation in order to effectively address the challenge of financial inclusion. Mobile banking promises great potential in achieving scale efficiently. Safely leveraging the ever expanding mobile phone network in credit delivery, insurance distribution and money transfers may also be explored.
2. Allow the establishment of small finance banks:
Raghuram Rajan committee on financial sector reforms made this recommendation back in 2008. This has also been a long standing demand of certain leading players involved in financial inclusion initiatives. Local Area Banks were a step in the right direction but met with limited success apparently due to lack of regulator’s interest in pursuing the idea further. More than 10 MFIs in the country manage over Rs. 500 crores each in assets with equity base of anywhere between Rs. 50 crores and Rs. 2000 crores.
By allowing limited service small banks with minimum capital requirement of Rs. 50 crores would not only accelerate the provision of much needed savings services to the unbanked clientele but also significantly and sustainably reduce cost of funds, and improve operating efficiency for MFIs, in turn reducing borrowing rates for end-clients. Moreover, since the Malegam committee has made it loud and clear that MFIs must be supervised more closely by the RBI, small microfinance banks in addition to the committee recommended NBFC-MFIs would make a decent portfolio for the Reserve Bank to merit a separate supervision wing with adequate resources to enforce policies more effectively rather than by just adding a new category under NBFC group which may or may not have dedicated resources necessary to regulate the sector. On the top if it, RBI regulated “banks” enjoy greater credibility and are less likely to be subjected to knee-jerk political actions.
3. Allow NBFC MFIs to offer business correspondence services for commercial banks:
MFIs together deliver credit and, to a limited extent, insurance successfully to over 20 million households in India today, of which NBFC MFIs make up for roughly 85%. Those MFIs that would not qualify to be small banks (per the above suggestion) may be allowed to offer core banking services on behalf of commercial banks via business correspondence model. Given high potential for outreach through an extensive network of field force these MFIs make perfect partners for taking banks to the last mile. This would not only enable non-bank MFIs to offer savings and other banking services to the unbanked but also help enhance banks’ oversight on MFI activities.
4. Bring all sizable private microfinance activities under one umbrella:
Malegam committee apparently left out a large number of NGO MFIs and small NBFCs from the purview of its recommendations. If implemented the recommended framework would leave ample room for recurrence of situations like those led to the recent turmoil or create regulatory confusion at the least. It is important to define rules for all significant players through a common policy regime. At the same time it is also imperative to enable seamless transformation of small MFIs into large responsible entities. All privately owned MFIs that manage an asset base of more than Rs. 10 crores or serve more than 10,000 clients may not be allowed to operate as non-profits since it is in societal interest that financial business of sizable proportion be practiced under proper supervision, especially where majority clientele constitute vulnerable population. Beginning with a minimum capital requirement of Rs. 5 crores for newly transforming or start-up MFIs a timeline, say 3-5 years horizon, may be set for raising the capital base to Rs. 15 crores as recommended by the Malegam committee.
5. Promote public-private partnerships:
SHG-bank linkage program is a hugely successful government sponsored microcredit program that is aimed at making bank credit accessible to the poor. Public sector banks and state governments work together under NABARD’s support in making this subsidized credit program work. MFIs with their extensive outreach into the hinterlands could prove great partners in funding to and managing the credit risk of SHGs. At the behest of RBI and the central government, NABARD could consider lending directly to MFIs for on-lending to government sponsored SHGs that are unable to access bank credit. This will not only minimize the possibility of duplication of groups and multiple lending but also help build strong symbiotic relationship between state governments and MFIs, in turn avoiding some of the troubles that seem to have caused Andhra Pradesh government to act the way it did. Similar thought could be extended to other transactional services such as bill payments, government pensions, welfare payments etc., in a phased manner.
6. Extend tax breaks and special status to MFIs operating in remote and difficult terrains:
The objective of financial inclusion would only be fulfilled when basic financial services reach every corner of the country through legitimate means. Offering MFIs with tax breaks and special recognition for reaching out to remote and underserved areas could prove an effective strategy in deepening the financial access. Such recognition could mean having access to special credit lines from banks at below-market rates. Lower cost of funds and tax savings could in turn be useful in offsetting extra operating costs incurred in serving less accessible areas without significant negative impact on revenues and/or effective cost to the borrowers.
This is the first time RBI has ever commissioned an intensive exercise on MFI regulation. Such opportunities do not come too often and should be best utilized. Policy frameworks of Philippines, Cambodia, Peru, Bolivia, Ghana, Kenya and Uganda could come handy as good reference points. These countries have been hailed for achieving some success in establishing progressive regulatory environments for microfinance.
It is understood that implementation of some of the above suggestions would mean commitment of significant additional resources on the part of RBI and the government. The very task of making financial services available to roughly 50% of nation’s population that is unbanked is no simple matter either and an earnest investment in a robust regulatory oversight infrastructure sooner than later may not be a bad idea.
About the Author
Sasidhar Thumuluri is a seasoned microfinance professional who keeps a close eye on the developments in India. He has studied the business of microfinance in over 30 countries and has a good grasp of its details. He is currently employed with Habitat for Humanity International in Washington DC and manages its global housing microfinance portfolio. Sasidhar can be contacted on his Linked In Profile .