2011 Global Microscope - Data Model

Supported by Publication Date: October 2011

Global Microscope on the Microfinance Business Environment 2011

OVERALL AND CATEGORY RANKINGS

OVERALL SCORE

COUNTRY HIGHLIGHT 1 Peru 67.8 =12 Bolivia 64.7 =1

REGION FILTER 3 Pakistan 62.8 =14 Kenya 60.3 =4

REGION HIGHLIGHT 5 El Salvador 58.8 =46 Philippines 58.5 =47 Colombia 56.0 =7

Overall and category scores 0-100 where 100=best 8 Ecuador 55.1 =79 Uganda 53.7 =7

=10 Mexico 53.6 =10=10 Panama 53.6 =10

12 Paraguay 53.3 =1013 Cambodia 50.9 =1014 Brazil 49.2 =1015 Rwanda 48.6 =1016 Chile 46.8 =1617 Tanzania 46.5 =1618 Honduras 46.3 =1619 Ghana 46.2 =1620 Dominican Republic 46.1 =1621 Kyrgyz Republic 45.2 =1622 Armenia 45.1 =2223 Uruguay 44.4 =2224 Mozambique 43.9 =2225 Nigeria 43.4 =2226 Georgia 43.3 =22

=27 Bosnia 43.1 =22=27 India 43.1 =22

29 Nicaragua 42.3 =2230 Mongolia 41.8 =3031 Tajikistan 41.1 =3032 Costa Rica 39.7 =3033 Indonesia 39.2 =3034 Guatemala 39.0 =3035 Azerbaijan 38.6 =3036 Madagascar 37.0 =3037 Morocco 33.7 =3738 Lebanon 33.5 =3739 China 32.0 =3740 Senegal 31.8 =3741 Cameroon 31.6 =3742 Egypt 31.4 =4243 Bangladesh 30.9 =4244 Yemen 30.1 =4245 Jamaica 29.1 =4246 Argentina 28.8 =4247 Dem. Rep. of Congo 28.5 =4248 Sri Lanka 27.4 =48

=49 Haiti 26.6 =48=49 Turkey 26.6 =50

51 Nepal 26.1 =5052 Venezuela 25.1 =5053 Trinidad and Tobago 21.8 =5054 Thailand 21.1 5455 Vietnam 19.7 55

Regulatory Framework and Practices

Overall score for each country is calculated as the weighted sum of the "Regulatory Framework and Practices" and "Supporting Institutional Framework" category scores, reduced by the adjustment factor.

The adjustment factor is based on each country's Stability score and represents a combined assessment of the likelihood and potential impact that political shocks or weak governance could have on the Microfinance environment.

Adjustment Factor: Stability

Pakistan 75.0 =1 Bolivia 70.0 1 Costa Rica 92.5Philippines 75.0 =1 Peru 70.0 =2 Chile 90.0Uganda 75.0 =3 Armenia 60.0 =2 Uruguay 90.0Cambodia 70.0 =3 Colombia 60.0 4 Brazil 87.5Kenya 70.0 =5 Chile 55.0 =5 El Salvador 82.5Peru 70.0 =5 Ecuador 55.0 =5 Indonesia 82.5Bolivia 65.0 =5 El Salvador 55.0 =7 Colombia 80.0El Salvador 65.0 =5 Kenya 55.0 =7 Jamaica 80.0Madagascar 65.0 =5 Mexico 55.0 =7 Mexico 80.0Ecuador 60.0 =5 Pakistan 55.0 =7 Panama 80.0Kyrgyz Republic 60.0 =5 Panama 55.0 =7 Trinidad and Tobago 80.0Mongolia 60.0 =12 Bosnia 50.0 =12 Ghana 77.5Paraguay 60.0 =12 Brazil 50.0 =12 Guatemala 77.5Rwanda 60.0 =12 Nicaragua 50.0 =12 Mongolia 77.5Tanzania 60.0 =12 Paraguay 50.0 =12 Tanzania 77.5Colombia 55.0 =12 Uruguay 50.0 =16 Dominican Republic 75.0Honduras 55.0 =17 Dominican Republic 45.0 =16 Honduras 75.0Mexico 55.0 =17 Ghana 45.0 =16 Mozambique 75.0Mozambique 55.0 =17 Philippines 45.0 =16 Peru 75.0Panama 55.0 =20 Georgia 40.0 =16 Turkey 75.0Tajikistan 55.0 =20 Honduras 40.0 =21 Argentina 72.5Azerbaijan 50.0 =20 India 40.0 =21 China 72.5Brazil 50.0 =20 Nigeria 40.0 =21 Paraguay 72.5China 50.0 =20 Rwanda 40.0 =21 Philippines 72.5Dominican Republic 50.0 =25 Argentina 35.0 =21 Rwanda 72.5Georgia 50.0 =25 Cambodia 35.0 =21 Vietnam 72.5Ghana 50.0 =25 Costa Rica 35.0 =27 Bosnia 70.0India 50.0 =25 Egypt 35.0 =27 Morocco 70.0Nigeria 50.0 =25 Guatemala 35.0 =27 Senegal 70.0Cameroon 45.0 =25 Indonesia 35.0 =27 Uganda 70.0Costa Rica 45.0 =25 Jamaica 35.0 =31 Armenia 67.5Guatemala 45.0 =25 Kyrgyz Republic 35.0 =31 Bolivia 67.5Indonesia 45.0 =25 Lebanon 35.0 =31 Kenya 67.5Nicaragua 45.0 =25 Morocco 35.0 =31 Nigeria 67.5Senegal 45.0 =25 Mozambique 35.0 =31 Pakistan 67.5Yemen 45.0 =25 Tanzania 35.0 =36 Cameroon 65.0Bangladesh 40.0 =25 Uganda 35.0 =36 Ecuador 65.0Bosnia 40.0 =25 Venezuela 35.0 =36 Georgia 65.0Chile 40.0 =39 Azerbaijan 30.0 =36 Lebanon 65.0Dem. Rep. of Congo 40.0 =39 Sri Lanka 30.0 =40 Azerbaijan 62.5Uruguay 40.0 =39 Tajikistan 30.0 =40 Cambodia 62.5Armenia 35.0 =39 Trinidad and Tobago 30.0 =40 Haiti 62.5Egypt 35.0 =39 Turkey 30.0 =40 India 62.5Haiti 35.0 =44 Bangladesh 25.0 =40 Tajikistan 62.5Lebanon 35.0 =44 Mongolia 25.0 45 Madagascar 57.5Morocco 35.0 =46 Cameroon 20.0 =46 Bangladesh 47.5Nepal 35.0 =46 Dem. Rep. of Congo 20.0 =46 Kyrgyz Republic 47.5Sri Lanka 30.0 =46 Haiti 20.0 48 Venezuela 45.0Vietnam 30.0 =46 Nepal 20.0 =49 Nepal 42.5Argentina 25.0 =46 Senegal 20.0 =49 Thailand 42.5Jamaica 25.0 =46 Thailand 20.0 51 Dem. Rep. of Congo 40.0Thailand 25.0 =46 Yemen 20.0 52 Sri Lanka 30.0Turkey 25.0 53 China 15.0 =53 Egypt 17.5Venezuela 20.0 =54 Madagascar 10.0 =53 Nicaragua 17.5Trinidad and Tobago 15.0 =54 Vietnam 10.0 55 Yemen 5.0


Supporting Institutional Framework

-1.88%-2.50%-2.50%-3.13%-4.38%-4.38%-5.00%-5.00%-5.00%-5.00%-5.00%-5.63%-5.63%-5.63%-5.63%-6.25%-6.25%-6.25%-6.25%-6.25%-6.88%-6.88%-6.88%-6.88%-6.88%-6.88%-7.50%-7.50%-7.50%-7.50%-8.13%-8.13%-8.13%-8.13%-8.13%-8.75%-8.75%-8.75%-8.75%-9.38%-9.38%-9.38%-9.38%-9.38%

-10.63%-13.13%-13.13%-13.75%-14.37%-14.37%-15.00%-17.50%-20.63%-20.63%-23.75%

Adjustment factor

2011 RANK COMPARED WITH 2010 RANK

Tables show country rank for Overall score in 2011 scorecard and 2010 scorecard (at default weighting)NB 2010 scores not directly comparable to 2011 due to change in indicator components.

2011 ranks calculated excluding Egypt as this country was not present in 2010 scorecard.

IMPROVED RANK 2011 2010 Change LOWER RANK 2011 2010 Change

Uruguay 23 46 +23 India 27 8 -19

Mongolia 30 44 +14 Nicaragua 29 13 -16

Rwanda 15 29 +14 Yemen 43 27 -16

Mexico 10 23 +13 Ghana 19 4 -15

Brazil 14 26 +12 Guatemala 34 19 -15

Lebanon 38 49 +11 Nepal 50 35 -15

Mozambique 24 34 +10 Bangladesh 42 33 -9

Indonesia 33 41 +8 Kyrgyz Republic 21 12 -9

Morocco 37 45 +8 Argentina 45 37 -8

Jamaica 44 51 +7 Haiti 48 40 -8

Panama 10 17 +7 Tajikistan 31 25 -6

Tanzania 17 24 +7 Cameroon 41 36 -5

Kenya 4 10 +6 Georgia 26 21 -5

Bosnia 27 32 +5 Madagascar 36 31 -5

Azerbaijan 35 38 +3 Sri Lanka 47 42 -5

Cambodia 13 16 +3 Philippines 6 2 -4

Nigeria 25 28 +3 Costa Rica 32 29 -3

Paraguay 12 15 +3 Thailand 53 50 -3

Senegal 40 43 +3 Chile 16 14 -2

Venezuela 51 54 +3 Ecuador 8 6 -2

Colombia 7 9 +2 Vietnam 54 52 -2

Pakistan 3 5 +2 China 39 38 -1

Uganda 9 11 +2

Bolivia 2 3 +1

Dem. Rep. of Congo 46 47 +1

El Salvador 5 6 +1

Trinidad and Tobago 52 53 +1

Tables show country rank for Overall score in 2011 scorecard and 2010 scorecard (at default weighting)

NO CHANGE 2011 2010 Change

Armenia 22 22 0

Dominican Republic 20 20 0

Honduras 18 18 0

Peru 1 1 0

Turkey 48 48 0

CATEGORY RANKING OVERALL SCORECalculated score 0-100 (100=best)

COUNTRY HIGHLIGHT Weighted sum of category scores

REGION FILTER Rank Score / 100

1 Peru 67.8

REGION HIGHLIGHT 2 Bolivia 64.7

3 Pakistan 62.8

SELECT INDICATOR 4 Kenya 60.3

5 El Salvador 58.8

6 Philippines 58.5

7 Colombia 56.0

8 Ecuador 55.1

9 Uganda 53.7

=10 Mexico 53.6

=10 Panama 53.6

12 Paraguay 53.3

13 Cambodia 50.9

14 Brazil 49.2

15 Rwanda 48.6

16 Chile 46.8

17 Tanzania 46.5

18 Honduras 46.3

19 Ghana 46.2

20 Dominican Republic 46.1

21 Kyrgyz Republic 45.2

22 Armenia 45.1

23 Uruguay 44.4

24 Mozambique 43.9

25 Nigeria 43.4

26 Georgia 43.3

=27 Bosnia 43.1

=27 India 43.1

0 10 20 30 40 50 60 70 80 90 100

Calculated score 0-100 (100=best)

Rank Score / 100 Regional Averages Score / 100

29 Nicaragua 42.3 All countries 41.5

30 Mongolia 41.8 Africa 42.9

31 Tajikistan 41.1 All Asia 37.8

32 Costa Rica 39.7 East Asia 37.6

33 Indonesia 39.2 Eastern Europe and Central Asia 40.4

34 Guatemala 39.0 Latin America and the Caribbean 45.1

35 Azerbaijan 38.6 Middle East and North Africa 32.2

36 Madagascar 37.0 South Asia 38.0

37 Morocco 33.7

38 Lebanon 33.5

39 China 32.0

40 Senegal 31.8

41 Cameroon 31.6

42 Egypt 31.4

43 Bangladesh 30.9

44 Yemen 30.1

45 Jamaica 29.1

46 Argentina 28.8

47 Dem. Rep. of Congo 28.5

48 Sri Lanka 27.4

=49 Haiti 26.6

=49 Turkey 26.6

51 Nepal 26.1

52 Venezuela 25.1

53 Trinidad and Tobago 21.8

54 Thailand 21.1

55 Vietnam 19.7

0 10 20 30 40 50 60 70 80 90 100

INDICATOR SCORES Regulatory Framework and Practices :: Regulation and supervision of microcredit portfolios

COUNTRY HIGHLIGHT

Are regulations and supervision in the country conducive to microcredit provision by banks and other established financial institutions?

REGION FILTER

REGION HIGHLIGHT

SELECT INDICATOR

1111111000000000000000000000000000

No such regulations exist or regulations are prohibitive

000000000000000000000

Regulatory Framework and Practices :: Regulation and supervision of microcredit portfolios


Regulations create serious obstacles Regulations create minor obstacles

Egypt 1 Argentina 1 Azerbaijan 1Jamaica 1 Armenia 1 Bolivia 1Sri Lanka 1 Bangladesh 1 Cameroon 1Thailand 1 Bosnia 1 Chile 1Trinidad and Tobago 1 Brazil 1 Georgia 0Venezuela 1 China 1 Ghana 0Vietnam 1 Colombia 1 Guatemala 0

1 Costa Rica 1 India 01 Dominican Republic 1 Indonesia 01 Dem. Rep. of Congo 1 Kyrgyz Republic 01 Ecuador 1 Madagascar 01 El Salvador 1 Mexico 01 Haiti 1 Mongolia 01 Honduras 1 Nigeria 01 Lebanon 1 Pakistan 01 Morocco 1 Panama 01 Mozambique 1 Paraguay 01 Nepal 1 Peru 01 Nicaragua 1 Rwanda 01 Senegal 1 Tajikistan 01 Turkey 1 Tanzania 01 Uruguay 0 01 Yemen 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 0

Regulations create at least two such obstacles for MFIs

0 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 00 0 0


CambodiaKenyaPhilippinesUganda

Regulations present no significant obstacles

INDICATOR RANKING OVERALL SCORERating 0-100 (100=best)

COUNTRY HIGHLIGHT

Weighted sum of category scoresREGION FILTER

REGION HIGHLIGHT

Rank Score / 100

SELECT INDICATOR 1 Peru 67.8

2 Bolivia 64.7

3 Pakistan 62.8

4 Kenya 60.3

5 El Salvador 58.8

6 Philippines 58.5

7 Colombia 56.0

8 Ecuador 55.1

9 Uganda 53.7

=10 Mexico 53.6

=10 Panama 53.6

12 Paraguay 53.3

13 Cambodia 50.9

14 Brazil 49.2

15 Rwanda 48.6

16 Chile 46.8

17 Tanzania 46.5

18 Honduras 46.3

19 Ghana 46.2

20 Dominican Republic 46.1

21 Kyrgyz Republic 45.2

22 Armenia 45.1

23 Uruguay 44.4

24 Mozambique 43.9

25 Nigeria 43.4

26 Georgia 43.3

=27 Bosnia 43.1

=27 India 43.1

29 Nicaragua 42.3

30 Mongolia 41.8

31 Tajikistan 41.1

32 Costa Rica 39.7

33 Indonesia 39.2

34 Guatemala 39.0

35 Azerbaijan 38.6

36 Madagascar 37.0

37 Morocco 33.7

38 Lebanon 33.5

39 China 32.0

40 Senegal 31.8

41 Cameroon 31.6

42 Egypt 31.4

43 Bangladesh 30.9

44 Yemen 30.1

45 Jamaica 29.1

46 Argentina 28.8

47 Dem. Rep. of Congo 28.5

48 Sri Lanka 27.4

=49 Haiti 26.6

=49 Turkey 26.6

51 Nepal 26.1

52 Venezuela 25.1

53 Trinidad and Tobago 21.8

54 Thailand 21.1

55 Vietnam 19.7

Weighted sum of category scores

Data

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COUNTRY PROFILE

SELECT COUNTRY

SELECT INDICATOR

Argentina

SCORECARD Rank / 55 Score / 100

OVERALL SCORE 46 28.8Regulatory Framework and Practices =50 25.0

Regulation and supervision of microcredit portfolios =26 50.0Formation of regulated/supervised microcredit institutions =42 25.0Formation/operation of non-regulated microcredit institutions =38 25.0Regulatory and supervisory capacity for microfinance =33 25.0Regulatory framework for deposit-taking =50 0.0

Supporting Institutional Framework =25 35.0Accounting transparency =22 50.0Client Protection: Transparency in pricing =34 25.0Client Protection: Dispute resolution =6 50.0Credit bureaus =11 50.0Policy and practice for financial transactions through agents =45 0.0

Adjustment Factor: Stability =21 72.5Political shock to microfinance =1 100.0Political stability =23 45.0

REGULATION AND SUPERVISION OF MICROCREDIT PORTFOLIOSThe Superintendency of Financial Institutions of the Banco Central de la República Argentina (BCRA, the Central Bank) is the main formal regulator for the overall financial system. Microfinance was until recently a completely non-regulated industry; institutions operating within it are either Sociedades Anónimas (SAs, limited companies) or non-governmental organisations (NGOs). Existing institutions, such as banks or NGOs, may form SAs, which can operate as non-regulated institutions allowed to provide credit and are subject to lower taxation. However, in December 2008 a Central Bank circular took important first steps toward regulating microcredit. It recognised the activity for the first time, allowed banks to grant microcredit directly to clients rather than through formation of another SA and permitted banks to hold up to 100% of the shares in an SA. It also allowed and explicitly differentiated banks’ efforts to provide second-tier funding to microfinance institutions (as opposed to other, non-microfinance institutions), ultimately easing conditions for banks to lend money to non-regulated microfinance institutions (NGOs and SAs). Finally, the circular even enabled NGOs and SAs to raise funds on capital markets to facilitate funding. While immediate impacts were somewhat obscured by the global recession and a general tightening of liquidity in the country’s banking system, evidence is mounting of positive, if not overwhelming, impacts. Banks have slowly increased their presence in the sector (such as Banco de Provincia with its new microfinance unit) and greater access to non-public funding is now available for NGO MFIs, as several domestic and foreign banks have opened or expanded on-lending to NGO MFIs. Documentation requirements were also eased by the 2008 circular, and capital-adequacy standards generally do not apply, since SAs are non-prudentially-regulated, and in any event are considered adequate. Still, the circular’s definition of microcredit is seen by some as too broad and banks still face a labour contracts burden that prevents personnel from working outside branches (which some circumvent by setting up as Sociedades Comerciales (SCs), which have more labour flexibility) and high indirect labour costs, given social charges. Although public institutions are in principle second-tier and there are no floors or ceilings on interest rates, they introduce distortion into market interest rates and competition by requiring institutions to which they on-lend to apply administratively determined rates (currently 6%) and also by offering concessional rates in loans from government programmes that can be as low as one-quarter of those charged commercially. The state also injects competitive distortion by offering financing to non-profit organisations at a subsidized rate, on the condition that that institution offers microcredit at a capped rate, which is often at a level that does not cover operating costs for these organisations. There is no general cap on interest rates, although rates tend to be high (at between 40-80% per annum), reflecting the high cost of credit in an inflationary economy. A high tax burden (such as a tax on banking operations for internal administration) also remains onerous, as well as provincial-level restrictions on the share of capital that may be held by foreign institutional investors (first adopted in 2005 at 4% by Ciudad Autónoma de Buenos Aires and since emulated by other provinces).

(Banco Central, December 2010; Personal interviews: June 2011)

PERFORMANCE INDICATORS

FINANCIAL PERFORMANCE

Return on Assets (Weighted average) -2.8%

Return on Assets (Median) -15.2%

OUTREACH 0

Portfolio size, US$ 779,936

Average loan balance as a % of GNI per capita 5.4%

Y-O-Y growth in number of borrowers 17.9%

Growth on GLP 46.8%

DEPOSITS 0

Number of deposit accounts 0

Loan/deposit ratio 3.9

Average deposit balance, US$ 0

Growth on deposits 32.7%

Average deposit account balance / GNI per capita 0.00

EFFICIENCY 0

Borrowers per staff member 64.4

Cost per loan, US$ 312.4

Cost per borrower, US$ 352.0

RISK 0

Portfolio at risk > 30 days 5.2%

Percent of write-offs 2.03%

* Data provided by MIX market.

** Except for the weighted average of the ROA, all data is calculated as the median.

COUNTRY DETAIL SELECT COUNTRY

Argentina Data


2

1

1

1

0

Supporting Institutional Framework

2

Regulation and supervision of microcredit portfolios

Regulations create at least two such obstacles for MFIs

Formation of regulated/supervised microcredit institutions

Regulations exist but multiple obstacles make formation very difficult

Formation/operation of non-regulated microcredit institutions

Unregulated institutions face many obstacles to establishing operations;

Regulatory and supervisory capacity for microfinance

Limited capacity to regulate and supervise;

Regulatory framework for deposit-taking

Regulated institutions may not take deposits;

Accounting transparency

National standards exist but are adhered to by only some institutions

1

2

2

0

Adjustment Factor: Stability

0

55

Client Protection: Transparency in pricing

Regulations are technically in place but they are not followed or enforced;

Client Protection: Dispute resolution

A mechanism for dispute resolution exists, but it does not work well in practice (e.g. it is too costly, time-consuming, unfair, or is only available to a limited number of potential users);

Credit bureaus

Credit bureaus are weak in some of these ways;

Policy and practice for financial transactions through agents

The environment is not conducive and there are no existing agent mechanisms in the country;

Political shock to microfinance

The country has been free of any political developments affecting microfinance operations

Political stability

Long text notes are abridged, double click an indicator, or click the button below to view full text. MACROS must be enabled.

Notes

The Superintendency of Financial Institutions of the Banco Central de la República Argentina (BCRA, the Central Bank) is the main formal regulator for the overall financial system. Microfinance was until recently a completely non-regulated industry; institutions operating within it are either Sociedades Anónimas (SAs, limited companies) or non-governmental organisations (NGOs). Existing institutions, such as banks or NGOs, may form SAs, which can operate as non-regulated institutions allowed to provide credit and are subject to lower taxation. However, in December 2008 a Central Bank circular …

There are no specialised juridical vehicles for microfinance in Argentina, although the limited company form, unregulated by theCentral Bank, has been used for microfinance purposes by both downscaling banks and NGOs. Although credit co-operatives were created by a September 2007 law as a means to channel credit to micro, small and medium-sized enterprises (and one that could also capture deposits from members), only two had been authorised by the Central Bank as of September 2009 and apparently none with any significant microfinance presence. The vehicle appears unattractive to NGOs and SAs s …

Administratively, forming an NGO can take up to one year. Each province has its own authority that registers NGOs. Although it is not difficult to establish a non-regulated institution that offers microfinance services, and while NGOs can set market interest rates (subject to the loose caps specified in the first indicator) they face competition from SAs that receive second-tier public loans that require them to fix their interest rates (6% currently) and that also access their own, more limited line of second-tier public on-lending, which comes with similarly problematic interest rate caps. N …

Specialised expertise and methodologies for microfinance have generally been lacking and five government entities compete with each other in shaping the industry in practice: the Central Bank/Financial Superintendency; the Ministry of Finance (which has a second-tier funding programme for SAs); the General Inspectorate of Justice of the Ministry of Justice (which regulates the formation and organisation—but not the finances—of SAs and NGOs); FONCAP, a public-private enterprise; and the Ministry of Social Development (which has a second-tier funding scheme for NGO-MFIs). This creates considerab …

Institutions operating in microfinance are not allowed to capture deposits of any type, and at present, there is no distinction made between the traditional saver and potential microfinance savers, so this reduces the possibilities of increasing the capacity for microfinance institutions to capture deposits. There is no legal minimum deposit requirement for banks, the problem is that the costs of maintaining an account are not offset by the remuneration of the account for a consumer. This means that for a saver, a deposit essentially ends up having a "negative" impact. There may well be a modi …

There is a large gap between the standards followed by regulated (non-microfinance) institutions and MFIs (mostly NGOs and SAs), which are non-regulated and have laxer norms and practices. Commercial organisations must submit annual audited accounts under local standards (which are not yet aligned to international standards). This information must be submitted to tax and corporation regulators in the country. Non-regulated organisations are not subject to auditing standards, aside from those that operate with the aid of international funding, of which in Argentina there are few. The Buenos Air …

There is no requirement to publish effective rates, and practices are very uneven. The RADIM network reports that its SA and NGO members divulge rates clearly in loan agreements. External audits have begun to appear with more frequency, however, owing to pressure from international funders and self-regulation through MFI networks, such as RADIM, who have been by holding conferences to promote the Transparent Pricing Initiative in Argentina. However, there is less clarity with respect to fees charged by microfinance institutions. Financial institutions do have a requirement to clearly publish f …

There is no specific regulatory framework in place that may allow a regulation such as the Consumer Protection Act to be a tool for borrower protection. As such, in Argentina, disputes are resolved in the courts, with all the time and money that may entail for a borrower. However, the legal framework currently favours the borrower, and a private mediation process must be completed before going to court. The number of cases that reach the court are quite low and there is a large percentage of dispute cases that are resolved before they reach court.

(Personal interviews, June 2011)

The country has 26 private bureaus, plus a public registry, but none is specific to microfinance. Most of the data come from the formal financial system, are often outdated, and are consequently of limited utility, although lately some improved information from small-scale consumer lending has become available. The market in Argentina is not yet as developed in terms of the issue of monitoring indebtedness, a situation that occurs frequently among microfinance institutions. There is no developed credit bureau (there is incipient negative information exchanged between 3 or 4 institutions) to an …

Argentina is still behind in the use of technology applied to microcredit. What have been used in recent years are the services of collection agents, to increase the points and times in which customers can make their payments. There is still no development in terms of offering microcredit through mobile phone or wireless means and there is, as yet, no innovative channel of development for microfinance. The market for microfinance in Argentina is still quite underdeveloped; committing time and resources to making it more sophisticated is not currently a priority for the regulator or the financ …

Although access to financing remains a weakness, there are no special circumstances that could generate extreme tension in the short term. Despite the general lack of regulatory oversight for microfinance in Argentina, there is no sign of any demand-side movement that may have an adverse effect on development of the industry. Continued commitment to expansionary macroeconomic policies for political reasons, despite the significant economic distortions these have created, create some risk of producing a loss of confidence and renewed capital flight. The election in October 2011 should be orderl …

COUNTRY COMPARISON COMPARE WITH

Argentina Argentina

OVERALL SCORE 28.8 28.8

REGULATORY FRAMEWORK AND PRACTICES 25.0 25.0

Regulation and supervision of microcredit portfolios 50.0 50.0

Formation of regulated/supervised microcredit institutions 25.0 25.0

Formation/operation of non-regulated microcredit institutions 25.0 25.0

Regulatory and supervisory capacity for microfinance 25.0 25.0

Regulatory framework for deposit-taking 0.0 0.0

SUPPORTING INSTITUTIONAL FRAMEWORK 35.0 35.0

Accounting transparency 50.0 50.0

Client Protection: Transparency in pricing 25.0 25.0

Client Protection: Dispute resolution 50.0 50.0

Credit bureaus 50.0 50.0

Policy and practice for financial transactions through agents 0.0 0.0

ADJUSTMENT FACTOR: STABILITY 72.5 72.5

Political shock to microfinance 100.0 100.0

Political stability 45.0 45.0

PERFORMANCE INDICATORS Argentina Argentina

FINANCIAL PERFORMANCE

Return on Assets (Weighted average) -2.8% -2.8%

Return on Assets (Median) -15.2% -15.2%

OUTREACH

Portfolio size, US$ 779,936 779,936

Average loan balance as a % of GNI per capita 0.1 0.1

Y-O-Y growth in number of borrowers 17.9% 17.9%

Growth on GLP 46.8% 46.8%

DEPOSITS

Number of deposit accounts 0 0

Loan/deposit ratio 3.9 3.9

Average deposit balance, US$ 0 0

Growth on deposits 32.7% 32.7%

Average deposit account balance / GNI per capita 0.0% 0.0%

EFFICIENCY

Borrowers per staff member 64.4 64.4

Cost per loan, US$ 312.4 312.4

Cost per borrower, US$ 352.0 352.0

RISK

Portfolio at risk > 30 days 5.2% 5.2%

Percent of write-offs 2.0% 2.0%

SCATTER CHART OVERALL SCORERating 0-100 (100=best)

COUNTRY HIGHLIGHT

Regulation and supervision of microcredit portfoliosREGION FILTER Rating 0-4 (4=best)

REGION HIGHLIGHT CORRELATION(X,Y) 0.66

SELECT X-AXIS INDICATOR

SELECT Y-AXIS INDICATOR

0 10 20 30 40 50 60 70 800

0.5

1

1.5

2

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Regulation and supervision of microcredit portfolios

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A note on the number of borrowers data: Data for the number of microfinance borrowers comes from MIX market, while data for the number of self-employed is obtained from the Multilateral Investment Fund household surveys. The self-employed data is used as a proxy for the number of microenterprises and thus represents the total market potential in a given country. This data is only available for LAC countries. All borrower and microenterprise data proxies are for 2010 or the latest available year.

WEIGHTS

CATEGORY WEIGHTSRegulatory Framework and Practices 1 50.0% |||||||||||||||||||||||||

Supporting Institutional Framework 1 50.0% |||||||||||||||||||||||||

INDICATOR WEIGHTSRegulatory Framework and Practices Regulation and supervision of microcredit portfolios 1 20.0% ||||||||||

Formation of regulated/supervised microcredit institutions 1 20.0% ||||||||||

Formation/operation of non-regulated microcredit institutions 1 20.0% ||||||||||

Regulatory and supervisory capacity for microfinance 1 20.0% ||||||||||

Regulatory framework for deposit-taking 1 20.0% ||||||||||Supporting Institutional Framework Accounting transparency 1 20.0% ||||||||||

Client Protection: Transparency in pricing 1 20.0% ||||||||||

Client Protection: Dispute resolution 1 20.0% ||||||||||

Credit bureaus 1 20.0% ||||||||||

Policy and practice for financial transactions through agents 1 20.0% ||||||||||

SELECT WEIGHT PROFILE:Change weights by editing numbers in the yellow "Weight" column.Set a weight to zero to completely remove the influence of any indicator/category.

SELECT WEIGHT PROFILE:Change weights by editing numbers in the yellow "Weight" column.Set a weight to zero to completely remove the influence of any indicator/category.

NORMALISED SCORES

All scores 0-100 where 100=best

WEIGHT Argentina ArmeniaOVERALL SCORE 28.8 45.1

1 REGULATORY FRAMEWORK AND PRACTICES 50.0% 25.0 35.01.1 Regulation and supervision of microcredit portfolios 20.0% 50.0 50.01.2 Formation of regulated/supervised microcredit institutions 20.0% 25.0 50.01.3 Formation/operation of non-regulated microcredit institutions 20.0% 25.0 0.01.4 Regulatory and supervisory capacity for microfinance 20.0% 25.0 75.01.5 Regulatory framework for deposit-taking 20.0% 0.0 0.0

2 SUPPORTING INSTITUTIONAL FRAMEWORK 50.0% 35.0 60.02.1 Accounting transparency 20.0% 50.0 75.02.2 Client Protection: Transparency in pricing 20.0% 25.0 75.02.3 Client Protection: Dispute resolution 20.0% 50.0 50.02.4 Credit bureaus 20.0% 50.0 75.02.5 Policy and practice for financial transactions through agents 20.0% 0.0 25.0

3 ADJUSTMENT FACTOR: STABILITY 72.5 67.53.1 Political shock to microfinance 50.0% 100.0 100.03.2 Political stability 50.0% 45.0 35.0

STABILITY ADJUSTMENT FACTOR -6.88% -8.13%

Azerbaijan Bangladesh Bolivia Bosnia Brazil Cambodia Cameroon Chile China38.6 30.9 64.7 43.1 49.2 50.9 31.6 46.8 32.050.0 40.0 65.0 40.0 50.0 70.0 45.0 40.0 50.075.0 50.0 75.0 50.0 50.0 100.0 75.0 75.0 50.075.0 50.0 50.0 50.0 50.0 75.0 50.0 25.0 50.0

0.0 50.0 75.0 50.0 50.0 50.0 25.0 50.0 25.050.0 25.0 75.0 50.0 50.0 50.0 25.0 25.0 50.050.0 25.0 50.0 0.0 50.0 75.0 50.0 25.0 75.030.0 25.0 70.0 50.0 50.0 35.0 20.0 55.0 15.075.0 50.0 50.0 75.0 50.0 75.0 50.0 75.0 50.025.0 75.0 100.0 75.0 50.0 75.0 25.0 50.0 0.0

0.0 0.0 75.0 50.0 50.0 0.0 0.0 75.0 0.025.0 0.0 75.0 50.0 50.0 0.0 0.0 50.0 25.025.0 0.0 50.0 0.0 50.0 25.0 25.0 25.0 0.062.5 47.5 67.5 70.0 87.5 62.5 65.0 90.0 72.5

100.0 50.0 100.0 100.0 100.0 100.0 100.0 100.0 100.025.0 45.0 35.0 40.0 75.0 25.0 30.0 80.0 45.0

-9.38% -13.13% -8.13% -7.50% -3.13% -9.38% -8.75% -2.50% -6.88%

Colombia Costa Rica Ecuador Egypt El Salvador Georgia Ghana56.0 39.7 46.1 28.5 55.1 31.4 58.8 43.3 46.255.0 45.0 50.0 40.0 60.0 35.0 65.0 50.0 50.050.0 50.0 50.0 50.0 50.0 25.0 50.0 75.0 75.050.0 50.0 50.0 50.0 75.0 25.0 75.0 75.0 50.075.0 50.0 75.0 25.0 50.0 50.0 75.0 0.0 50.050.0 25.0 25.0 25.0 75.0 50.0 50.0 75.0 25.050.0 50.0 50.0 50.0 50.0 25.0 75.0 25.0 50.060.0 35.0 45.0 20.0 55.0 35.0 55.0 40.0 45.050.0 25.0 50.0 25.0 50.0 50.0 75.0 75.0 50.050.0 50.0 50.0 25.0 50.0 25.0 50.0 50.0 25.075.0 50.0 25.0 25.0 50.0 25.0 50.0 50.0 50.075.0 50.0 75.0 0.0 100.0 50.0 75.0 25.0 25.050.0 0.0 25.0 25.0 25.0 25.0 25.0 0.0 75.080.0 92.5 75.0 40.0 65.0 17.5 82.5 65.0 77.5

100.0 100.0 100.0 50.0 100.0 0.0 100.0 100.0 100.060.0 85.0 50.0 30.0 30.0 35.0 65.0 30.0 55.0

-5.00% -1.88% -6.25% -15.00% -8.75% -20.63% -4.38% -8.75% -5.63%

Dominican Republic

Dem. Rep. of Congo

Guatemala Haiti Honduras India Indonesia Jamaica Kenya Lebanon39.0 26.6 46.3 43.1 39.2 29.1 60.3 45.2 33.545.0 35.0 55.0 50.0 45.0 25.0 70.0 60.0 35.075.0 50.0 50.0 75.0 75.0 25.0 100.0 75.0 50.025.0 25.0 50.0 50.0 25.0 25.0 75.0 50.0 50.050.0 75.0 75.0 50.0 50.0 25.0 75.0 100.0 50.025.0 0.0 50.0 50.0 25.0 25.0 50.0 50.0 25.050.0 25.0 50.0 25.0 50.0 25.0 50.0 25.0 0.035.0 20.0 40.0 40.0 35.0 35.0 55.0 35.0 35.075.0 25.0 50.0 50.0 75.0 75.0 75.0 50.0 50.025.0 50.0 50.0 50.0 25.0 25.0 50.0 25.0 50.0

0.0 25.0 25.0 0.0 25.0 50.0 50.0 25.0 50.050.0 0.0 50.0 50.0 25.0 0.0 25.0 50.0 0.025.0 0.0 25.0 50.0 25.0 25.0 75.0 25.0 25.077.5 62.5 75.0 62.5 82.5 80.0 67.5 47.5 65.0

100.0 100.0 100.0 50.0 100.0 100.0 100.0 50.0 100.055.0 25.0 50.0 75.0 65.0 60.0 35.0 45.0 30.0

-5.63% -9.38% -6.25% -9.38% -4.38% -5.00% -8.13% -13.13% -8.75%

Kyrgyz Republic

Madagascar Mexico Mongolia Morocco Mozambique Nepal Nicaragua Nigeria Pakistan37.0 53.6 41.8 33.7 43.9 26.1 42.3 43.4 62.865.0 55.0 60.0 35.0 55.0 35.0 45.0 50.0 75.075.0 75.0 75.0 50.0 50.0 50.0 50.0 75.0 75.075.0 50.0 50.0 75.0 50.0 75.0 50.0 50.0 75.075.0 50.0 25.0 0.0 75.0 25.0 50.0 50.0 50.025.0 50.0 75.0 50.0 50.0 0.0 50.0 25.0 100.075.0 50.0 75.0 0.0 50.0 25.0 25.0 50.0 75.010.0 55.0 25.0 35.0 35.0 20.0 50.0 40.0 55.025.0 75.0 25.0 75.0 50.0 25.0 75.0 25.0 75.0

0.0 75.0 50.0 0.0 50.0 50.0 75.0 50.0 75.00.0 50.0 25.0 0.0 25.0 0.0 25.0 50.0 50.0

25.0 50.0 0.0 75.0 25.0 0.0 50.0 25.0 25.00.0 25.0 25.0 25.0 25.0 25.0 25.0 50.0 50.0

57.5 80.0 77.5 70.0 75.0 42.5 17.5 67.5 67.5100.0 100.0 100.0 100.0 100.0 50.0 0.0 100.0 100.0

15.0 60.0 55.0 40.0 50.0 35.0 35.0 35.0 35.0

-10.63% -5.00% -5.63% -7.50% -6.25% -14.37% -20.63% -8.13% -8.13%

Panama Paraguay Peru Philippines Rwanda Senegal Sri Lanka Tajikistan Tanzania53.6 53.3 67.8 58.5 48.6 31.8 27.4 41.1 46.555.0 60.0 70.0 75.0 60.0 45.0 30.0 55.0 60.075.0 75.0 75.0 100.0 75.0 50.0 25.0 75.0 75.050.0 50.0 75.0 75.0 75.0 50.0 50.0 75.0 25.050.0 75.0 50.0 50.0 50.0 25.0 50.0 25.0 100.050.0 50.0 100.0 75.0 50.0 50.0 0.0 50.0 50.050.0 50.0 50.0 75.0 50.0 50.0 25.0 50.0 50.055.0 50.0 70.0 45.0 40.0 20.0 30.0 30.0 35.075.0 50.0 75.0 50.0 25.0 25.0 25.0 75.0 75.050.0 50.0 75.0 50.0 25.0 25.0 25.0 50.0 25.050.0 75.0 50.0 50.0 50.0 25.0 25.0 0.0 25.075.0 50.0 75.0 25.0 50.0 0.0 25.0 0.0 0.025.0 25.0 75.0 50.0 50.0 25.0 50.0 25.0 50.080.0 72.5 75.0 72.5 72.5 70.0 30.0 62.5 77.5

100.0 100.0 100.0 100.0 100.0 100.0 0.0 100.0 100.060.0 45.0 50.0 45.0 45.0 40.0 60.0 25.0 55.0

-5.00% -6.88% -6.25% -6.88% -6.88% -7.50% -17.50% -9.38% -5.63%

Thailand Turkey Uganda Uruguay Venezuela Vietnam Yemen21.1 21.8 26.6 53.7 44.4 25.1 19.7 30.125.0 15.0 25.0 75.0 40.0 20.0 30.0 45.025.0 25.0 50.0 100.0 50.0 25.0 25.0 50.025.0 0.0 25.0 75.0 25.0 25.0 25.0 75.025.0 25.0 25.0 50.0 25.0 0.0 50.0 50.0

0.0 0.0 25.0 75.0 50.0 25.0 25.0 25.050.0 25.0 0.0 75.0 50.0 25.0 25.0 25.020.0 30.0 30.0 35.0 50.0 35.0 10.0 20.025.0 50.0 75.0 50.0 50.0 75.0 25.0 50.025.0 25.0 25.0 50.0 50.0 50.0 25.0 0.0

0.0 0.0 25.0 25.0 75.0 25.0 0.0 0.025.0 75.0 25.0 25.0 50.0 0.0 0.0 25.025.0 0.0 0.0 25.0 25.0 25.0 0.0 25.042.5 80.0 75.0 70.0 90.0 45.0 72.5 5.050.0 100.0 100.0 100.0 100.0 50.0 100.0 0.035.0 60.0 50.0 40.0 80.0 40.0 45.0 10.0

-14.37% -5.00% -6.25% -7.50% -2.50% -13.75% -6.88% -23.75%

Trinidad and Tobago

All countries Africa All Asia East Asia South Asia41.5 42.9 37.8 37.6 40.4 45.1 32.2 38.048.0 55.9 48.8 50.7 45.0 46.4 37.5 46.060.0 72.7 60.4 64.3 64.3 54.8 43.8 55.050.5 56.8 52.1 46.4 57.1 42.9 56.3 60.045.9 54.5 41.7 39.3 28.6 51.2 37.5 45.042.3 40.9 39.6 42.9 53.6 41.7 37.5 35.041.4 54.5 50.0 60.7 21.4 41.7 12.5 35.038.1 32.3 29.6 26.4 39.3 46.9 31.3 34.054.1 43.2 45.8 46.4 71.4 58.3 56.3 45.042.7 31.8 43.8 35.7 46.4 51.2 18.8 55.031.4 29.5 14.6 14.3 28.6 45.2 18.8 15.035.0 18.2 16.7 14.3 35.7 53.6 37.5 20.027.3 38.6 27.1 21.4 14.3 26.2 25.0 35.066.0 67.3 61.0 68.9 64.3 73.7 39.4 50.086.4 95.5 75.0 92.9 92.9 92.9 50.0 50.045.5 39.1 47.1 45.0 35.7 54.5 28.7 50.0

Eastern Europe

Latin America and the Caribbean

Middle East and North Africa

INDICATOR DATA

OVERALL SCORE1 REGULATORY FRAMEWORK AND PRACTICES

1.1 Regulation and supervision of microcredit portfolios Rating 0-4 (4=best)1.2 Formation of regulated/supervised microcredit institutions Rating 0-4 (4=best)1.3 Formation/operation of non-regulated microcredit institutions Rating 0-4 (4=best)1.4 Regulatory and supervisory capacity for microfinance Rating 0-4 (4=best)1.5 Regulatory framework for deposit-taking Rating 0-4 (4=best)

2 SUPPORTING INSTITUTIONAL FRAMEWORK2.1 Accounting transparency Rating 0-4 (4=best)2.2 Client Protection: Transparency in pricing Rating 0-4 (4=best)2.3 Client Protection: Dispute resolution Rating 0-4 (4=best)2.4 Credit bureaus Rating 0-4 (4=best)2.5 Policy and practice for financial transactions through agents Rating 0-4 (4=best)

3 ADJUSTMENT FACTOR: STABILITY3.1 Political shock to microfinance Rating 0-2 (0=best)3.2 Political stability Rating 0-100 (0=best)

DP DEPENDENT VARIABLES DP1 Number of borrowers as % of population %DP2 Number of borrowers as % of self-employed %DP3 Number of borrowers as % of poor population %

BG PERFORMANCE INDICATORSFP FINANCIAL PERFORMANCE

FP1 Return on Assets (Weighted average) %FP2 Return on Assets (Median) %OU OUTREACH

OU1 Portfolio size, US$ US$OU2 Average loan balance as a % of GNI per capita % of GNI per capitaOU3 Y-O-Y growth in number of borrowers %OU4 Growth on GLP %

DE DEPOSITSDE1 Number of deposit accounts accountsDE2 Loan/deposit ratio ratioDE3 Average deposit balance, US$ US$DE4 Growth on deposits %DE5 Average deposit account balance / GNI per capita 0

EF EFFICIENCYEF1 Borrowers per staff member ratioEF2 Cost per loan, US$ US$EF3 Cost per borrower, US$ US$RK RISK

RK1 Portfolio at risk > 30 days %RK2 Percent of write-offs %

Argentina Armenia Azerbaijan Bangladesh Bolivia Bosnia Brazil Cambodia Cameroon

2.0 2.0 3.0 2.0 3.0 2.0 2.0 4.0 3.01.0 2.0 3.0 2.0 2.0 2.0 2.0 3.0 2.01.0 0.0 0.0 2.0 3.0 2.0 2.0 2.0 1.01.0 3.0 2.0 1.0 3.0 2.0 2.0 2.0 1.00.0 0.0 2.0 1.0 2.0 0.0 2.0 3.0 2.0

2.0 3.0 3.0 2.0 2.0 3.0 2.0 3.0 2.01.0 3.0 1.0 3.0 4.0 3.0 2.0 3.0 1.02.0 2.0 0.0 0.0 3.0 2.0 2.0 0.0 0.02.0 3.0 1.0 0.0 3.0 2.0 2.0 0.0 0.00.0 1.0 1.0 0.0 2.0 0.0 2.0 1.0 1.0

0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.055.0 65.0 75.0 55.0 65.0 60.0 25.0 75.0 70.0

0.1 7.3 4.0 12.0 8.8 7.0 0.5 8.7 0.60.8 43.5 8.10.5 27.6 25.5 23.9 14.6 50.1 2.3 28.8 1.5

-2.8% 3.0% 4.4% 5.9% 2.0% -1.3% 4.6% 2.9% 0.8%-15.2% 3.4% 4.0% 2.2% 1.5% -2.2% 6.7% 2.9% 0.9%

779,936 16,388,103 4,494,493 12,156,828 34,084,684 28,716,361 4,184,589 26,203,315 5,632,9065.4% 46.2% 23.9% 20.5% 105.2% 31.9% 14.1% 89.1% 76.5%

17.9% 21.6% 11.5% 6.7% 12.5% -27.4% 8.1% 9.7% 11.1%46.8% 43.9% 24.9% 18.3% 26.7% -29.7% 38.7% 30.7% 50.5%

0 0 0 151,752 0 0 0 3,286 16,9133.9 2.0 1.9 2.9 1.0 1.1 2.6 13.8 0.8

1,403.8 4,481.0 27.4 924.9 1,538.4 1,461.4 89.2 504.532.7% 18.3% 54.9% 16.2% 9.7% -16.2% 36.9% 23.3% 14.9%

44.0% 92.0% 5.0% 53.0% 33.0% 18.0% 14.5% 43.0%

64.4 81.4 78.9 126.2 75.6 117.7 91.9 75.4 80.6312.4 159.1 191.2 15.3 262.2 211.8 279.3 98.8 110.4352.0 159.1 222.7 15.4 269.9 220.8 460.5 104.4 160.9

5.2% 1.0% 1.5% 6.6% 2.3% 10.9% 5.0% 1.0% 11.0%2.0% 0.4% 0.0% 0.0% 0.7% 8.6% 1.4% 0.9% 0.5%

Chile China Colombia Costa Rica Ecuador Egypt El Salvador

3.0 2.0 2.0 2.0 2.0 2.0 2.0 1.0 2.01.0 2.0 2.0 2.0 2.0 2.0 3.0 1.0 3.02.0 1.0 3.0 2.0 3.0 1.0 2.0 2.0 3.01.0 2.0 2.0 1.0 1.0 1.0 3.0 2.0 2.01.0 3.0 2.0 2.0 2.0 2.0 2.0 1.0 3.0

3.0 2.0 2.0 1.0 2.0 1.0 2.0 2.0 3.02.0 0.0 2.0 2.0 2.0 1.0 2.0 1.0 2.03.0 0.0 3.0 2.0 1.0 1.0 2.0 1.0 2.02.0 1.0 3.0 2.0 3.0 0.0 4.0 2.0 3.01.0 0.0 2.0 0.0 1.0 1.0 1.0 1.0 1.0

0.0 0.0 0.0 0.0 0.0 1.0 0.0 2.0 0.020.0 55.0 40.0 15.0 50.0 70.0 70.0 65.0 35.0

1.4 0.0 3.3 0.6 3.7 0.1 4.9 0.8 2.718.0 19.4 11.1 15.2 24.5 26.4

9.3 0.7 7.2 2.6 7.4 0.3 13.7 3.6 7.2

0.1% 1.9% 2.5% 0.3% 2.3% -0.3% 1.4% 11.8% -0.7%-13.4% 2.1% 2.0% 2.8% 2.6% 0.2% 1.4% 8.4% 0.9%

12,868,453 4,501,361 15,071,048 1,606,349 7,280,007 1,955,427 7,031,647 7,279,267 5,790,0298.7% 49.0% 22.6% 23.0% 8.8% 130.0% 35.6% 8.1% 32.3%9.5% 8.8% 10.9% 7.1% 15.2% 5.5% 16.6% 9.8% 3.9%

44.3% 19.8% 27.3% 19.5% 16.3% 31.7% 41.6% 9.2% 16.2%

6,225 0 0 0 5,437 13,213 9,550 0 03.2 13.2 1.5 0.0 2.2 1.4 1.2 8.0 1.0

379.8 21.2 500.8 25.7 354.9 187.5 367.2 32.5 658.950.9% -56.4% 47.0% 46.7% -3.0% 27.9% 31.0% 8.8% 21.8%

5.0% 0.0% 11.0% 0.0% 7.5% 109.5% 9.5% 1.0% 18.0%

133.8 42.6 122.7 73.0 88.2 145.1 131.9 156.3 75.3213.7 65.6 181.4 204.5 158.5 112.2 188.8 27.3 224.6219.5 81.3 204.5 236.8 162.3 112.2 197.4 27.3 233.3

5.6% 0.8% 4.5% 4.9% 4.0% 1.2% 2.9% 2.3% 9.4%3.0% 0.0% 2.1% 0.0% 1.3% 1.8% 0.4% 0.0% 1.5%

Dominican Republic

Dem. Rep. of Congo

Georgia Ghana Guatemala Haiti Honduras India Indonesia Jamaica Kenya

3.0 3.0 3.0 2.0 2.0 3.0 3.0 1.0 4.03.0 2.0 1.0 1.0 2.0 2.0 1.0 1.0 3.00.0 2.0 2.0 3.0 3.0 2.0 2.0 1.0 3.03.0 1.0 1.0 0.0 2.0 2.0 1.0 1.0 2.01.0 2.0 2.0 1.0 2.0 1.0 2.0 1.0 2.0

3.0 2.0 3.0 1.0 2.0 2.0 3.0 3.0 3.02.0 1.0 1.0 2.0 2.0 2.0 1.0 1.0 2.02.0 2.0 0.0 1.0 1.0 0.0 1.0 2.0 2.01.0 1.0 2.0 0.0 2.0 2.0 1.0 0.0 1.00.0 3.0 1.0 0.0 1.0 2.0 1.0 1.0 3.0

0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.070.0 45.0 45.0 75.0 50.0 25.0 35.0 40.0 65.0

3.6 0.8 2.1 0.9 2.0 2.5 0.2 N/A 2.924.9 12.4

15.1 2.9 4.2 1.5 3.3 8.8 1.3 N/A 5.5

3.3% 1.2% 2.9% -3.7% 1.1% 2.0% 3.3% 5.2%7.3% 2.3% 2.5% -9.6% 2.2% 1.2% 4.0% 1.5%

5,553,634 1,455,980 4,774,360 12,637,061 4,631,713 7,792,279 2,944,482 5,473,937111.1% 40.0% 17.7% 70.7% 33.8% 10.6% 25.3% 39.2%

49.4% 11.1% 15.5% -24.0% -1.7% 20.6% 11.9% -3.8%54.5% 14.5% 21.6% 2.1% 14.8% 19.2% 29.6% 16.8%

0 18,443 0 6,198 2,034 0 11,649 38,49618.4 0.8 24.4 0.6 3.4 6.2 1.7 1.7

341.2 71.6 317.3 66.7 108.2 27.2 117.8 89.352.8% 32.1% -2.0% 80.5% 29.8% 20.5% 29.6% 28.6%23.0% 12.0% 12.0% 9.0% 7.5% 2.0% 5.0% 12.0%

38.8 107.0 120.9 56.9 87.6 215.3 74.2 120.7479.2 77.6 98.6 210.8 200.1 15.9 86.4 125.2498.1 69.0 98.6 210.8 202.3 16.6 81.9 146.8

2.7% 4.7% 6.0% 21.6% 8.0% 1.1% 12.5% 8.1%1.4% 0.0% 1.7% 13.4% 2.1% 0.0% 0.5% 0.6%

Lebanon Madagascar Mexico Mongolia Morocco Mozambique Nepal Nicaragua

3.0 2.0 3.0 3.0 3.0 2.0 2.0 2.0 2.02.0 2.0 3.0 2.0 2.0 3.0 2.0 3.0 2.04.0 2.0 3.0 2.0 1.0 0.0 3.0 1.0 2.02.0 1.0 1.0 2.0 3.0 2.0 2.0 0.0 2.01.0 0.0 3.0 2.0 3.0 0.0 2.0 1.0 1.0

2.0 2.0 1.0 3.0 1.0 3.0 2.0 1.0 3.01.0 2.0 0.0 3.0 2.0 0.0 2.0 2.0 3.01.0 2.0 0.0 2.0 1.0 0.0 1.0 0.0 1.02.0 0.0 1.0 2.0 0.0 3.0 1.0 0.0 2.01.0 1.0 0.0 1.0 1.0 1.0 1.0 1.0 1.0

1.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 2.055.0 70.0 85.0 40.0 45.0 60.0 50.0 65.0 65.0

6.9 1.0 0.4 5.0 14.2 2.5 0.2 2.6 5.630.1 37.5

16.0 5.1 0.5 10.5 40.2 28.2 0.3 8.2 11.7

4.0% 4.0% 2.2% 8.5% 2.1% 2.6% -2.3% 2.2% -5.4%4.3% 3.4% 1.3% 1.6% 4.7% 0.7% -4.3% 2.8% -4.6%

4,959,053 14,951,809 4,657,432 5,278,782 135,264,838 14,550,830 2,842,607 3,513,179 6,008,156110.2% 12.2% 162.8% 3.8% 158.4% 14.0% 73.8% 29.7% 83.7%

11.6% 3.6% -7.1% 16.4% 3.6% -11.0% 16.2% 15.1% -13.3%23.4% 3.7% 5.2% 33.0% 73.3% -0.4% 11.5% 53.1% -10.5%

0 0 30,074 0 194,286 0 16,584 34,561 031.6 1.1 5.4 1.1 2.5 2.5 2.7

253.0 122.2 75.8 647.0 55.1 17.4 264.3-31.1% 11.9% 26.0% 82.3% 32.1% 48.9% 19.9%27.0% 28.0% 1.0% 30.0% 11.0% 3.0% 23.5%

77.4 122.4 34.4 108.6 64.6 124.2 70.9 190.5 88.9122.4 184.2 146.9 169.4 157.3 89.3 167.1 18.2 141.6122.4 175.3 167.8 180.1 190.8 89.3 259.3 18.4 138.0

3.1% 3.5% 7.5% 4.3% 2.9% 6.8% 4.1% 0.6% 16.4%0.2% 0.9% 1.6% 2.6% 0.1% 5.5% 0.2% 0.0% 4.0%

Kyrgyz Republic

Nigeria Pakistan Panama Paraguay Peru Philippines Rwanda Senegal Sri Lanka

3.0 3.0 3.0 3.0 3.0 4.0 3.0 2.0 1.02.0 3.0 2.0 2.0 3.0 3.0 3.0 2.0 2.02.0 2.0 2.0 3.0 2.0 2.0 2.0 1.0 2.01.0 4.0 2.0 2.0 4.0 3.0 2.0 2.0 0.02.0 3.0 2.0 2.0 2.0 3.0 2.0 2.0 1.0

1.0 3.0 3.0 2.0 3.0 2.0 1.0 1.0 1.02.0 3.0 2.0 2.0 3.0 2.0 1.0 1.0 1.02.0 2.0 2.0 3.0 2.0 2.0 2.0 1.0 1.01.0 1.0 3.0 2.0 3.0 1.0 2.0 0.0 1.02.0 2.0 1.0 1.0 3.0 2.0 2.0 1.0 2.0

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.065.0 65.0 40.0 55.0 50.0 55.0 55.0 60.0 40.0

0.3 1.1 0.4 6.9 11.2 3.1 0.5 1.3 6.54.9 9.6 33.9

0.9 4.8 1.2 19.6 32.3 11.7 0.9 4.0 43.0

7.3% -2.1% 3.5% 2.6% 2.3% 2.6% 1.7% 0.5% 1.4%8.1% -2.7% 4.0% 2.8% 2.1% 2.0% 1.1% 0.8% 1.1%

8,412,253 3,326,817 3,889,892 92,852,458 24,982,206 5,509,136 3,080,504 13,178,211 3,308,90414.4% 11.8% 31.9% 46.7% 29.1% 15.5% 119.0% 86.0% 7.6%11.8% 7.8% 6.6% 17.0% 5.1% 8.2% 46.4% 27.4% 6.2%60.2% 3.4% 11.5% 35.3% 24.1% 20.9% 27.2% 18.0% 9.4%

67,028 0 2,134 21,210 4,442 27,598 21,045 46,401 13,8961.7 2.1 4.8 1.0 1.1 1.3 1.5 1.6 1.2

56.9 70.6 241.2 4,718.9 1,391.4 98.9 44.5 125.0 56.750.9% 19.0% 10.4% 38.2% 35.0% 20.8% 27.9% 18.9% 19.5%

5.0% 7.0% 3.0% 172.0% 25.0% 5.0% 8.0% 12.0% 2.5%

177.5 98.3 76.6 145.6 99.4 111.3 52.0 138.4 149.431.8 42.2 225.3 147.9 204.6 69.7 203.2 125.9 30.531.8 39.9 225.3 160.5 235.5 70.1 205.2 148.2 32.0

1.4% 3.9% 5.0% 4.0% 6.1% 6.0% 4.6% 8.4% 5.0%0.1% 1.8% 0.5% 2.7% 1.3% 0.5% 4.0% 1.5% 0.0%

Tajikistan Tanzania Thailand Turkey Uganda Uruguay Venezuela Vietnam

3.0 3.0 1.0 1.0 2.0 4.0 2.0 1.0 1.03.0 1.0 1.0 0.0 1.0 3.0 1.0 1.0 1.01.0 4.0 1.0 1.0 1.0 2.0 1.0 0.0 2.02.0 2.0 0.0 0.0 1.0 3.0 2.0 1.0 1.02.0 2.0 2.0 1.0 0.0 3.0 2.0 1.0 1.0

3.0 3.0 1.0 2.0 3.0 2.0 2.0 3.0 1.02.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 1.00.0 1.0 0.0 0.0 1.0 1.0 3.0 1.0 0.00.0 0.0 1.0 3.0 1.0 1.0 2.0 0.0 0.01.0 2.0 1.0 0.0 0.0 1.0 1.0 1.0 0.0

0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.0 0.075.0 45.0 65.0 40.0 50.0 60.0 20.0 60.0 55.0

1.7 0.5 0.0 N/A 0.1 0.8 N/A 0.1 9.62.6 0.5

3.7 1.6 0.2 N/A 0.3 3.4 N/A 0.5 66.1

1.4% -1.5% 3.3% -16.7% -10.5% 3.9%3.9% 2.2% 1.7% -2.9% 3.4% -16.7% -10.5% 6.2%

722,427 14,893,446 1,491,914 6,391,117 10,974,203 4,289,826 74,496,626 1,167,89088.4% 40.3% 4.4% 83.1% 22.2% 21.8% 13.4%

8.6% 25.1% 22.6% 10.7% 83.1% 11.7% 8.8%39.6% 12.7% 23.5% 7.6% 66.4% -22.8% 14.0%

0 17,167 0 21,153 74,694 0 142,897 10,9862.8 2.8 7.5 3.2 1.9 2.9

6,951.3 35.9 37.8 59.9 271.7 35.4193.0% 12.2% 81.2% 16.1% 16.5% 17.8%987.0% 14.0% 0.0% 13.0% 4.0% 3.0%

35.5 155.3 683.5 160.0 94.1 45.4 82.5 155.0151.0 116.4 19.8 90.5 165.3 783.2 493.0 16.5154.0 116.4 19.8 92.5 177.8 1,201.1 493.0 17.4

2.9% 1.9% 0.1% 6.7% 3.9% 9.2% 1.3% 0.0%0.0% 0.6% 0.0% 0.8% 1.7% 0.0% 2.3% 0.0%

Trinidad and Tobago

Yemen

2.03.02.01.01.0

2.00.00.01.01.0

2.090.0

0.1

0.3

10.2%3.1%

583,68511.0%

7.7%53.8%

5,1735.3

17.825.3%

2.0%

108.040.239.0

1.6%0.0%

INDICATOR NOTES

Argentina ArmeniaOVERALL SCORE

1 REGULATORY FRAMEWORK AND PRACTICES1.1 Regulation and supervision of microcredit portfolios1.2 Formation of regulated/supervised microcredit institutions Becoming a regu1.3 Formation/operation of non-regulated microcredit institutions1.4 Regulatory and supervisory capacity for microfinance1.5 Regulatory framework for deposit-taking

2 SUPPORTING INSTITUTIONAL FRAMEWORK2.1 Accounting transparency2.2 Client Protection: Transparency in pricing2.3 Client Protection: Dispute resolution2.4 Credit bureaus2.5 Policy and practice for financial transactions through agents

3 ADJUSTMENT FACTOR: STABILITY3.1 Political shock to microfinance3.2 Political stability

(Banco Central, December 2010; Personal interviews: June 2011)(Central Bank of Armenia; company websites, MIX Market Report, personal Interviews: July 2011; Law no 39-N 2007 and Regulation 9 2007)(Banco Central, August 2010 and January 2011; Portalmicrofinanzas.org, August 2010; Personal interviews: June 2011)(Banco Central, August 2010; Personal interviews, June 2011)(CGAP Reports 2010; Central Bank of Armenia; personal interviews: June-July 2011)(Personal interviews, June 2011)

(Personal Interviews: July 2011; CGAP Reports)

(Personal interviews, June 2011)(Source: Central Bank of Armenia; personal Interviews: July 2011; CGAP)

(Deloitte IAS, December 2010; Personal interviews, June 2011)(Accounting Law of 2002; personal Interviews: June-July 2009, 2011; MixMarket, Deloitte/IAS Plus.)(Personal interviews, June 2011)(Central Bank of Armenia website; company websites; personal Interviews: July 2011; World Business 2011; CGAP Report 2010)(Personal interviews, June 2011)(Central Bank of Armenia website; company websites; personal Interviews: July 2011; Financial System Ombudsman website).(World Bank, Doing Business 2011; Personal interviews, June 2011)(Personal interviews: July 2011; World Bank, Doing Business, 2011.)(Personal interviews, June 2011)(Central Bank of Armenia website, company websites; personal Interviews: July 2011)

(EIU Risk Briefing, July 2011; Personal interviews, June 2011)(Moody’s Investors Service; EIU Country Risk; Personal interviews: July 2011)

Azerbaijan Bangladesh Bolivia Bosnia Brazil Cambodia Cameroon Chile China

(Brown and Jacobs, 2010; Central Bank; CGAP March, 2009; Microfinance Centre for CEE & NIS 2007; Microfinance Centre, IFC, 2010; Microscope, 2010; Investor Letter 2008; MIX Market report 2006, 2009; personal Interviews, June 2011; World Bank, Doing Business 2010.)(Microcredit Regulatory Authority November 2010 circular; Bangladesh Bank, Banking Regulation and Policy Department Circular No. 10, March 10th, 2010; MRA, Credit and Development Forum, Bangladesh; Grameen Bank website; personal interviews: June 2011; Dewan, 2011)(Banco de Desarollo Productivo; Central Bank of Bolivia; Mix Market; MF Transparency Bolivia; personal interviews: June-July 2011)(CGAP Microfinance & Banking Laws/Regulations;, Summary of Client Protection in Bosnia and Herzegovina, 2011; Mix Market, 2011; Law on the Central Bank of Bosnia and Herzegovina of 1997 (amended through 2006); Law on Banks for the Federation of Bosnia and Herzegovina of 1998 (amended through 2003),;Law on Microcredit Organizations of the Federation of Bosnia and Herzegovina (enacted in 2006); Decree on the Supervision of Microcredit Organization Business Operations (enacted in 2007); Economist Intelligence Unit (EIU) Microscope Survey, 2011; Personal Interviews: July 2011.) (Meagher et al, 2006; personal interviews: May 2009, March-April 2010, June 2011; regulation Programa Nacional de Microcredito Produtivo Orientado, 2005; Rosales, ICC, August 2008.)(NBC, Law on Banking and Finance, 1999 and Prakas B7.00-06 on Registration and Licensing of Microfinance Institutions (2000); Amendment to of Prakas on Licensing of microfinance Institutions (2006); Prakas on The Maintenance of Minimum Reserve Requirement in Banks and Financial Institutions (2009); Banking With the Poor; CGAP 2005; International Development Law Organisation 2008; Microfinance Gateway; personal interviews: June 2009, April 2010, July 2011; PlaNet Finance 2008.)(Personal interviews: June 2009, April 2010; June 2011; Recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale (Collection of microfinance regulations in CEMAC), October 2002 ; the Cameroon Microfinance portal; Planet Rating CEC, Cameroun 2010 ; BEAC, July 2010)(Personal interviews June-July 2011; Financial Legislation (Law 18.101); Economist Intelligence Unit (EIU) Microscope Survey, July 2011)(Personal interviews July 2011, CBRC and PBC regulations as translated by Planet Finance 2011, Planet Finance 2011. KPMG 2010, World Microfinance Forum Geneva 2010.)(Azerbaijan Law on Non-Bank Credit Institutions, 2009; Brown and Jacobs, 2010; MIX report 2009; personal interviews, March 2010.)(Speech: “Microfinance regulations: Who benefits?”, Dhaka, March 15th-17th 2010, Sir Fazle Hasan Abed; CGAP focus note, 2006; Microcredit Regulatory Authority; MIX Market; personal interviews: March 2010, June 2011.)(ASFI; EIU Microscope Survey 2011; personal interviews: June-July 2011)(CGAP Microfinance & Banking Laws/Regulations; Mix Market 2011; Law on Microcredit Organizations of the Federation of Bosnia and Herzegovina (enacted in 2006) ; Decree on the Supervision of Microcredit Organization Business Operations (enacted in 2007); Decree on Requirements and the Procedure for Issuing and Revoking the Operating Permit (enacted in 2007); Decree on Requirements and the Procedure for Issuing the Operating Permit to a Microcredit Foundation Formed Upon the Microcredit Organization's Change of Form (enacted in 2007); Personal Interviews, July 2011; EIU Microscope Survey, 2011)(Curat et al, 2007; Meagher et al, 2006; personal interviews: May 2009, March-April 2010, June 2011; Lei nº 12.126, December 16, 2009)(Cambodia Microfinance Association list of members; Banking With the Poor; CGAP 2005; International Development Law Organisation 2008; PlaNet Finance 2008; Microfinance Gateway; personal interviews: June 2009, April 2010, July 2011.)(Personal interviews: June 2009, June 2011; Recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale (Collection of microfinance regulations in CEMAC), October 2002 ; International Development Law Organization, 2007; Finance Law Circular Letter, 2010; ACEP Planet Rating, 2008.)(EIU Microscope Survey, July 2011; Personal interviews, June-July 2011)(CBRC regulations as translated by Planet Finance 2011; Personal interviews July 2011; Planet Finance 2011, Asian Development Bank 2010.)(Azerbaijan Law on NBCIs 2009; Brown and Jacobs, 2010; personal interviews, June 2011; Microfinance Centre for CEE & NIS 2007; MIX report 2009.)(CGAP focus note, 2006; MRA, “Microfinance regulations in Bangladesh: Development and Experiences”, MRA paper presented at the International Conference on Microfinance, March 15th-17th 2010, Dhaka; personal interviews: June 2010, June 2011.) (ASFI; EIU Microscope Survey 2011; personal interviews: June-July 2011)(CGAP Microfinance & Banking Laws/Regulations; Mix Market 2011; Law on Microcredit Organizations of the Federation of Bosnia and Herzegovina (enacted in 2006) ; Decree on the Supervision of Microcredit Organization Business Operations (enacted in 2007); Decree on Requirements and the Procedure for Issuing and Revoking the Operating Permit (enacted in 2007); EIU Microscope Survey, 2011; Personal Interviews: July 2011.)(Meagher et al, 2006; Microfinance Gateway; personal interviews: May 2009, March-April 2010, June 2011; Lei nº 12.126, December 16, 2009)(Banking With the Poor 2009; CGAP 2005; International Development Law Organisation 2008; Microfinance Gateway; personal interviews: June 2009, April 2010, July 2011; PlaNet Finance 2008.)(Sources: Personal interviews: June 2009; Recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale (Collection of microfinance regulations in CEMAC), October 2002.)(EIU Microscope Survey, July 2011; Internal Tax Service, Government of Chile; Personal interviews, June-July 2011)(Personal interviews July 2011, Asian Development Bank 2010, microfinance forum 2010, MIX market 2011.)(Brown and Jacobs, 2010; personal interviews, June 2011; Microscope 2010)(Dewan, 2011; Personal interviews: June 2011; MRA website.) (ASFI; Cibils et al, 2006; EIU Microscope Survey 2011; IMF Article IV Consultation for 2011; personal interviews: June-July 2011)(CGAP 2011; Mix 2011; Personal Interviews: July, 2011)(Meagher et al, 2006; personal interviews: May 2009, March-April 2010, June 2011; Central Bank report on financial inclusion)(Banking With the Poor 2009; CGAP 2005; International Development Law Organization 2008; MicroCapital Monitor; PlaNet Finance 2008; personal interviews: June 2009, April 2010, July 2011.)(Personal interviews: June 2009, March-April 2010, June 2011; Recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale; Cobac, Annual Report 2007; World Bank, January 2010.)(Personal Interviews June-July 2011; Secretariat of Banks and Financial Institutions)(Personal interviews July 2011, Planet Finance 2011.) (Brown and Jacobs, 2010; MIX Market 2007, 2008; MIX Market report December 2009; personal interviews, June 2011)(Personal interviews: March-April 2010, June 2011; MRA, Microcredit Regulatory Authority Rules 2010; CGAP country profiles; Dewan, March 2011.)(ASFI; BancoSol; EIU Microscope Survey 2011; Prodem; personal interviews: June-July 2011)

Under the Law on MCOs, all microfinance institutions in FBiH and RS are non-deposit-taking financial organizations. Their business activities are restricted to disbursing microcredits. Given three rounds of financial crises that led to deposit losses, this law is unlikely to change, with no prospects for MCOs to be able to accept deposits; MCOs therefore can be expected to remain forced to fund themselves through donors, wholesale markets or retained earnings. Market experts regard this as a positive feature of the market as the potential risk associated with deposits with these institutions would be too high. (CGAP 2011; Mix 2011; Law on Microcredit Organizations of the Federation of Bosnia and Herzegovina (enacted in 2006); EIU Microscope Survey, 2011; Personal Interviews: July 2011)(Resolution 3211, June 30, 2004; Resolution 3881; Personal interviews, June 2011)(NBC, Prakas On Licensing of Microfinance Deposit Taking Institutions, 2007; MIX Market; Symbiotics September 2010; personal interviews: June 2009, April 2010, July 2011.)(Personal interviews, April 2010; Survey; Recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale (Collection of microfinance regulations in CEMAC), October 2002; ACEP Cameroon Planet rating, 2010.)(EIU Microscope Survey, July 2011; Article 86, General Law of Cooperatives; MIX Market)(Personal interviews July 2011, Economist Intelligence Unit Risk Briefing April 2010, China.org 2011, China Microfinance Association 2009.)

(Azerbaijan Microfinance Association, 2007; Brown and Jacobs, 2010; Newly Independent States Policy Forum on Microfinance Law and Regulation in Azerbaijan, 2003; Microscope 2010; personal interviews, June-July 2009, March 2010, June 2011.) (World Bank ROSC, Deloitte/IAS Plus; personal interviews: June 2011.)(Deloitte/IAS PLUS; EIU Microscope Survey 2011; Mix Market; personal interviews: June-July 2011; World Bank ROSC)(MIX Market report; OECD 2010; Personal interviews: July 2011)(Economist intelligence Unit, Country Commerce, September 2009; Deloitte/IAS PLUS; personal interviews: May 2009, March-April 2010, June 2011.)(NBC, Prakas B7-02-47, On Reporting Requirement for Registered NGOs and Licensed Microfinance Institutions; World Bank, Report of the Observance of Standards and Codes, 2007; Deloitte IAS PLUS; personal interviews, June 2009, April 2010; PlaNet Finance 2008; World Bank 2007)(Cemac Survey 2007; COBAC annual report 2007; personal interviews: June 2009, April 2010, June 2011; Cameroon Financial System Stability Assessment update 2009; COBAC, January 2010; Microfinance Law in the CEMAC zone; Compta-EMF website, 2011.)(Deloitte, IAS-Plus; General Banking Law; General Cooperatives Law Regulations; Personal Interviews: June-July 2011)(Personal interviews July 2011, China Orbit 2011, Deloitte 2011.)(CGAP and Microfinance Information Exchange (MIX), March 2011; World Bank, Doing Business 2011; personal interviews, June 2011.)(MRA circular, November 2010; personal interviews, June 2011.)(Central Bank of Bolivia; EIU Microscope Survey 2011; personal interviews: June-July 2011)(Personal interviews: July 2011; Supervisory Agency client complaint forms (website); MicroRate; and MFTransparency)(Personal interviews June 2011; Central Bank report on financial inclusion)(NBC, Prakas B7-01-115 on the Calculation of Interest Rate on Microfinance Loans (2001); Microfinance Gateway, April 2011; MFTransparency.org; Personal interviews, July 2011) (Personal interviews, June 2011 ; EIU Microscope Survey ; recueil des textes réglementaires relatifs à l’activité de microfinance dans la Communauté Economique et Monétaire de l’Afrique Centrale (Collection of microfinance regulations in CEMAC), October 2002 ; Minister of Finance circular letter ; Microfinance law in the CEMAC zone.)(Consumer Protection Law; Personal Interviews June-July 2011; EIU Microscope Survey, July 2011)(Personal interviews July 2011, China Microfinance Association 2011, Microfinance Transparency 2011.)(CGAP and MIX Market, March 2011; personal interviews, June 2011.)(Personal interviews, June 2011.)(ASFI; EIU Microscope Survey 2011; personal interviews: June-July 2011)(Personal Interviews: July 2011)(Personal interviews June 2011; Law nº 12.126, December 16, 2009)(Personal interviews, July 2011)(Republic of Cameroon, January 2011.)(Personal interviews: June-July 2011; Heritage Foundation Index of Economic Freedom 2011; Chilean National Consumer Service-SERNAC)(Personal Interviews July 2011, Economist Intelligence Unit Risk Briefing April 2010, World Bank Doing Business 2011.)(CGAP and MIX Market, March 2011; Personal interviews: March 2010, June 2011; World Bank, Doing Business 2011.)(Dewan, May 2011; World Bank “Doing Business 2011” Credit Information Index; Personal interviews: June 2011.)(EIU Microscope Survey 2011; personal interviews June-July 2011; World Bank Doing Business 2011)(Personal Interviews: July 2011; World Bank, Doing Business 2011)(Central Bank report on financial inclusion; Personal interviews: May 2009, March-April 2010, June 2011; World Bank, Doing Business 2011; news reports.)(Symbiotics Newswatch, May 2011; Microcapital Monitor, May 2011; Personal interviews: July 2011.)(Personal interviews: June 2009, March-April 2010, June 2011; World Bank, Doing Business 2011; Planet Rating CEC 2010.) (World Bank Doing Business 2011; Personal Interviews: June-July 2011)(Personal interviews July 2011, World Bank Doing Business 2011, China Daily 2010.)(Brown and Jacobs, 2010; Personal interviews, June 2011.)(Personal interviews, June 2010, June 2011; Bangladesh Bank, 2008; The Daily Star, 2010) (ASFI; CGAP, “Microfinance and Mobile Banking: The Story So Far”, July 2010; Kumar, Anjali et al, 2006; Personal interviews: June-July 2011; Denton, Peter, 2004.) (Personal interviews: July 2011; Company websites; various press articles.)(Central bank report on financial inclusion; personal interviews: June 2011)(Vision Fund website; Personal interviews, July 2011)(Sources: Personal interviews, April 2010, June 2011; Minutes of BEAC seminar on the regulatory environment for electronic money, June 2011; EIU Microscope survey, June 2011.) (General Banking Law; Personal Interviews: June-July, 2011; EIU Microscope Survey, July 2011)(Personal interviews July 2011, KPMG 2010, World Microfinance Forum Geneva 2010, GoMo News November 2010.)

(Personal interviews: June 2011.) (Economist Intelligence Unit “Risk Briefing” analysis; media reports; personal interviews: June 2011; Roodman, 2011.)(EIU Country Forecast, June 2011; EIU Microscope Survey 2011; EIU Risk Briefing, April 2011; IMF Article IV Consultation for 2011; personal interviews: June-July 2011)(Personal interviews, July 2011; local media)(EIU Risk Briefing; personal interviews: June 2011, media reports)(Personal interviews, July 2011)(Personal interviews, June 2011)(Personal interviews: June-July 2011; EIU Political Risk Assessment June 2011; Heritage Foundation Economic Freedom Index 2011)(Personal interviews July 2011.)

Colombia Costa Rica Ecuador Egypt El Salvador Georgia GhanaDominican

RepublicDem. Rep. of

Congo

(Decree 919; Economist Intelligence Unit, Country Finance, May 2009; Ley 590 de 2000; Finanzaspersonales.com Microfinance Gateway; personal interviews: May 2009, March 2010, June 2011; Resolucion 01 de 2007.)(Economist Intelligence Unit, Country Finance, February 2011; EIU Microscope Survey 2010 and 2011; personal interviews: March 2010, May 2009, June 2011.)(CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008; Ley 488-08 del 30 de diciembre 2008; Microfinance Gateway; Personal interviews: July 2009, April 2010, June 2011; PROMIPYME website; Secretariat for Industry and Commerce, 2007; Severino, June 2011; Portal Microfinanzas; Ortiz, March 2011)(CGAP diagnostic report 2007; Loi Relative à l’Activité et au Contrôle des Établissements de Crédit, 2002; Microfinance Gateway; personal interviews: June 2009, March 2010, June-July 2011.)The new constitution of September 2008 mandates the formation of separate superintendencies for the public, private and “social” financial systems, and the Ley de la Economia Popular y Solidaria (LEPS), which was passed in April 2011, now provides legislation for the creation of the superintendency (Superintendencia de Economía Popular y Solidaria) for the "popular and social" financial system. Until this legislation is enforced, however, the previous system, with its single superintendency (Superintendencia de Bancos y Seguros—SBS), remains in force. This Banking Superintendency regulates banks, financial associations, savings and credit mutual associations for housing, savings and credit co-operatives that exceed a certain size (until recently US$10m in assets), and investment and development corporations. Under a new co-operatives law passed in late 2009, any co-operative that takes deposits, whatever its size, is considered to practice financial intermediation, and therefore subject to prudential regulation (around 50 are in this category). However, the law does not treat them exactly the same as banks, increasing their ability to operate in more-leveraged fashion, and it is seen by some as overly lax on provisioning. Once it has been implemented, the LEPS will supersede this older law Similarly, the new superintendency will regulate non-deposit-taking co-operatives, which were supervised but not prudentially regulated by the Ministry of Social Welfare. A number of restrictions in recent years have made it difficult for microfinance institutions to cover their operating costs; these include successive tightening of limits on interest rates, outlawing of commissions and other caps—all of which are seen as posing significant obstacles. Under the new LEPS, previously unregulated NGOs, savings and credit unions and co-operatives will be subject to the same interest-rate caps. This will impair their ability to compete and force some out of certain sectors of the market since artificially low caps will not let them cover their costs. Lastly, there are two competing norms for the definition of microcredit, attendant risk categories, and provisioning requirements. (EIU Microscope Survey 2011; Microfinance Gateway; personal interviews: May 2009, March-May 2010, June-July 2011, regulations)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, April 2010; SANABEL, 2010; USAID, 2009; personal interviews, June 2011.)

("Ley de Bancos"; "Ley de Coperativas y Sociedades de Ahorro y Crédito"; "Country Finance: El Salvador"; "Anteproyecto de Ley de la Banca de Desarrollo de El Salvador"; "BFA abre créditos con 4% de interés"; "Inicia Análisis del Proyecto de Ley de Usura"; Personal interviews: June-July 2011; Economist Intelligence Unit (EIU) Microscope Survey, July 2011)(Personal Interviews, July 2011; MixMarket; CGAP; National Bank of Georgia; company websites)(Bank of Ghana, 2008; Microfinance in Ghana: An Overview; Bank of Ghana, Notice No. BG/GOV/SEC/2009/6; CGAP Regulation Centre Profiles; CGAP 2005 Paper; EIU, Country Reports, February 2010, June 2011; Microscope 2010; personal interviews: June-July 2011.)

(Microfinance Gateway; Superintendencia de la Economia Solidaria; personal interviews: May 2009, March 2010, June 2011.)(Economist Intelligence Unit, Country Finance, February 2011; personal interviews: May 2009, March 2010, June 2011.)(CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008; Microfinance Gateway; personal interviews: July 2009, April 2010.)(CGAP diagnostic report 2007; personal interviews: June 2009, March 2010, June-July 2011; media reports.)(Microfinance Gateway; Microfinanza: July 2006, personal interviews: May 2009, February-March 2010, June-July 2011, regulations, EIU Microscope Survey 2011, Superintendencia de Bancos del Ecuador)Under Article 12 of the draft General Rules, an MFC would not be able to grant a single loan in an amount that exceeds 5% of MFC equity (defined as the sum of paid up capital, reserves, and capitalization of profits after deducting deferred losses if applicable), with each loan also subject to an overall loan ceiling of EGP500,000.‐(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, April 2010; EFSA, 2010; IMF, April 2010; SANABEL, 2010; USAID, 2009; personal interviews, June 2011.)("Country Finance, December 2010; "Ley de Bancos" "Country Guide: El Salvador"; Personal interviews: June-July 2011.)(Personal interviews, July 2011; MixMarket; CGAP; National Bank of Georgia, company websites)

A new microfinance law due to be in force later in 2011 will bring together all of the previously disparate regulations (see above) in an effort to harmonize and simplify the regulatory framework for the sector. It should improve matters substantially, as market operators suggest that the current regime is slow, bureaucratic and makes it difficult for foreign investors to support the development of institutions with capital. (Bank of Ghana, 2008; Bank of Ghana, Requirements for Non-Bank Financial Institution Licences; CGAP 2005 paper; CGAP profiles; Microscope 2010; personal interviews: June-July 2011)

(Curat et al, 2007; Microfinance Gateway; MIX Market; personal interviews: May 2009, March 2010, June 2011.)The relevant laws under which NGOs may alternatively be constituted are the Law of Associations, Law of Foundations or Law of Civil Societies; all but two of the 15 Costa Rican microfinance institutions (MFIs) reporting data to MIX Market in May 2011 are NGOs (and all except one of these is unregulated). Although it is fairly easy to form an NGO and operate in microfinance, NGOs tend to be small and undercapitalised with the exception of ACORDE and ADRI (the two largest). They also lack access to international co-operation, given the country's more-developed status, or to much in the way of suitable public second-tier funding (although talks are now underway that would allow greater access to public funds as the 2008 Development Banking Law is implemented). NGOs are subject to the same taxes as regulated institutions but are prohibited from taking deposits or accessing capital markets. Supervision is provided by donors and MFI networks, both local and regional, the two largest being REDCOM and the Nicaragua-based REDCOMIF. (EIU Microscope Survey 2010 and 2011; personal interviews: March 2010, May 2009, June 2011.)(CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008; MIX Market; personal interviews: July 2009, April 2010, June 2011; EIU Microscope Survey, July 2011; Ortiz, March 2011)(CGAP diagnostic report 2007; personal interviews: June 2009, March 2010, June-July 2011.)(CGAP Microfinance Regulatory Centre, 2008; Garcés Dávila, regulations, personal interviews: August 2008, March-May 2010, June-July 2011, Red Financiera Rural, EIU Microscope Survey 2011)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, April 2010; EFSA, 2010; Moussa, Magdy, 2007; SANABEL, 2010; USAID, 2009; personal interviews, June 2011.)("Ley de Asociaciones y Fundaciones Sin Fines de Lucro"; "Servicio de registros de ONGs";"Anteproyecto de Ley de la Banca de Desarrollo de El Salvador"; Personal interviews: June-July 2011; EIU Microscope Survey, July 2011.)(Personal Interviews, July 2011; MIX Market; MicroCapital, USAID)

NGOs, community-based organisations, ROSCAs and ASCAs can provide microcredit services, but these unregulated institutions are not permitted to mobilise deposits. Most microfinance institutions (MFIs) listed on MIX market in 2008 are NGOs (11 of 16), supported by international funding. These informal institutions are widespread in Ghana and tend to be quite efficiently self-regulated. The Association of Financial NGOs (ASSFIN) was inaugurated in 2005 acts as an apex organisation of some financial organisations in Ghana, with 96 member institutions. Ghana Micro Finance Institutions (GHAMFIN) publishes performance benchmarks of MFIs, including the 40 registered FNGOs. Another informal segment altogether consists of different types of Susu agents, which can take deposits and are increasingly popular. The first of these are individual “Susu collectors” (informal savings agents) that provide savings services to rural and urban clients. Many of the individual Susu collectors are self-regulated through membership with the Ghana Susu Collectors Savings and Credit Association (GCSCA). Susu savings schemes are also operated and backed by licensed institutions such as RCBs, S&Ls, and some commercial banks. However, a third type of Susu agent (Susu Companies) is registered with the Registrar-General, and offers both savings and credit (where credit lines are extended as a multiple of savings). The rate of fraud and failure in this segment has reputedly been high, though this has not stopped the growing use and offer of such savings and credit schemes. (Amanor, Klien, Madelung, 2007; IFAD, President’s Report: Proposed Loan to the Republic of Ghana for the Rural and Agricultural Finance Programme, December 2008; IFAD, Ghana - Informal Financial Services for Rural Women in the Northern Region; Ghana Association of Microfinance Institutions (GHAFMIN); Microscope 2010; Personal interviews: June-July 2011).

(Microfinance Gateway; Personal interviews: May 2009, March 2010, June 2011; Rosales, ICC Report, August 2008.)(Economist Intelligence Unit, Country Finance, February 2011; Economist Intelligence Unit, Risk Briefing, March 2008; EIU Microscope Survey 2010 and 2011; personal interviews: May 2009, March 2010, June 2011.)(CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008; Microfinance Gateway; personal interviews: July 2009; April 2010, June 2011; PROMIPYME website; EIU Microscope Survey, July 2011)(CGAP diagnostic report 2007; personal interviews: June 2009, March 2010, June-July 2011; Draft Microfinance Regulation.)There is substantial, specialised capacity for regulation since the activity of microfinance is regulated (with specific risk categories, credit methodologies, provisioning requirements, etc) rather than specific types of institution. In addition, the banking superintendency (Superintendencia de Bancos) approved an external microfinance rating agency in 2009. However, a still unclear official definition of microcredit remains a problem The new superintendency for the popular and social economy will focus more closely on the “popular/social” economy and, under the new LEPS, previously un-regulated MFIs will come under the supervision of the new superintendency. It is not clear how this will work in practice and how closely the activities of the numerous providers will be regulated and what prudential requirements they will have to meet. There are often concerns about the political independence and credibility of the existing Superintendencia de Bancos.(Regulations, Personal interviews: May 2009, February-March 2010, June-July 2011, EIU Microscope Survey 2011) (CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, April 2010; EFSA, 2010; IMF, April 2010; Microfinance Information Exchange, 2011; SANABEL, 2010; personal interviews, June 2011.)("Estructura Organizativa: Superintendencia del Sistema Financiero"; "Segundo Madrugón Legislativo el Año para Unificar las Tres Superintendencias"; "Informe de Diagnóstico sobre el marco jurídico y normativo de la banca sin sucursales en El Salvador"; Personal interviews: June-July 2011)(Personal Interviews, July 2011; National Bank of Georgia; MIX Market; MicroCapital; CGAP; USAID) (Amanor, Klien, Madelung, 2007; CGAP Profile; IDLO report, Microfinance Sector in Ghana, November 2008; Microscope 2010; personal interviews: June-July 2011.)

(MixMarket; personal interviews June 2011; Aguirre et al. 2008 CGAP Report, Bernardo et al. 2005 Efficiency and Expense Preference Report, Superintendencia de la Economia Solidaria)(MIX Market; personal interviews: July 2011, REDCAMIF.)(CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008; Portal Microfinanzas case study, 2010; Personal interviews: June 2011; EIU Microscope Survey, July 2011; Microfinance Gateway, June 2009)(Microfinance Regulations & Instructions, BCC; "Programme d’Appui au Secteur de la Microfinance : Phase II (PASMIF II : 2010-2014)", United Nations Development Programme (UNDP), Microscope 2010, Policy Diagnostic for Access to Finance in DRC, CGAP, April 2007, Isern, Crenn, Lhériau, Masamba ; Draft MF Regulations; Personal Interviews, June-July 2011)(Regulations, personal interviews June-July 2011, Superintendencia de Bancos del Ecuador)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; Daily News Egypt, February 2010; EFSA, April 2010; EFSA, 2010; Moussa, Magdy, 2007; SANABEL, 2010; USAID, 2009; personal interviews, June 2011.)("Ley de Bancos"; "Ley de Coperativas y Sociedades de Ahorro y Crédito"; Personal interviews: June-July 2011)(Personal Interviews, July 2011; National Bank of Georgia; MIX Market; MicroCapital; CGAP; USAID) (Microscope 2010; Personal interviews: June-July 2011, Licensing requirements and operating rules for MFIs, BoG, July 2011)

(Deloitte/IAS PLUS; Latin American Venture Capital Association, Annual Scorecard on the Private Equity and Venture Capital Environment in Latin America and the Caribbean, April 2010; MIX Market; personal interviews: May 2009, March 2010, June 2011.)(MIX Market; eStandards Forum; PricewaterhouseCoopers IFRS adoption by country; Deloitte/IAS plus; EIU Microscope Survey 2010 and 2011; personal interviews: May 2009, March 2010, June 2011.)(Deloitte/IAS PLUS, accessed July 2011; Inter-American Accounting Association (IAAA), 2007; World Bank Report on Observance of Standards and Codes, December 2004; personal interviews: July 2009, April 2010.)(Deloitte IAS Plus, draft MFI Act ROSC April 2010, World Bank personal interviews: June 2009, March 2010, June-July 2011.)Annual external audits and ratings are required for regulated institutions, and these have been well enforced by the banks superintendency. Regulated institutions are required to publish the results of external audits on the superintendency's website. For Ecuador as a whole, IFRS are being implemented and are supposed to be in place by January 2012, as established by the Superintendencia de Companias. Theoretically, all entities that provide financial services to the public will be subject to these rules once they are in place. Under the existing rules, however, accounting transparency for non-regulated institutions is mixed. Some NGOs are "self-regulating” owing to organisations providing technical services, such as the Rural Financing Network (Red Financiera Rural—RFR), which also includes many regulated institutions. Over half the microfinance institutions listed in MIX Market for Ecuador had published details of their lending portfolios on the RFR's website at the end of 2010. However, degrees of transparency between currently non-regulated institutions can vary greatly.(IAF PLUS/Deloitte; personal interviews: May 2009, March 2010, June-July 2011, MixMarket, Red Financiera Rural)

The 2010 draft General Rules for Microfinance Companies, not yet in effect as of June 2011, states that the proposed MFCs would operate “with sound management policies, procedures and control systems according to international best practices,” which would include a requirement to put in place an internal audit system to assist the managers of the MFC in “achieving effective and efficient administration of its fiscal and operating functions.” Under Article 18 of the 2010 draft General Rules for MFCs, an MFC would have to comply with internationally recognized accounting and auditing standards (as reflected in Egyptian Accounting and Auditing Standards) and would have to be audited by an external auditor selected by the MFC's Board of Directors and registered at the EFSA. The 2010 draft General Rules also prescribe that an MFC would have to submit quarterly financial statements to EFSA.(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; Deloitte/IAS Plus, accessed July 2011; EFSA, April 2010; EFSA, 2010; IMF, April 2010; Microfinance Information Exchange, 2011; Moussa, Magdy, 2007; SANABEL, 2010; USAID, 2009; personal interviews, June 2011.)("Financing Reporting Framework in El Salvador"; "Report on the Observance of Standards and Codes"; "El Salvador: International Financial Reporting Standards"; "Servicio de registros de ONGs"; Personal interviews: June-July 2011, EIU Microscope survey, July 2011)(Personal Interviews July 2011, National Bank of Georgia, Company Annual Reports)(Sources: eStandards Forum Ranking; eStandards, Best Practice Report, Ghana, April 2009, March 2010; PriceWaterhouseCoopers, Ghana Banking Survey, 2009; World Bank, ROSC 2004, MixMarket Data 2009/10)

(Economist Intelligence Unit survey, March 2010; Microfinance Gateway; MIX Market; MFTransparency; personal interviews: May 2009, March 2010, June 2011.)Transparency in pricing is low for both regulated and, especially, non-regulated MFIs. Regulated financial institutions (both public and private) are required to provide information on effective interest rates on all forms of publicity, according to the Acuerdo SUGEF 10-07, but the enforcement capacity of SUGEF in this regard is weak. Many institutions therefore refrain from disclosing prices, making comparisons difficult among different products and lenders. Non-regulated MFIs seldom engage in self-regulation in price transparency, and there is little effort by MFI networks or donors to promote greater disclosure. This is partly because of the low levels of competition among MFIs and the widespread knowledge among potential clients that the state-owned banks (and to a lesser degree, downscaling commercial banks) are capable of offering lower rates.(Acuerdo SUGEF 10-07, personal interviews: June 2011)(Microfinance Gateway; MIX Market 2008; personal interviews: July 2009, April 2010, June 2011; Banco Central de la República Dominicana, June 2011; MF Transparency)(MIX Market; personal interviews June 2009, March 2010, June-July 2011.)

There are strong regulations enforcing the disclosure of effective interest rates, full terms of loans, commissions and fees (via the web, at branches and in reports to the superintendency). At present, these apply only to regulated institutions. For non-regulated institutions, whose practices vary, disclosure is better among those institutions in the RFR. Once the new LEPS has been implemented, institutions that were not previously regulated will come under these norms as well and potentially be subject to stricter rules on disclosure of interest rates. It is not yet clear how this will be enforced in practice, how efficiently the new superintendency will enforce interest-rate disclosure and how much of a priority it will be (as until now the main bank superintendency has enforced interest-rate disclosure among regulated institutions).(Regulations; personal interviews June-July 2011, Red Financiera Rural)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, 2010; USAID, 2009; personal interviews, June 2011.)("Financial Access 2010: The State of Financial Inclusion Through the Crisis"; "Ley de Bancos"; "Ley de Coperativas y Sociedades de Ahorro y Crédito"; Personal interviews: June-July 2011)(Personal Interviews, July 2011; Central Bank, MFT Transparency, MicroFinanza Rating srl, Mix Market) (CGAP Paper 2005; Mix Market; World Bank, Banking the Poor 2009; Personal interviews: June-July 2011.)

(MIX Market; IFC/WB Doing Business in Colombia; Alarcon Lozano et al 2010; personal interviews June 2011, SmartCampaign.org)(Personal interviews: June 2011; CNC, Consumidores de Costa Rica.)(Personal interviews, June 2011; ProConsumidor website; CORDAID, Marina Ortiz and Mario Davalos, Sondeo sobre las Microfinanzas en la República Dominicana, 18th November 2008)(Personal Interviews: June-July 2011, Draft microfinance legislation, World Bank, Doing Business 2011.)(Superintendencia de Bancos; personal interviews June-July 2011, EIU Microscope Survey 2011)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, 2010; Personal interviews, June 2011.)("Financial Access 2010: The State of Financial Inclusion Through the Crisis"; Personal interviews: June-July 2011)(Personal Interviews, July 2011; MixMarket; CGAP; National Bank of Georgia; IFC; Ombudsman’s Office)(Doing Business, World Bank, 2011; personal interviews, June-July 2011).(Microscope Survey, March-April 2010; Microfinance Gateway; personal interviews: May 2009, March 2010, June 2011; World Bank, Doing Business 2011.)

There is a small public registry, mostly restricted to information by and for banks, and three private bureaus. Both private and public bureaus are gaining increasing coverage, but regulated institutions tend to favour the use of private bureaus. The quality of data relevant to microfinance is mixed, and largely depends on the source: data from the private bureaus include mostly negative information (for example, default and late-payment history) but includes data from non-financial institutions (such as retailers and utility companies). Overall, Costa Rica continues to have a Depth of Credit Information Index score of 5.0 out of a maximum of 6.0 from the World Bank Doing Business project, which compares favourably with the regional average of 3.3 and even the OECD average of 4.7. The public registry has coverage of 23.3% (down from 24.3% in 2010 but up from 14.6% in 2009 and 6.1% in 2008), and private bureaus cover 56.0% (up from 51.6% in 2010). (Personal interviews: May 2009, March 2010, June 2011; World Bank Doing Business 2011.)(Personal interviews: July 2009, April 2010; World Bank, Doing Business 2011; EIU Microscope survey, July 2011)(Personal interviews: March 2010, June-July 2011; World Bank, Doing Business 2011.) (EIU Microscope Survey, March-April 2010; personal interviews: May 2009, March 2010; June-July 2011, World Bank, Doing Business 2011)(CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, 2010; SANABEL, 2010; USAID, 2009; World Bank, July 2008; personal interviews, June 2011)("Aval a la ley de protección a información crediticia"; "World Bank, Doing Business Credit Information Index"; Personal interviews: June-July 2011.)(World Bank, Doing Business 2011; Personal interviews: July 2011; Planet Rating)(Bank of Ghana, Act 773, 2008; Lawfields Business Law Bulletin, Issue No. 14 (October-December 2008); XDS website; personal interviews: June-July 2011; press articles; World Bank, Doing Business 2011, media reports)The government is promoting access through non-bank correspondents, and adoption of this model has been slow since the cost of building and operating a network is high. Subsidies or co-finances have been provided to NGOs, cooperatives, finance companies and banks to open new points of contact in municipalities of less than 50,000 inhabitants where there were the presence of such entities. The development of this strategy resources 27 entities in the network of the Bank the opportunity, to extend coverage to 324 new points of contact, 310 municipalities.

(Personal interviews: June 2011; CGAP Reports on Branchless banking (Nov 2008 and Jan 2010); Alarcon et al, New Agent Model. (2010))Banking services through agents are poorly developed in Costa Rica, with the majority of these being offered by the larger banks and therefore not specifically targeted at potential microfinance clients. There is no specific regulatory framework for these activities either. Geography is a major impediment for the development of a major agent-based market: the small size of the country and relatively efficient transport network means travelling to areas served by the formal banking sector is not prohibitive. Low population density also means there is a high concentration of the population in urban areas, particularly the San José metropolitan area, which is well served by bank branches. Further expansion of the mobile-banking sector will largely take place as more banks begin to emulate the services now offered by the early adopters of this technology. It is unclear, however, whether this will have a significant effect on microfinance institutions. (Personal interviews: June 2011.)(Persona interviews, June 2011; Jamaica Observer, March 2011; AFI, November 2008; Caribbean Financial Action Task Force, May 2011)(MIX Market; Microfinance Gateway; personal interviews: June 2009, March 2010; Personal interviews, March 2010, June-July 2011.)(Personal interviews: June-July 2011, Banco de Guayaquil, media reports) (CGAP, “Government and Policy: Regulation Center: Egypt,” accessed via the Internet June 2011; EFSA, 2010; EFSA, April 2010; USAID, 2009; personal interviews, June 2011)("Informe de Diagnóstico sobre el marco jurídico y normativo de la banca sin sucursales en El Salvador"; "Ley de Bancos"; Personal interviews: June-July 2011; EIU Microscope survey, 2011)(Personal Interviews, July 2011; company websites; National Bank of Georgia; Planet Rating) (IDLO report, Microfinance Sector in Ghana, November 2008; Microscope 2010; MIX Market; personal interviews: June-July 2011; press articles.)

(Economist Intelligence Unit, Colombia Risk update (June 2011), IMF World Economic Outlook (April 2011), personal interview June 2011.)(Personal interviews: June 2011.) (Personal interviews, June 2011; Bloomberg, June 2011; Associated Press, April 2011; EIU Country Report)(Media reports; Personal Interviews: June-July 2011.)(Personal interviews: June-July 2011, media reports)(EFSA, 2010; EIU, June 2011; personal interviews, June 2011)("El Salvador country profile"; "El Salvador Risk Briefing"; Personal interviews: June-July 2011)(Personal Interviews, July 2011; EIU Country Risk; World Bank Doing Business 2011; media reports)(Media reports, 2011, personal interviews: June-July 2011).

Guatemala Haiti Honduras India Indonesia Jamaica Kenya Lebanon

The Law on Bank

Kyrgyz Republic

(Government of the Republic of Haiti, Action Plan for National Recovery and Development of Haiti: Immediate Key Initiatives for the Future, March 2010; IDB internal memorandum, March 3rd 2010; personal interviews: May-July 2009, April-May 2010, June 2011; World Bank and IMF Haiti: Financial System Stability Assessment, February 2008; Deibert, “Banker” 2005; SwissRe, 2011; IDB, January-February 2011; EIU Country Report May 2011; ANIMH; SOGESOL; IDB MCN, 2010)(National Commission for Bank and Insurance; Superintendant of Securities and Other Institutions; Ley de Cooperativas de Honduras; Law of OPDFs; personal interviews: June 2011)(Asher and Shankar, October 2009; Malegam Committee Report, January 2011; Microfinance Gateway Highlights 2008; Personal interviews: June 2011; Reserve Bank of India, July 2008 and 2009, February and July 2011; RBI Monetary Policy Statement 2011-12 (Including Developmental and Regulatory Policies), May 3rd 2011; Hindu Business Line, June 2011; Business Standard, February 2011.)(Bank Indonesia; Banking With the Poor Network 2009; Martowijoyo 2007; Meagher 2006; Microfinance Gateway; Permodalan Nasional Madani; personal interviews: June 2009, March 2010, June/July 2011; PlaNet Finance 2008; Tempo January 2011.)(Central Bank of Jamaica, Microfinance Gateway, Personal Interviews: May 2009, March 2010, June-July 2011, Caribbean Group of Bank Supervisors' database; Jamaica Observer, May 18, May 19, 2011 Development Bank of Jamaica; EIU Microscope Survey 2011.)Under the existing regulatory framework, all credit operators are free to set interest rates, including banks, non-bank financial institutions (NBFIs, a legal categorization by the CBK for which no licensed institutions yet exist), DTMs and MFIs. However, burdensome reporting and other requirements imposed by the Central Bank hinder regulation and effectiveness of the sector, as they are a disincentive for unregulated MFIs to transform to regulated DTMs. This is exemplified by the fact that only 4 MFIs have transformed into DTMs. Additionally, provisioning requirements are burdensome for DTMs, as they are not yet completely appropriate for microcredit portfolios. The required capital adequacy ratio is 12% of total risk-adjusted assets, plus off-balance-sheet items, but only banks, licensed DTMs and licensed SACCOs are allowed to mobilise savings. Regulations for the 200 non-deposit-taking MFIs are yet to be put in place, although the Association of Microfinance Institutions in Kenya (AMFI) and the MoF are leading efforts to develop a comprehensive regulatory framework for them. Currently, these institutions are registered under the Companies Act (law 486), which requires submission of audited financial statements to the CBK. In 2007 the government launched the Woman Enterprise Fund and the Youth Enterprise Development Fund, with around KSh2bn each, which provide wholesale credit lines under market rates. Most of the funds are channelled through local MFIs. These programmes and other credit lines provided by the IFC and other development financial institutions are beginning to create competition to commercial MFIs, because even though their mandate is to operate in significantly underserved sectors, the capacity required to access these funds is at a level indicating that applicants are of a higher socioeconomic strata. In addition, Kenya Post Office Savings Bank (KPOSB) offers financial services, especially savings-mobilisation. KPOSB is a state-owned corporation established under the KPOSB Act and operates under that Act and the State Corporations Act under the oversight of the finance ministry. KPOSB operates a nationwide network comprising branches. (AllAfrica, various press articles; CBK, Microfinance Act, 2006; CBK website; CBK Bank Supervision Annual Report 2010; CBK press release (CBK licenses Uwezo); CBK press release (CBK licenses Remu); CGAP country profile; CGAP Financial Inclusion Regulation Center: Kenya, 2011; CGAP regulation and supervision series; EIU Microscope Survey 2011; KPOSB website; MicroCapital article January 20, 2011; Microscope 2010; MIX Market Kenya Country Briefing, July 2010; SACCO Societies Act, 2008; SASRA website; SASRA Circular No. 1 of 2010; SASRA release June 22, 2011; SMEP website; personal interviews: June 2011)(Asian Development Bank, 2003, 2004; Brown and Jacobs, 2010; CGAP, 2002, 2005 and 2009; CGAP website, Regulation Center: Kyrgyz Republic; COMTEX, 2009; IFC, 2007, 2008; EIU, Microscope 2010; Ledgerwood, White, and Brand, 2006; Microfinance Regulation and Supervision Resource Centre, August 2006; Molavi and Bedelbayeva, 2002; NBKR website, 2011; Law No. 124, 2002; personal interviews, June-July 2009, March 2010, June 2011; Tom Jacobs, MLDP 2004; World Bank, Report on the Observance of Standards and Codes, 2008.)(Banque du Liban; personal interviews: May-June 2009, April 2010, June 2011; SANABEL, 2009; UNDP, 2004.)

(EIU Microscope Survey 2010 and 2011; Personal interviews, June 2011, March 2010, May 2009.)(Personal interviews: May-July 2009, April 2010, June 2011; FONKOZE website; Fletcher report, 2010; Fonkoze 2001 newsletter; World Bank Doing Business 2011)(Personal Interviews: June 2011; OPDF Regulations Law)(Bhattacharjee and Staschen, 2004; Economist Intelligence Unit Country Finance, July 2009; Eschborn: GTZ, 2004; Microfinance Gateway Highlights 2008; Microfinance India, State of the Sector Report, 2009; NABARD, 2010; Personal interviews: June 2011.)(Bank Indonesia Microfinance Gateway; Banking With the Poor Network 2009; Martowijoyo 2007; Meagher 2006; Permodalan Nasional Madani; personal interviews: June 2009, March 2010, June/July 2011; PlaNet Finance 2008.) (Microfinance Gateway; Microscope on Microfinance Survey, June-July 2011; personal interviews: May 2009, March 2010, June-July 2011.)(CBK website; AllAfrica, various press articles; CBK press release (CBK licenses Uwezo); CBK press release (CBK licenses Remu); Microscope 2010; MicroCapital, January 20, 2011 article; SMEP website; SASRA website; SASRA circular, June 22, 2011; SASRA SACCO Application Form; personal interviews: June 2011)(Asian Development Bank 2003, 2004; CGAP report, 2002, 2005 and 2009; COMTEX, 2009; Brown and Jacobs, 2010; IFC World Bank Report, 2007, 2008; Ledgerwood, White, and Brand, 2006; Microfinance Regulation and Supervision Resource Centre, August 2006; Microscope 2010; personal Interviews: June-July 2009, March 2010, June 2011; Syminvest website; Tom Jacobs, MLDP 2004; World Bank, Report on the Observance of Standards and Codes, 2008.)(Personal interviews: May-June 2009, April 2010; June 2011; Economist Intelligence Unit, Microscope Survey 2011.)Around 300 NGOs (constituted as “foundations” or “civil associations”) operate in Guatemala, around 45 of which are in microcredit. It takes no more than four months and Q3,000-5,000 (US$370-610) to register an NGO. Twenty-two of the 23 Guatemalan MFIs listed in MIX Market in July 2011 are NGOs. Yet NGOs are subject to fairly steep taxation when using non-donated funds (value-added tax or VAT, income tax, a 5% gross assets tax or 35% tax on annual profits). NGOs lost a court case where they sought to have such taxes declared illegal. Public second-tier funding is expensive, available erratically and mostly in small amounts, and comes with interest rate caps. The lack of regulation and absence of an upgrading pathway (especially for the larger NGOs) permits operational flexibility and freedom to target clientele as organisations see fit; however, it limits their capacity to capitalise themselves, offer broader financial services and become more professionalised entities. NGOS have long sought to be allowed to offer deposit-taking, and a handful of them meet minimum capital and other requirements where they could undertake deposit-taking, but they have continued to be frustrated by the absence of a legal framework for upgrading and a long-awaited microfinance law. The combination of tax and funding difficulties with the continued absence of appropriate regulatory pathways leads to a downgrade in this year’s score. NGOs have continued to lose market share to banks, in part because of these difficulties. (EIU Microscope Survey 2010 and 2011; Personal interviews, June 2011, March 2010, May 2009; Fundación Real Instituto Elcano, April 15th 2004; MIX Market 2011.)(MIX Market; personal interviews: May-July 2009, April 2010; Haiti Reconstruction Fund, March 2011 report; Interim Haiti Recovery Commission; Fletcher report, 2010)(Civil Society Registration and Supervision Unit, Secretariat of the Interior and Population; Ministry of the Interior Agreement 770-A-2003; Personal Interviews: June 2011; Federation of Honduran Non-governmental Development Organisations; International Center for Non-Profit Law)

(Micro-Credit Ratings International Limited, 2006; Micro Financial Sector (Development and Regulation) Bill 41 of 2007; Microfinance Gateway Highlights 2008; Reserve Bank of India; M-CRIL, A Study of the Regulatory Environment and its Implications for Choice of Legal Form by Microfinance Institutions in India, 2005; Personal interviews: June 2011.)(Bank Indonesia Microfinance Gateway; Banking With the Poor Network 2009; Martowijoyo 2007; Meagher 2006; Permodalan Nasional Madani; personal interviews: June 2009, March 2010, June/July 2011; PlaNet Finance 2008.)(Development Bank of Jamaica, Bank of Jamaica, Personal interviews: May 2009; March-April 2010, June-July 2011.)

(AMFI website 2011; CGAP Financial Inclusion Regulation Center: Kenya; Gina Din communication, May 25, 2011; KUSCCO website; Microscope 2010; personal interviews: June 2011)(Asian Development Bank 2003, 2004; Brown and Jacobs, 2010; CGAP report, 2002, 2005 and 2009; COMTEX, 2009; IFC World Bank Report, 2007, 2008; Ledgerwood, White, and Brand, 2006; Microfinance Regulation and Supervision Resource Centre, August 2006; Molavi and Bedelbayeva, 2002; personal interviews, June-July 2009, March 2010, June 2011; Tom Jacobs, MLDP 2004; World Bank, Report on the Observance of Standards and Codes, 2008.)(Personal interviews: June 2011; SANABEL, 2009; Economist Intelligence Unit Microscope Survey 2011.)

(Economist Intelligence Unit, Country Finance, December 2010; IMF, 2009 Article IV Consulting and Second Review Under the Stand-By Arrangements, 2010; International Bank for Reconstruction and Development and International Finance Corporation, Country Partnership Strategy for the Republic of Guatemala, Report No. 44772-GT, August 2008; EIU Microscope Survey 2010 and 2011; US Country Commercial Guide: Guatemala, 2010; Personal interviews, June 2011, March 2010, May 2009.)(IMF, Haiti: Financial System Stability Assessment, February 5th 2008; personal interviews: May-July 2009, June 2011; Washington Post, July 2011) (IMF Stand-by Review May 2011; CNBS Regulations, CIRCULAR: SVOI-009/2003; Personal Interviews: June 2011; Honduran Cooperatives Institute, Secretariat for Industry and Commerce)Data collection by official agencies on the microfinance industry is uneven and published with a significant time lag. Mix Market covers over 140 Indian MFIs with a total loan portfolio of US$4.4bn covering 26.8m active borrowers. The most comprehensive annual review of developments in India’s microfinance sector is privately funded. A gradual relaxation by the RBI of BC guidelines over last 2-3 years has significantly contributed to the development of BC initiatives aimed at fostering financial inclusion. The RBI encourages the spread of mobile banking, which it sees as a means of pushing financial inclusion through the banking sector, and it has issued guidelines on pre-paid instruments. The guidelines facilitate services like micro remittances and savings for the ‘financially excluded”. The “New Pension Scheme” launched on May 1st 2009 and regulated by the Pension Fund Regulatory and Development Authority (PFRDA) is also targeting the “financially excluded” though its adoption and success are still questionable. (Malegam Committee Report, January 2011; Microfinance Gateway Highlights 2008; personal interviews: June 2011; Reserve Bank of India; Srinivasan, 2009; Business Standard, June 2011.)(Bank Indonesia Microfinance Gateway; Banking With the Poor Network 2009; Martowijoyo 2007; Meagher 2006; Permodalan Nasional Madani; personal interviews: June 2009, March 2010, June/July 2011; PlaNet Finance 2008.)(Economist Intelligence Unit, Risk Briefing; Microscope on Microfinance Survey, June-July 2011; personal interviews: May 2009, March 2010, June-July 2011, Caribbean Group of Bank Supervisors' database.)(AMFI website; CBK Guideline on Agent Banking 2010; CBK Bank Supervision Annual Report 2010; CGAP Financial Inclusion Regulation Center: Kenya; FSD Kenya Consumer Protection Diagnostic Study 2011; KUSCCO website; Microscope 2010; SASRA website; personal interview: June 2011) (Asian Development Bank 2003, 2004; CGAP report, 2002, 2005 and 2009; COMTEX, 2009; IFC, Matthew and Jacobs, 2010; World Bank Report, 2007, 2008; Ledgerwood, White, and Brand, 2006; Microfinance Regulation and Supervision Resource Centre, August 2006; Molavi and Bedelbayeva, 2002; personal interviews, June-July 2009, March 2010, June 2011; Tom Jacobs, MLDP 2004; World Bank, Financial Sector Assessment, 2007; World Bank, Report on the Observance of Standards and Codes, 2008.)(MIX Market, accessed June 2011; Personal interviews: May-June 2009, April 2010, June 2011; Economist Intelligence Unit Microscope Survey 2011.)

(Economist Intelligence Unit, Country Finance, December 2010; Personal interviews, June 2011; EIU Microscope Survey 2011.)(MercyCorps; Fletcher report, 2010)(Personal Interviews June-July 2011; EIU Microscope Survey, July 2011; CNBS Financial Reports)NBFCs, the largest MFIs (accounting for 75% of the sector in terms of outstanding loans in 2010), are not allowed to accept savings deposits without special approval. In order to do so, NBFCs need an investment-grade rating from a credit-rating agency, which is difficult to obtain. NGO-MFIs are also not permitted to accept deposits. Since MFIs are not at present considered as a separate class of NBFCs, no separate set of prudential norms has been prescribed. The draft proposal of the Microfinance Bill 2007, however, suggests that not-for-profit NGO-MFIs—accounting for only 10% of the sector in terms of client outreach—will be allowed to accept savings subject to certain conditions. The NGO-MFI must register with NABARD, have existed for three years, should have net own funds of at least Rs0.5m and should have “satisfactory” management. The draft bill does not specify a prudential limit on the size of deposits that an MFI can accept. The bill provides that registered NGO-MFIs would be able to mobilise only compulsory savings from Self-Help Groups (SHGs). The “Microfinance India State of the Sector Report 2009” concludes that “neither the RBI nor the government of India seems to be focusing on enabling savings through the microfinance bill”. The Malegam Committee highlights the possible systemic risk of permitting microfinance providers “to carry on the business of providing thrift services and thereby attracting public deposits”. The BC model has become more popular and its use has expanded and pilots for no frills accounts are ongoing. Both initiatives have helped people access savings services. Given strict regulations on savings, MFIs in the south of India have found creative ways to get around them. They are offering a popular savings product whereby the MFI provides a loan for the purchase of gold and the borrower repays the loan to own the gold at the end of a predetermined period.(Malegam Committee Report, January 2011; Microfinance India, State of the Sector Report, 2009; Shankar and Asher, 2009.)(Banking With the Poor Network 2009; Bank Indonesia website; personal interviews, June/July 2011.)(BoJ regulations, personal interviews June-July 2011.)

Other institutions still use compulsory savings accounts, but the view now taken by the CBK is that institutions taking deposits of any kind should be regulated. AMFI and the Ministry of Finance are currently drafting regulations around non-deposit taking financial institutions.(Sources: AllAfrica, various press articles; AMFI website; CBK press release (CBK licenses Uwezo); CBK press release (CBK licenses Remu); MicroCapital, January 20, 2011; CGAP Financial Inclusion Regulation Center: Kenya; CBK Guideline on Agent Banking, 2010; CBK Bank Supervision Annual Report, 2010; EIU Microscope 2010; EIU Microscope Survey 2011; SASRA website; SMEP website; Uwezo website; personal interviews: June 2011)(Brown and Ruth Jacobs, 2010; National Bank of the Kyrgyz Republic, “Registered nonbank financial institutions,” May 31, 2011; EIU, Microscope 2010; Personal interviews, June 2011; World Bank, Financial Sector Assessment, 2007)(Personal interviews: June 2011; SANABEL, 2009; Economist Intelligence Unit Microscope Survey 2011.)

Throughout the economy, IFRS are required for all listed and unlisted companies, and were first adopted as mandatory for larger companies in 2002, based on their 2001 version, and have since been updated periodically. For tax accounting, the Guatemala Institute of Public Accountants and Auditors (Instituto Guatemalteco de Contadores Públicos y Auditores—IGCPA) voluntarily adopted in 2009 the IFRS as issued by the International Accounting Standards Board (IASB) in 2008. In December 2010 the IGCPA also adopted the IFRS for small and medium-sized enterprises (SMEs). Despite general improvements in supervision and regulation, the supervision by the Superintendency of Banks of the accuracy of annual financial statements was put into question by the failure of several banks in 2007 and by consolidations and acquisitions in the sector. In September 2009 the banking superintendency presented to the Guatemalan Congress a number of reforms to the Law of Banks and Financial Groups. Among other things, the reform would set accounting standards for financial entities (except for insurance services and deposit-taking activities) and require financial groups to register the operations of all companies belonging to the group. Although a favourable committee vote was taken in February 2010, the full Congress had taken no action by mid-2011. Standards vary considerably at non-regulated institutions and depend to some extent on the requirements of external and international funders; in one important, NGO-dominated MFI network, institutions reportedly follow IAS, according to the network’s accounting manual (similar to that of regulated institutions used by the superintendency), reflecting improvements in recent years. Annual external audits are required for regulated institutions and some NGOs have made increasingly strong efforts at self-regulation and transparency, promoted by their networks and by external funders. Of the 21 Guatemalan NGOs given such ratings by MIX Market as at July 2011, all but one were given four or five-diamond ratings (indicating audited financial statements with auditor’s opinion and notes for at least two consecutive years, or better).(Deloitte/IAS PLUS; website, Superintendencia de Bancos; eStandards Forum; Personal interviews, June 2011, March 2010, May 2009; Economist Intelligence Unit, Country Finance, December 2010.)(Deloitte/IAS Plus; IDB internal memorandum, March 3rd 2010; Government of the Republic of Haiti, Action Plan for National Recovery and Development of Haiti: Immediate Key Initiatives for the Future, March 2010; personal interviews: May-July 2009, April 2010; World Bank and IMF Haiti: Financial System Stability Assessment, February 2008.)(Personal Interview July 2011; Technical Board for Accounting and Auditing Norms Regulations; Resolución JTNCA 001-2010)(Deloitte/IAS Plus; Economic Times, “Are corporates ready for IFRS?”, April 7th 2010; Bloomberg News, “Accounting rule deadline to be extended”, March 17th 2010; Microcapital online, 2009; Ministry of Corporate Affairs, February 2011; Personal interviews: June 2011.)(Asian Development Bank 2003; Deloitte/IAS PLUS; IMF ROSC; personal interviews: June 2009, March 2010, June/July 2011; PlaNet Finance 2008.) (Deloitte/IAS PLUS; personal interviews: May 2009, March 2010, June-July 2011.)(CBK Microfinance Regulations, 2008; MIX Market 2011; Microscope 2010; SACCO Regulations 2010; personal interviews: June 2011)(Brown and Jacobs, 2010; CGAP website, Regulation Center: Kyrgyz Republic; Ministry of Finance website; personal interviews: June-July 2009, March 2010, June 2011; World Bank, Report on the Observance of Standards and Codes, 2008.)(eStandards Forum, 2011; Garmeen-Jameel & IFC, 2008; MIX Market, accessed June 2011; UNDP, accessed June 2011; personal interviews: May-June 2009, April 2010, June 2011; World Bank, 2003.)(Personal interviews, June 2011, March 2010, May 2009; EIU Microscope Survey 2011.)(Personal interviews, June 2011; Fletcher report, 2010; Deibert, “Notes,” 2005; SMART Campaign Endorsers; SMART Campaign Interview, 2010)

(Financial System Law, Articles 55-6; Personal Interviews June-July 2011; EIU Survey, July 2011) (Malegam Committee Report, 2011; Economist Intelligence Unit, Country Finance, July 2008; personal interviews: June 2011; Microfinance India, State of the Sector Report, 2010; MIX Market; NABARD, 2010; Reserve Bank of India, January 2009; MFIN, July 2011.)(Bank Indonesia, bank websites, personal interviews, June/July 2011.)(Personal Interviews June-July 2011).(FSD Kenya Consumer Protection Diagnostic Study 2011; MIX Market 2011; Poverty Matters Blog article July 13, 2011; Kenya Open Data Project website; MF Transparency website, 2011; Microscope 2010; personal interviews: June 2011)(CGAP and Mix, March 2011; Microscope, 2010; personal interviews: June-July 2009, June 2011.)(Personal interviews: June 2011; Smart Campaign Movement, accessed June 2011; Planet Rating, 2011; Economist Intelligence Unit Microscope Survey 2011.)

(Personal interviews, June 2011; EIU Microscope Survey 2011.)(Personal interviews, June 2011; ACCION, 2008; SMART Campaign Interview, 2010)(Personal Interviews June 2011; EIU Survey, July 2011; Heritage Foundation Economic Freedom Index 2011)(Sa-Dhan Code of Conduct, July 2011; Malegam Committee Report 2011; personal interviews, June 2011).(World Bank Doing Business 2011; Transparency International Global Corruption Barometer 2010.)(Economist Intelligence Unit Risk Briefing, personal interviews June-July 2011.)(FSD Kenya Consumer Protection Diagnostic Study 2011; personal interviews: June 2011)(CGAP/World Bank, 2010; CGAP and MIX, March 2011; personal interviews, June 2011.)(Personal interviews: June 2011; Economist Intelligence Unit Microscope Survey 2011.)(Personal interviews, June 2011, March 2010, June 2009; World Bank, Doing Business 2011.)(IDB internal memorandum, March 3rd 2010; personal interviews: May-July 2009, April 2010; Doing Business 2011.)(TransUnion Honduras; CNBS Regulations; Doing Business 2011)(Economist Intelligence Unit, Country Finance, July 2008; Personal interviews: June 2011; Wall Street Journal, March 9th 2010; Business Standard, May 30th 2011; World Bank, Doing Business 2011.)(Microfinance Gateway 2009; personal interviews: June/July 2011; World Bank Doing Business 2011; ADB.) (Doing Business 2011; Jamaica Observer February 16th 2011, February 11th 2011; personal interviews: March 2010, June-July 2011; BoJ regulations.)(CBK website; Kenya Credit Information Sharing Initiative website, April 2011 announcement; Microscope 2010; personal interview: June 2011; World Bank Doing Business Credit Information Index 2011)

(Brown and Jacobs, 2010; IFC, September 2010, April 2011; Ishenim website; personal Interviews: June-July 2009, June 2011; Microscope 2010; World Bank, Doing Business 2011.)(Personal interviews: May-June 2009, April 2010; World Bank, Doing Business 2011; Economist Intelligence Unit Microscope Survey 2011.)

(Personal interviews, June 2011; EIU Microscope Survey 2011.)(Microfinance Focus, September 2010 and January 2011; MercyCorps; Fletcher report, 2010)(Financial System Institutions Law, Article 15; Personal Interviews: June 2011)(Personal interviews: June 2011; MIX Market, 2010; RBI Notification Nov. 2009; Reserve Bank of India, “Report of the Working Group to Review the Business Correspondent Model”, 2009.)(Diagnostic Report on the Legal and Regulatory Environment for Branchless Banking in Indonesia 2009; Flaming, Prochaska, and Staschen, 2009; The Economist, April 2011; Personal interviews: June 2011; Mobile Business Briefing, June 2011.)(Personal interviews June-July 2011, Jamaica Information Service, Jamaica Observer January 17th 2010.)The Central Bank of Kenya issued a Guideline on Agent Banking in 2010, to govern how agent banking services will be carried out in Kenya in order to ensure the safety of the banking sector as well as to promote the use of agent banking in order to reduce the cost of financial services. In February 2011, the CBK announced the launch of a pair of draft regulations on electronic money issuers and electronic retail transfers, which aim to facilitate electronic payment services without compromising the safety and efficiency of Kenya’s National Payment System, while at the same time providing minimum standards for consumer protection. Thus, regulations provide a conducive environment for mobile banking that allow for a wide range of transactions to occur. Mobile microfinance services are also offered through commercial banks operating in microfinance, as well as MFIs. (CBK Bank Supervision Annual Report 2010; CBK Guideline on Agent Banking 2010; CGAP M-PESA Mobile Money video, 2011; EIU Microscope Survey 2011; FinAccess, “Financial Inclusion in Kenya, 2009; FSD Consumer Protection Diagnostic Study 2011; Microscope 2010; Mobile Money Africa, July 5, 2011; personal interviews: June 2011)(Personal Interviews: June 2011.)

There are few to no restrictions on MFIs establishing branches throughout the country. Al Majmoua has a total of nine branches throughout the country and continues to open two or three branches a year. However, set-up costs are continuing to increase, by as much as 200-300% annually, primarily because of price increases for real property. There are no regulations or technology in place to allow microfinance providers to offer services through a range of agents. The infrastructure for transactions through mobile phones or the Internet is lacking at present. However, improvements are being made, and mainstream banks are slowly starting to offer mobile and Internet banking as new channels for accessing credit and other financial services. (Personal interviews: June 2011; Economist Intelligence Unit Microscope Survey 2011.)

(Economist Intelligence Unit, Risk Briefing, June 15th 2011; Personal interviews, June 2011.)(Personal interviews, June 2011; media reports; EIU Country Report)(EIU Political Stability Forecast June 2011; Personal Interviews June-July 2011)(The Economist, November 4th 2010, “Microfinance in India: Discredited”: June 2011 personal interviews; The Indian Express, “Help Microfinance—Don’t kill it”, November 26th 2010.)(Personal interviews, June/July 2011.)(Personal interviews: June-July 2011, media reports.)(EIU Microscope Survey 2011; personal interviews: June 2011)(EIU Country Report, May 2011; Personal Interviews: June 2011.)(Micro Capital; Economist Intelligence Unit Country Report Lebanon, May 2011; Personal interviews: June 2011).

Madagascar Mexico Mongolia Morocco Mozambique Nepal Nicaragua Nigeria Pakistan

A grassroots mo

(Andrianasolo Paper, 2008; CGAP CLEAR Paper 2005; CGAP Portail Microfinance; Microfinance Madagascar; Microscope 2010; personal interviews: June-July 2011.)(Marulanda Consultores/DAI Mexico, Meagher et al, 2006; personal interviews: May 2009, April 2010, June 2011; Economist Intelligence Unit, Country Finance, March 2010; Microscope Survey, July 2011; private communication, ICC Consulting; Microfinance Gateway; ProDesarrollo)(Personal interviews: June/July, 2011; “Mongolia: Microfinance and Financial Sector Diagnostic Study”, 2011; IMF Country Report, 2011; CGAP on Mongolia Report, “Mongolia: Financial System Stability Assessment”, 2011; “Mongolia: the Microfinance Industry” Report, 2005)(Law 18-97, 1997; Law 34-03; Pierce, World Bank; Introductory Note of Law 53-10, 2011; personal interviews: June 2010, June 2011.)(Bank of Mozambique notice no. 4/GGBM/2005; BoM Microfinance Decree 57/2004; Club of Mozambique, “15,000 benefit from rural support programme,” November 16th, 2010; Economist Intelligence Unit Microscope Survey 2011; Microscope 2010; IFLR1000, “Mozambique: Legal framework of microfinance activities and institutions,” 2009; Law 15/99 as amended 9/2004; Mozambique News Agency AIM Reports, “Agriculture to yield over 2 million tonnes,” no. 277, June 7th, 2004; Mozambique News Agency AIM Reports, “President Guebeza launches agriculture campaign,” no. 411, October 19th, 2010; personal interviews: June 2011)(MicroSave, May 2011; Department of Cooperatives website; Sana Kisan Bikas Bank website; Armin Hofmann and Helmut Grossmann, December 2005; Banking With the Poor Network 2009; Centre for Microfinance; Microfinance Gateway; personal interviews: June 2009, April 2010, June 2011; Rural Finance Nepal/GTZ, February 2004; Sinha & Sagar, 2007; Ulrich Wehnert, Dhakal 2010.)("Ley General de Bancos, Instituciones Financieras No Bancarias y Grupos Financieros"; "Ley Reguladora de Préstamos entre Particulares"; "Ley de Fomento y Regulación de las Microfinanzas"; "Ley General de co-operativas"; "Country Finance 2011"; "Country Report, August 2010"; "Principios para reforzar el marco institucional/regulatorio de las Instituciones de Microfinanzas"; "Regulation and Supervision of Microfinance in Nicaragua"; "Nicaragua: Sixth Review under the Extended Credit Facility and Financing Assurance Review"; "Críticas para nueva ley nicaragüense"; "Alba Caruna ahora le presta a las microfinancieras"; "Ley prohíbe créditos de usura"; Personal interviews: April 2010, July 2011; Economist Intelligence Unit (EIU) Microscope Survey, July 2011(CBN Regulation 2001; CBN Regulatory and Supervisory Framework for Microfinance Banks in Nigeria, 2005; CBN Revised Microfinance Policy Framework for Nigeria, 2011; CBN Press Conference, 2010; CBN Press Release, 2010; CBN List of MFBs, 2011; CBN Circular April 2011; CBN Regulatory Guidelines; CGAP Access to Finance in Nigeria, 2009; EIU Microscope Survey 2011; Microfinance Africa article, July 12, 2011; Microscope 2010; personal interviews: March 2010, June-July 2011.)(State Bank of Pakistan, Strategic Framework for Sustainable Microfinance, January 2011; MIcroCapital Monitor, June 2011; Symbiotics Newswatch April 2011; CGAP 2007; Microfinance Gateway November 2010; personal interviews: June 2009, April 2010; Pakistan Microfinance Network; PlaNet Finance 2008; SEEP Network 2008; SMED Circular No. 10, 2006; State Bank of Pakistan, MicroCapital Monitor; World Bank, Banking With the Poor, 2009.)(AccèsBank Madagascar and Bank of Africa; Andrianasolo Paper, 2008; Central Bank; CGAP Paper 2005; CGAP, Microscope 2010; Portail Microfinance; personal interviews: June-July 2011.)(Meagher et al, 2006; Rosales, ICC, August 2008; personal interviews, April 2010, May 2009, June 2011; Economist Intelligence Unit, Country Finance, March 2010, Microfinance Gateway.)"

(Microscope 2010; Personal Interviews, June/July 2011, “Report on the Observance of Standards and Codes Mongolia: Accounting and Auditing”, 2008.)(Circulaire du Gouverneur de Bank Al-Maghrib, 2006 ; CGAP diagnostic report, 2005; Policy Forum for the Arab World May 2009 CGAP presentation; personal interviews: June 2009, June 2010, June 2011; Law 18-97, 1997; Law 53-10, 2010; Loi bancaire Marocaine (Moroccan banking law), 2006.)(Arcubus website; BoM website; FDM website; Microfinance Africa, “The First Micro-bank Mozambique is inaugurated as a rural microfinance bank,” May 11th, 2010; Microfinance in Mozambique, 2005; Mozambique News Agency AIM Reports, “Private banks ‘responding positively,’” No. 386, September 23rd, 2009; personal interviews: June-August 2009, March-April 2010; July 2011)(Banking With the Poor Network 2009; Centre for Microfinance; Microfinance Gateway; NRB Website Banking and Financial Institution Statistics, April 2010; Sinha & Sagar, 2007; personal interviews: June 2009, April 2010, June 2011; PlaNet Finance 2008; MicroSave, May 2011; NEFSCUN 2010.)("Ley General de Bancos, Instituciones Financieras No Bancarias y Grupos Financieros"; "Ley de Fomento y Regulación de las Microfinanzas"; "Country Profile, Nicaragua"; "Nicaraguan Microfinance Institution Banco del Exito (BANEX) to be liquidated"; "Country Report Nicaragua: August 2010"; Personal interviews: April 2010, July 2011; EIU Microscope Survey, July 2011)

On the other hand, requirements for conversion to MFB licence from a non-governmental organisation (NGO) are quite rigorous, and involve a long process of supervision and inspections. Microfinance regulations encourage, but do not require, all NGOs with total assets greater than N20m to transform into an MFB. The process includes upgrading the microfinance management team, internal controls, the management information system (MIS) and external audits. In addition, the CBN announced a new requirement for MFI management to undergo a certification programme, which it subsidizes. NGOs must also separate the social functions of the transforming NGO-MFI from the credit/financial services by creating a separate MFB. These conditions, along with the higher registration fees, have made the process very costly, restricting NGO transformation. In fact, until 2008, the CBN had assisted only eight foreign NGOs to transform to MFBs. Lift Above Poverty Organization (LAPO) is the largest NGO-MFI in Nigeria, which attempted to transform into a registered bank with Opportunity International. However, after three years, LAPO abandoned the attempt and has found that registering as a new MFB is significantly faster and more straightforward than transformation.(CBN website; CBN Press Conference, 2010; CBN Microfinance Policy, Regulatory & Supervisory Framework for Nigeria, 2006; CBN Revised Microfinance Policy Framework for Nigeria, 2011; CBN Prudential Guidelines for Deposit Money Banks in Nigeria, 2010; CGAP Access to Finance in Nigeria, 2009; Microscope 2010; personal interviews: March 2010, June-July 2011)(State Bank of Pakistan (various); CGAP 2007; Microfinance Gateway; Pakistan Microfinance Network; personal interviews: June 2009, April 2010; PlaNet Finance 2008; SEEP Network 2008; World Bank, Banking With the Poor, 2009.)

(Andrianasolo Paper, 2008; CGAP Paper 2005; CGAP, Portail Microfinance, personal interviews March 2010, June-July 2011.)(Meagher et al, 2006; personal interviews: May 2009, March 2010, June 2011; Microscope Survey, July 2011; MIX Market.).(Personal interviews, June/July 2011; Microscope 2010; “On the Legal Status of the Committee on Financial Regulations”, 2005)(CGAP diagnostic report 2005; Law 18-97, 1997; Policy Forum for the Arab World May 2009 CGAP presentation; personal interviews: May-June 2009, June 2011)(AMOMIF website; Bank of Mozambique Press Release No. 09/2011; BoM Press Release No. 13/2010; BoM website; Club of Mozambique, “15,000 benefit from rural finance support programme,” November 16th, 2010; Economist Intelligence Unit Microscope Survey 2011; Finscope website: Mozambique; IMF Mozambique Financial System Stability Assessment, 2010; Microfinance in Mozambique, 2005; Mozambique News Agency AIM Reports, “$12 million for micro-credit,” no. 272, March 18th, 2004; Mozambique News Agency AIM Reports, “Agriculture to yield over 2 million tonnes,” no. 277, June 7th, 2004; personal interviews: June-August 2009, March-April 2010; June-July 2011)(Banking With the Poor Network 2009; Centre for Microfinance; Microfinance Gateway; personal interviews: June 2009, April 2010, June 2011; PlaNet Finance 2008; Sinha & Sagar, 2007.)("Ley de Fomento y Regulación de las Microfinanzas"; "Ley Reguladora de Préstamos entre Particulares"; "Principios para reforzar el marco institucional /regulatorio de las Instituciones de Microfinanzas"; Personal interviews: July 2011)(CBN Revised Microfinance Policy Framework for Nigeria, 2011; CGAP Access to Finance in Nigeria, 2009; EIU Microscope Survey 2011; Microscope 2010; personal interviews: March 2010, June 2011)(Pakistan Microfinance Network website, Pakistan Poverty Alleviation Fund website, State Bank of Pakistan (various); CGAP 2007; Microfinance Gateway; SEEP Network 2008; Pakistan Microfinance Network; personal interviews: June 2009, April 2010; PlaNet Finance 2008; World Bank, Banking With the Poor, 2009.)(Andrianasolo Paper, 2008; CGAP CLEAR; Microscope 2010; personal interviews: June-July 2011.)(Marulanda Consultores/DAI Mexico, Meagher et al, 2006; personal interviews: March 2010, May 2009, June 2011; Economist Intelligence Unit, Country Finance, March 2010; Economist Intelligence Unit, Viewswire, 21st May 2009; Microscope survey, July 2011.)(Microscope 2010; Personal Interviews: June/July 2011; “On the Legal Status of the Committee on Financial Regulations” 2005; “Banking Law of Mongolia”, 2010)(Sources: CGAP diagnostic report 2005; personal interviews: May-June 2009, June 2011; FNAM code of conduct; Loi 18-97, 1997.)(Economist Intelligence Unit Microscope Survey 2011; IMF Mozambique Financial System Stability Assessment, January 2010; Microfinance in Mozambique, 2005; personal interviews: June-August 2009, March-April 2010; June-July 2011.)(Banking With the Poor Network 2009; Centre for Microfinance, MicroCapital Monitor, Dhakal 2010; personal interviews: June 2009, April 2010, June 2011; PlaNet Finance 2008; Sinha & Sagar, 2007; Kathmandu Post, June 2011; The Himalayan Times, June 2011.)("Ley de Fomento y Regulación de las Microfinanzas"; "Country Finance"; "Country Report: September 2010"; Personal interviews: April 2010, July 2011)(CBN website; CBN Press Conference, 2010; CBN Circular April 2011; CBN Microfinance Banks’ Returns Template; Microfinance Africa article May 2, 2011; Microfinance Nigeria article April 25, 2011; Microscope 2010; personal interviews: March 2010; June-July 2010)(State Bank of Pakistan, various, Securities and Exchange Commission of Pakistanl; CGAP 2007; Pakistan Microfinance Network; personal interviews: June 2009, July 2011; PlaNet Finance 2008; SEEP Network 2008; World Bank, Banking With the Poor, 2009.)(Instruction no 005/2007 11 May 2007, relative aux operations de microfinance.

While non-regulated SOFOMES cannot take deposits, SOFIPOS and SOCAPs are permitted to take deposits and offer micro-savings. In the case of SOCAPs, only members are permitted to take deposits, as opposed to the general public. Both entities are permitted to offer time, savings and current accounts, while SOCAPs are additionally permitted to issue debit cards although issuance has been low (SOFIPOS with the highest operational level, IV, are theoretically allowed to issue debit cards but no such institutions have been granted this category so far). There are also no requirements for minimum balances or fees for opening accounts. To accept deposits, SOFIPOS must go through a two-year waiting period after which a separate evaluation with the CNBV is necessary to ensure compliance with the necessary requirements on transparency, governance, sustainability and anti-money laundering. Know-your client and anti/money laundering regulations are not perceived as excessively burdensome Deposits in SOFIPOS and SOCAPs are covered by deposit insurance, offered by the finance ministry (SHCP) through a special protection fund. However, this protection extends only to regulated institutions, thereby leaving out the numerous unregulated SOCAPs (those under the basic operational level). Banks offer the widest range of services for capturing savings and are also covered by a more sophisticated deposit insurance known as the IPAB which was created in the wake of the 1994/5 financial crisis.(CNVB: Tercer Reporte de Inclusión Financiera, personal interviews: June 2011, KnowYourCountry)(“Mongolia: Microfinance and Financial Sector Diagnostic Study” 2009; “Mongolia: the Microfinance Industry” 2011 Report; Personal interviews: June/July 2011; “Banking Law of Mongolia”, 2010)(Law 18-97, 1997; Law 53-10, 2010; Loi bancaire Marocaine (Moroccan banking law), 2006.)(Microfinance in Mozambique, Microfinance in Mozambique Achievements, Prospects & Challenges, June 2006; PlaNet Rating Socremo Social Rating, April 2008; BoM Microfinance Decree 57/2004; BoM Notice No. 4/GGBM/2005; BoM Press Release No. 09/2011; BoM Press Release No. 13/2010; BoM website; Economist Intelligence Unit Microscope Survey 2011; IFLR1000, “Mozambique: Legal framework of microfinance activities and institutions,” 2009; IMF Mozambique Financial System Stability Assessment, January 2010; Microfinance Africa, “The First Micro-bank Mozambique is Inaugurated as a Rural Microfinance Bank,” May 11th, 2010; Mozambique News Agency AIM Reports, “Private banks ‘responding positively,’” no. 386, September 23rd, 2009; personal interviews: June 2011)(IMF 2011; IMF 2010; Nirdhan Nirdah Utthan Bank website; Personal interviews, June 2011) ("Ley General de Bancos, Instituciones Financieras No Bancarias y Grupos Financieros"; "Ley de Fomento y Regulación de las Microfinanzas"; "Ley General de co-operativas"; Personal interviews: July 2011)(AB MFB website; Alliance MFB via MIX Market; CBN Revised Microfinance Policy Framework for Nigeria, 2011; CBN Microfinance Banks’ Returns Template; NDIC website; Crest MFB website; EIU Microscope Survey 2011; IMFB website; personal interviews: June 2011)(State Bank of Pakistan, Strategic Framework for Sustainable Microfinance in Pakistan, Jan 2011; South Asia Microfinance Network website; personal interviews July 2011)

(Deloitte/IAS Plus; personal interviews: June-July 2009, March-April 2010, June-July 2011; World Bank, ROSC, 2008)(eStandards Forum; Personal interviews: May 2009, March 2010, June 2011; Deloitte/IAS PLUS; Economist Intelligence Unit, Country Finance, March 2011.)(Microscope 2010; “Mongolia: Microfinance and Financial Sector Diagnostic Study” 2009; “Report on the Observance of Standards and Codes Mongolia: Accounting and Auditing”, 2008; “Mongolia: Financial System Stability Assessment”, 2011; Personal interviews: June/July 2011)(MFI Financial stability report 2008; personal interviews: May-June 2009, June 2011; Law 18-97, 1997; Arrêté du Ministre des Finances et de la Privatisation no. 1672-07 du 9 rejeb 1428 (25 July 2007) relatif au plan comptable des associations de micro-crédit.)(BoM Notice No. 4/GBN/2007; Deloitte/IAS Plus; Deloitte Mozambique Highlights 2011; IMF Country Report Mozambique No. 11/149; Microscope 2010; MIX Market; Mozambique News Agency AIM Reports, “Economy growing at 10%,” no. 173, January 5th, 2000; personal interviews June-July 2011)(Deloitte IAS PLUS; personal interviews: June 2009, April 2010, June 2011; PlaNet Finance 2008.)("Country Finance"; "Financing Reporting Framework in Nicaragua"; "Country Level Effectiveness and Accountability Review"; Personal interviews: April 2010, July 2011; EIU Microscope survey, July 2011)(CBN Economic Report for the First Half of 2010, 2010; CBN Regulatory and Supervisory Framework for Microfinance Banks in Nigeria, 2005; CBN Revised Microfinance Policy Framework for Nigeria, 2011; EIU Microscope Survey 2011; Microfinance Africa article, May 4, 2010; Microscope 2010; MIX Market; personal interviews: June 2011) (SECP, Companies Ordinance of 1984; M-CRIL; MIX Market; personal interviews: June 2009, April 2010; World Bank, Banking the Poor, 2009; Deloitte/IAS PLUS; Microfinance survey, March-April 2010; personal interviews: June 2009, April 2010; PlaNet Finance 2008; SEEP Network 2008.) (CGAP CLEAR; MIX Market Interview; Microscope 2010; personal interviews: June-July 2011; World Bank, Banking the Poor, 2009.)

(Meagher et al, 2006; personal interviews: May 2009, March-April 2010, June 2011; CONDUSEF; Economist Intelligence Unit, Country Finance, March 2010; Economist Intelligence Unit, Viewswire, 21st May 2009; Microscope Survey, July 2011; Microfinance Gateway.) (“Banking Law of Mongolia” 2010; Microscope 2010; Personal interviews: June/July 2011.)(Loi n° 31-08 edictant des mesures de protection du consommateur ; personal interviews, June 2011.)(BoM Annual Report, December 2009; Finscope website; Microcapital article, June 10th, 2010; Microfinance Focus article, September 30th, 2010; Microfinance Focus article, July 18th, 2011; Microscope 2010; personal interviews: June-July 2011)(The Himalayan Post, 6 January 2011; M-CRIL; MIX Market 2009-10; personal interviews: June 2009, April 2010, June 2011; World Bank, Banking the Poor report 2009; EIU Microscope survey, July 2011.)("Ley General de Bancos, Instituciones Financieras No Bancarias y Grupos Financieros"; "Ley de Fomento y Regulación de las Microfinanzas"; "Financial Access 2010: The State of Financial Inclusion Through the Crisis"; "Principios para reforzar el marco institucional/regulatorio de las Instituciones de Microfinanzas"; "Ley prohíbe créditos de usura"; "Country Level Effectiveness and Accountability Review"; Personal interviews: July 2011)(CBN Regulatory and Supervisory Framework for Microfinance Banks in Nigeria, 2005; Microscope 2010; MIX Market; personal interviews: June 2011)(SBP, Microfinance Ordinance of 2001; Pakistan Microfinance Network Members’ Code of Conduct, 2009; SMART Campaign, SMART Notes No. 5, October 2010, personal interviews: July 2011).

(Economist Intelligence Unit, Country Profile, November December 2009, Personal interviews: March 2010, June-July 2011; Microscope 2010; World Bank, Doing Business 2009, 2010, 2011.)The Law for Protection and Defence of Financial Services Users (Jan 1999) established CONDUSEF as a specialised consumer protection agency for the financial sector. A reform to the law in 2009 has also given it significant supervisory capacity. Its jurisdiction encompasses all institutions in the financial sector, including institutions not regulated by the CNBV (a total of 3,129 institutions as of end-2010). CONDUSEF offers a dispute resolution mechanism involving conciliation, technical and legal defence (by presenting a case to the Public Ministry) for claims up to around US$1m for non-insurance financial institutions (nearly 90% of disputes, however, are under US$2,000). Under the 2009 reform, efforts have been made to streamline the conciliation process and reduce waiting times to a maximum of 60 days for issuing a technical resolution (in practice, waiting times are less than half that). There is also increasing usage of telephone and internet services, the latter through a specialised online portal which for the moment only covers major commercial banks (which are the focus of most claims). As such, most claimants must be present physically, making it difficult for those in more remote (particularly rural) areas. Technical resolutions by CONDUSEF have legal validity and may be used in court although such procedures tend to be lengthy and costly and are generally avoided by small claimants. Although the CONDUSEF's mechanisms are broad (and improving), there were concerns among respondents over the agency's overall efficiency and the costs of dispute resolution for microfinance users. (CONDUSEF, personal interviews: June 2011)(Personal interviews: June/July 2011; “Mongolia: Microfinance and Financial Sector Diagnostic Study” 2009; “Report on the Observance of Standards and Codes Mongolia: Accounting and Auditing” 2008)(Personal interviews, June 2011)(BoM Annual Report 2009; Economist Intelligence Unit Microscope Survey 2011; Finscope website; IMF Mozambique Financial System Stability Assessment 2010; personal interviews: June-July 2011)(Personal interviews, June 2011.) ("Financial Access 2010: The State of Financial Inclusion Through the Crisis"; "Ley de Defensa de los Consumidores"; "Ley de Fomento y Regulación de las Microfinanzas"; "Ley de Mediación y Arbitraje"; Personal interviews: July 2011)(CBN Economic Report for the First Half of 2010, 2010; CBN Regulatory and Supervisory Framework for Microfinance Banks in Nigeria, 2005; Consumer Protection Council website, 2011; EIU Microscope Survey 2011; Microfinance Africa, October 28, 2010; Microfinance Nigeria, May 31, 2011; personal interviews: June 2011)(SBP, Circular 17: Guidelines in Dealing with Customers’ Complaints, July 2004; Pakistan Microfinance Network Members’ Code of Conduct, 2009; SMART Campaign, SMART Notes No. 5, October 2010, personal interviews July 2011).

(Microscope 2010; Personal interviews: June-July 2011; World Bank, Doing Business 2011)There is a private bureau, the Buró de Crédito, that works with larger MFIs and banks have their own bureau; both report positive as well as negative information, and the quality of information is generally judged to be adequate. Smaller MFIs rely upon another bureau, the Círculo de Crédito, which was begun by retail banks as an alternative to the Buró de Crédito but focused on smaller borrowers who were often outside the scope of larger banks. Many MFIs are reluctant to report information on their clients; such reporting is not legally required, although second-tier funders make it a condition of on-lending. The quality of credit information is much greater in central than in southern Mexico (which are the two regions where MFIs operate most frequently). Financial consumer protection legislation still under consideration would strengthen the use of credit bureaus for credit scoring to determine interest rates for individual borrowers. Additionally, there are efforts to restrict access to funding sources to non-regulated institutions which do not consult or send information to the bureau (all MFIs using PRONAFIM funds are required to consult the bureaus). Overall, bureau coverage has grown significantly in recent years. Mexico scores 6 out of 6 on the World Bank Doing Business 2011 Depth of Credit Information Index and the study reports that private bureau coverage is 71.6% (down from 77.5% in 2011) of adults. (World Bank Doing Business 2011, personal interviews: March 2010, May 2009, June 2011; Microscope Survey, July 2011)(Microscope 2010; Personal interviews: June/July 2011; “Banking Laws of Mongolia”, 2010)(Personal interviews: 2009, 2010, June 2011; World Bank Doing Business 2011; central bank website; Jaida Fund, Analyse du prêt individuel et de l’endettement croisé, January 2011)(IMF Mozambique Financial System Stability Assessment, January 2010; MIX Market 2007; personal interviews: June-August 2009, March-April 2010, June-July 2011; Planet Rating 2008; World Bank, Doing Business 2011.)(Microfinance Gateway; personal interviews: June 2009, April 2010, June 2011; PlaNet Finance 2008; World Bank, Doing Business 2011.)("Country Level Effectiveness and Accountability Review"; "Microfinance in Nicaragua: Country profile"; "World Bank, Doing Business Credit Information Index"; "Ley de Fomento y Regulación de las Microfinanzas"; Personal interviews July 2011)(CBN Guidelines for the Licensing, Operations and Regulation of Credit Bureaus in Nigeria, 2008; EIU Microscope Survey 2011; Microscope 2010; personal interview: 2011)(MIcroCapital Monitor; Microfinance Gateway; Pakistan Microfinance Network: Pakistan Microfinance Review Annual Assessment of the Pakistan Microfinance Industry; personal interviews: June 2009, July 2011; PlaNet Finance 2008; SEEP Network 2008; World Bank Doing Business 2011.)

(Corporate websites; Microscope 2010; personal interviews: June-July 2011.)Despite the low score, there is confidence from authorities as well as MFIs that the new laws have established a regulatory framework more conducive to adopting these innovations in coming years. The low level of financial inclusion further encourages the expansion of these services given the limited coverage of the traditional banking sector in smaller cities and rural areas (only 7% of rural municipalities had a bank branch in 2010, jumping to 17% with correspondents).(Personal interviews: June 2011; CNBV: Tercer Informe de Inclusión Financiera; El Economista, 13 Jul 2009, 24 Nov 2010)(“Mongolia: Microfinance and Financial Sector Diagnostic Study”, 2009; “Mongolia: the Microfinance Industry” 2005 Report; Personal interviews: June/July 2011.)(Personal interviews June 2011; Maroc Telecom and Meditelecom websites; Finance news Hebdo, 2010)(BoM Press Release No. 09/2011; IMF Republic of Mozambique Letter of Intent, May 2011; Microscope 2010; Mobile Money Africa article July 20th, 2011; World Bank Africa Trade Policy Note, May 2010) (MicroSave, 2011; World Bank, 2007; personal interviews: June 2011) ("Innovative Technologies in Microfinance for Latin America: Building Effective Delivery Channels"; Personal interviews, July 2011" "Inicia operaciones de MPeso", Personal interviews, July 2011; EIU Microscope survey, July 2011) (Aitec Africa article, June 21, 2009; CBN Regulatory Framework for Mobile Payments Services in Nigeria, 2009; All Africa article July 3, 2009; Financial Technology Africa article; MemeBurn article February 3, 2011; Microscope 2010; Mobile Money Africa article April 26, 2011; personal interviews: March 2010, June 2011)(State Bank of Pakistan, Strategic Framework for Sustainable Microfinance in Pakistan Jan 2011; SBP, GUIDELINES FOR MOBILE BANKING OPERATIONS OF MICROFINANCE BANKS / INSTITUTIONS, March 2008; CGAP, Update on Regulation of Branchless Banking in Pakistan February 2010)

The disputed presidency has long hung over the country’s political decision-making process, leaving it deadlocked for over two years now. Market operators insist that in a practical sense there has been no impediment to the day-to-day operation of microfinance. However, US trade sanctions have affected demand for exports of some products and more recently there has been a noticeable decline in overseas funding provision. This does not affect all deposit taking activity, or providers that are either self-sufficient, or more reliant on funding from European or other non-US external sources. The one area that has attracted some controversy is the proposals for leasing of large tracts of farmland by overseas companies or organisations, to which strong objections have been made locally and by environmental NGOs.(MIX Market Report, April 2011; Microscope 2010; personal interviews: June-July 2011.)(“Mongolia: Microfinance and Financial Sector Diagnostic Study”, 2009; Personal interviews: June/July 2011; EIU Mongolia Report, 2011)(Personal interviews, June 2011; EIU Country Report, July 2011)(Economist Intelligence Unit Country Report: Mozambique, May 2011; Economist Intelligence Unit Microscope Survey 2011; World Bank blog, Africa Can End Poverty, September 30th, 2010)(Personal interviews, June 2011)("Country Report, July 2011"; "Country Report, September 2010"; "Country Report, March 2011"; "Principios para reforzar el marco institucional/regulatorio de las Instituciones de Microfinanzas"; "Country Finance 2011")(CBN Press Conference 2010; CBN Revised Microfinance Policy Framework for Nigeria, 2011; personal interviews: June 2011)(Personal interviews, June 2011.)

Panama Paraguay Peru Philippines Rwanda Senegal Sri Lanka Tajikistan Tanzania

Banks and finance companies are the main regulated institutions active in microfinance. Banks that hold a licence to operate as a microfinance bank only differ to other banks through the following requirements: they are set up as anonymous organisations and must have a minimum amount of paid up capital totalling PAB3m, as well as having a loan portfolio not less than 75% in credit, with a guarantee that this does not exceed 1% of net assets, while loans must not exceed 3% of net assets. All other requirements are similar to those imposed on the rest of the banking sector. Institutions are free to set interest rates, but frontline banks cannot lend to microfinance customers, as they would be lending at a nominal rate synonymous with that applicable to any normal banking customer. Some public institutions, such as the Banco de Desarrollo Agropecuario and Caja de Ahorros (BDA, Agricultural Development Bank), at times compete unfairly with private, regulated MFIs through low interest rates and other concessional terms reflecting subsidies, but this is sporadic and credit is aimed more at the small and medium-sized enterprise (SME) segment. Documentation and capital-adequacy requirements are not onerous. The Ministerio de Economía y Finanzas (the Ministry of Economy and Finance) lacks a clear, compelling definition and legal framework for microfinance. A 2002 law enabling the formation of microfinance banks was not taken up by any banks and did not contain a strict definition of microlending to delineate sector activities. Law 72 approved by the Assembly in November 2009 established a second-tier government fund and guarantees for micro-lending offered by regulated institutions. Further second-tier activity is expected to be introduced in the near future. As such future regulation of the sector is a bit uncertain, as it is not known what this future second-tier programme will entail, although it is assumed that they will not be able to lend directly to MFIs and that clients will have to go through the usual funding regulations, such as risk certification.(Personal interviews, June 2011)(Personal interviews: June-July 2011; EIU Microscope Survey, July 2011)(Ebentreich, 2005; Microfinance Gateway; Microscope Survey, July 2011; personal interviews: June 2009, March 2010, June 2011.)(Bangko Sentral ng Pilipinas, 2006, 2009, 2010, 2011; National Credit Council 2006; MicroCapital Monitor October 2010 & June 2011; Microfinance Gateway October 2010 & June 2011; personal interviews: June 2009, April 2010, June 2011.)(Banque Nationale du Rwanda (BNR) 2009; Kantengwa Paper 2009; Republic of Rwanda 2009; Rwanda Microfinance Assessment 2005; Financial Sector Development Secretariat, 2009; personal interviews, March 2010 and July 2011.) (BCEAO Instructions, 2010; Decret de Réglementation, November 1997; Lettre Politique Sectorielle, December 2004; PARMEC law, January 1995; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; personal interviews: June-July 2009; April 2010; June 2011.)(Legal Study on the Microfinance Sector in Sri Lanka 2010; GTZ ProMis and Banking with the Poor Network Microfinance Industry Report 2009; GTZ ProMis Report on Savings Mobilization by Microfinance Institutions in Sri Lanka 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews: July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009;. various press articles.)(Microfinance Information Exchange (MIX) and Association of Microfinance Organisations of Tajikistan (AMFOT), 2009; Microfinance Information Exchange (MIX) and Consultative Group to Assist the Poor (CGAP), March 2011; National Bank of Tajikistan (NBT) website: accessed July 2011; Personal interviews: June-July 2011.)(Central Bank 2006; CGAP Microfinance Portal; Economist Intelligence Unit, Country Profile, June 2011; FSDT, 2006/9, “Reviews of Access to Credit”; Gallardo and Randhawa 2003; Microfinance Regulation and Supervision Resource Centre, 2005; Microscope 2010; personal interviews: June-July 2011; United Republic of Tanzania, 2000.)While there is no legal framework for microfinance in terms of risk categories, provisioning, and the like, there is a specific type of banking licence for “special banks” that focus on microfinance. This was first used to authorise MiBanco to open a microcredit bank in 1996 with lower minimum capital requirements (US$3m instead of US$10m). Microfinance banks are regulated by the Superintendencia de Bancos, and are subject to the most rigid regulatory requirements. Co-operatives are regulated by IPACOOP (the Autonomous Co-operative Institute). Only banks and co-operatives are allowed to capture deposits. NGOs are overseen by AMPYME (Micro, Small and Medium Enterprise Authority), which regulates the industry, but standards remain lax. There are 200,000 micro and small enterprises in Panama, and 65% of these are informal. According to the Network of Panamanian Microfinance (Red Panamena de Microfinanzas), many institutions are afraid of a advancing to a formal arrangement because of the tax and administrative burden that arises from this transition. Documentation and governance structure requirements are therefore better suited to larger commercial banks and are deemed to be quite burdensome and costly for microfinance institutions (MFIs). A proposal currently under consideration on the basis of law 72 would designate a state-owned bank to distribute funds to first-tier regulated microfinance institutions in 2011. As of April 2011, 15 foreign and local consultancies in Panama were working on a dozen legislative bills to hasten and ease the transition to formality for the 42% of Panamanian MFIs that are unregulated. However, given that cooperatives moved US$1.4 billion in assets last year, the superintendent of banks has called for more regulation, with as many as 8/9 cooperatives now bigger than many small banks in Panama. There is therefore some discussion around pushing co-operatives and credit unions to be supervised and regulated by the banking superintendency in Panama.(Personal interviews: June 2011; REDPAMIF, April 2011)(Personal Interviews: June-July 2011; UltimaHora, November 2010; Abeceb.com, November 2010; World Bank Doing Business 2011)(Ebentreich, 2005; Microfinance Gateway; Microscope Survey, July 2011; personal interviews: June 2009, March 2010, June 2011.)(CARD Bank; central bank; Microfinance Gateway Highlights 2008; personal interviews: June 2009, April 2010, June 2011.)(BNR, 2009; Kantengwa paper, 2009; personal interviews, March 2010 and July 2011.)(BCEAO Instructions, 2010; Decret de Réglementation, November 1997; Lettre Politique Sectorielle, December 2004; PARMEC law, January 1995; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions; personal interviews: June-July 2009; April 2010 ; June 2011; DRS-Sfd Annual Report, 2010.)(Central Bank Financial System Stability Review, 2010; Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; GTZ ProMis Report on Savings Mobilization by Microfinance Institutions in Sri Lanka 2009; International Financial Corporation, Deposit Assessment in Sri Lanka 2011; Microfinance Institutions in Sri Lanka 2009; personal interviews: July 2011; Regional Economies Microfinance Sector Assessment 2009; Sri Lanka Connecting; various press articles.)(GTZ-AMFOT, July 2010; Microfinance Information Exchange (MIX) and Association of Microfinance Organisations of Tajikistan (AMFOT), November 2009; NBT website: accessed July 2011; Personal interviews: June-July 2011.)(Central bank 2006; CGAP Paper 2005; Microscope 2010; personal interviews: June-July 2011.)NGOs may operate in microfinance and they are tax-exempt, but they cannot take deposits. Not many microfinance NGOs exist, and they struggle to raise capital. The main issue with the formation of NGOs in Panama is not that it is particularly difficult to form them, but that it is hard to make these kinds of entities sustainable and therefore mature over time. Given a general proliferation of non-profit entities, the government has tightened registration requirements, which are administered by a special office of the Ministry of Economics and Finance (the Justice Ministry accords NGOs juridical status). Co-operatives are not prudentially regulated; one is listed in MIX Market, although work is also being furthered, by IPACOOP (the regulator of co-operatives), to ensure that co-operatives are better regulated. Some of the changes that are being discussed are related to the implementation of measures to strengthen liquidity reserves, security, delinquency and money laundering. The sending of reports with more detailed financial information, and on a periodic basis to IPACOOP through software tools, is another of the changes that is being discussed in the new initiative.(Personal interviews, June 2011)(Personal interviews: June-July 2011; EIU Microscope Survey, July 2011)(Microfinance Gateway; personal interviews: March 2010, June 2009; Microscope Survey, July 2011; Risolidaria Solidaridad en Internet 2004.)(MIX Market; National Credit Council and central bank, 2006; personal interviews: June 2009, April 2010, June 2011.)(BNR, 2009; Kantengwa Paper, 2009; personal interviews, March 2010 and July 2011; Republic of Rwanda, 2009.)(BCEAO Instructions, 2010; Decret de Réglementation, November 1997; Lettre Politique Sectorielle, December 2004; PARMEC law, January 1995; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; DRS-Sfd Remedial action plan for the microfinance sector, May 2011; DRS-SFD press release, February 2011; personal interviews: June-July 2009; April 2010 ; June 2011; DRS-Sfd Annual Report 2010) (Legal Study on the Microfinance Sector in Sri Lanka, 2010; Microfinance Industry Report, 2009; Microfinance Institutions in Sri Lanka, 2009; personal interviews: July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment, 2009; GTZ ProMis Impact Assessment of Microfinance in Sri Lanka, 2010; various press articles.)(Personal interviews: June-July 2011.)(CGAP Paper 2005; Microscope 2010; personal interviews: June-July 2011.)International organisations such as the IMF and the OECD have generally praised Panamanian regulators for their improved supervision of the financial sector. For example, the IMF noted in its Article IV Consultation Staff Report, published in July 2009, that Panama’s banks were financially sound, well-capitalised and subject to effective supervision. Panama’s principal banking regulatory law, Decree Law 9 of 1998, was revised in August 2008 by Executive Decree No. 52 to modernise and strengthen the ability of the Superintendencia de Bancos de Panamá (SBP) to regulate and supervise the banking system. The new law strengthened the legal basis for consolidated cross-functional supervision, extended bank supervision to include financial conglomerates, improved the bank resolution framework, and enhanced risk-adjusted capital requirements. The SBP’s capacity and regulatory demands are generally high, insisting on regular external audits for banks. However, the Superintendency’s capacity and specialisation in the area of microfinance is not as robust as for the financial industry more generally. IPACOOP have a specialized department dedicated to oversight of the microfinance industry, but they have greater limitations and less reach than the SBP. NGOs are self-regulated, with financial experts advising and recommending measures to promote transparency and efficiency. As a result, the regulatory environment is fragmented, and more flexibility is required. Data is collected and institutional checks carried out, but all the regulatory bodies need to develop better tools to monitor the industry. This pattern is also mirrored in terms of innovation, which remains traditional.(Personal interviews, June 2011)(Personal interviews: June-July 2011)(Ebentreich, 2005; Microfinance Gateway; Microscope Survey, July 2011; personal interviews: June 2009, March 2010, June 2011; Rosales, ICC, August 2008.)(National Credit Council and the central bank, 2006; Microfinance Gateway, March 2011; personal interviews: June 2009, April 2010, June 2010.)(Kantengwa paper 2009; Rwanda Microfinance Assessment 2005; personal interviews, March 2010 and July 2011.)(Order no. 5472 of 21 June 2010 on the organization of DRS- SFD, June 2010; DRS-Sfd Annual Report, 2010; BCEAO Instructions, 2010; Decret de Réglementation, November 1997; Lettre Politique Sectorielle, December 2004; PARMEC law, January 1995; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; personal interviews: June-July 2009, April 2010 , June 2011; DRS-Sfd Annual Report 2010)(Sources: Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews: July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009; International Financial Corporation, Deposit Assessment in Sri Lanka 2011; various press articles.)(ADB, 2010; IMF, June 2011; Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)Banks can capture varied forms of deposits (fixed, savings, checking, trust funds), and regulations are considered reasonable, focusing in particular on the origin of income. Guidelines are in-line with usual banking norms, minimizing risk. In terms of co-operatives, which can also capture savings identified above, IPACOOP has set out resolutions with guidelines, stating that savings and credit cooperatives must abide by rules around identifying their client, and declare when a cooperative client has deposited or taken out money in excess of PAB10,000 or successive transactions that amount to PAB10,000. This also applies to cheques, travellers’ cheques, lottery winnings and other forms of transactions, all with a view to stemming money laundering. Documents related to a financial institution's operations must be preserved for a period of 5 years. There are no restrictions on opening deposits faced by clients, although banks themselves must comply with regulations and the demands of knowing their client.(IPACOOP, November 2009; Personal interviews, June 2011)(Personal interviews: June-July 2011)(Ebentreich, 2005; Microfinance Gateway; EIU Microscope Survey, July 2011; Personal interviews: June 2011)(CGAP, Philippines Country-Level Savings Assessment 2005, National Credit Council & Bangko Sentral ng Pilipinas, 2006; Microfinance Gateway Highlights 2008; Personal interviews: June 2009, April 2010; Bangko Sentral ng Pilipinas; Co-operative Development Authority; MIX Market; Microfinance Gateway)(BNR, 2009; personal interviews, March 2010 and July 2011.)(Personal interviews: June-July 2011; Rapport sur la situation globale du secteur au 30 juin 2008; BCEAO Instructions 2010 ; DRS-Sfd Remedial action plan for the microfinance sector, May 2011; BCEAO, Note on the Microfinance regional support program, undated.)(Sources: Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews: July 2011; GTZ ProMis Report on Savings Mobilization by Microfinance Institutions in Sri Lanka, 2009; GTZ ProMis Impact Assessment of Microfinance in Sri Lanka, 2010; International Financial Corporation, Deposit Assessment in Sri Lanka 2011; various press articles.)(ILO, November 2010; Pytkowska, Justyna and Koryński, Piotr, November 2010; Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)

(Personal interviews, June 2011)(Personal interviews: June-July 2011; Solventa, October 2010; La Nacion, March 2011; ABC, March 2011)(eStandards Forum; CONASEV; Deloitte/IAS Plus; Microscope Survey, March-April 2010; personal interviews: June 2009, March 2010, June 2011; Procapitales; World Bank, Report on the Observances of Standards and Codes, June 2004; COPEME.)(Deloitte IAS Plus; NCC and central bank, 2006; personal interviews: June 2009, April 2010, June 2011.)(World Bank, Report on the Observance of Standards and Codes, 2008; personal interviews, March 2010 and July 2011.) (BCEAO Instructions, 2010; Lettre Politique Sectorielle, December 2004; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; personal interviews: June-July 2009; April 2010 ; June 2011)(Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009; Central Bank of Sri Lanka Annual Report 2010; various press articles.)(World Bank, Extent of Disclosure Index, Accessed July 2011; Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)Banks are required to state their interest rates (both nominal and effective), and clearly state whether they are fixed or variable on a periodic basis. The Superintendency of Banks introduced an amendment to existing laws in January 2011, outlining banks’ responsibility to divulge fees and charges to their customers, specifying that information should be easily accessible, via websites and brochures. These regulated institutions must also divulge effective interest rates in all advertising materials and financial reports. With non-regulated institutions, REDPAMIF is developing a framework to monitor pricing and ensure that NGOs clearly state interest rates on a monthly basis. There is scope for non-regulated institutions to self-regulate, but at the moment, there is no general fixed or widely accepted policy, which means that inadequate disclosure exists.

(Personal interviews, June 2011; Superintendencia de Bancos, January 2011)(Personal interviews: June-July 2011)Regulated institutions are required to disclose effective interest rates and fees in all forms of published media and publicity as well as at the point of sale. Clients are also provided with a Cartilla de Información (information outline) with a comprehensive description of all costs which they must sign. These are also updated every month on the SBS website where information is presented for all regulated financial institutions and includes data on effective APR as well as minimum and maximum fees charged on different types of loans. Non-regulated institutions are under no legal obligation to provide such information and many do not do so in practice. Non-regulated institutions incorporated into networks (such as the COPEME) also often refrain from publishing information on rates and fees. (Ebentreich, 2005; MIX Market; personal interviews: June 2011)(National Credit Council and National Anti-Poverty Commission, Microfinance Consumer Protection Handbook, 2007; Central bank; MIX Market; Microfinance Gateway April 2011; personal interviews: June 2009, April 2010, June 2011.)(Kantengwa paper 2009; Rwanda Microfinance Assessment 2005; MFtransparency.org, July 2011; World Bank, Banking the Poor report 2009; personal interviews, March 2010 and July 2011.)(Decree n° 2009-95 of the creation of the observatory for the quality of financial services, October 2008; BCEAO Instructions, 2010; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; personal interviews, June 2011)(Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews: July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009; World Bank Banking the Poor report 2009; World Bank, Business 2010; various press articles.)(MIX Market, Accessed July 2011; Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)Disputes that arise from transactions with regulated institutions are monitored and resolved by the Superintendency. For non-bank disputes, clients are protected by ACODECO (Authority of Consumer Protection); dispute procedures are considered to be easy to access and cost-effective. REDPAMIF is working on a code of ethics in financial education. One solution they are considering is to have more trained personnel in the area of microfinance, but this kind of dispute resolution would be confidential and would not cover extreme circumstances. Disputes are often resolved internally before reaching a stage where the authority needs to intervene.

(Personal interviews, June 2011)(Personal interviews: June-July 2011)(INDECOPI; CAMPECAM; personal interviews: June 2011; SBS/CGAP 2010)(National Credit Council and National Anti-Poverty Commission, Microfinance Consumer Protection Handbook, 2007)(World Bank Doing Business 2011; personal interviews, March 2010 and July 2011)(Decree n° 2009-95 of the creation of the observatory for the quality of financial services, October 2008; BCEAO Instructions, 2010; Law 2008-47 of 3 September 2008 supporting regulation of the decentralized financial institutions, September 2008; personal interviews June 2011)(Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; personal interviews: July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009; various press articles, EIU Microscope survey, July 2011.)(Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)(Personal interviews, June 2011; REDPAMIF, March 2011; World Bank Doing Business 2011)(Personal interviews: June-July 2011; World Bank Doing Business 2011)(Ebentreich, 2005; Microfinance Gateway; Microscope Survey, March-April 2010; personal interviews: August 2008, June 2009; World Bank, Doing Business 2010.)

Meanwhile, the private sector is pursuing its own initiative. The Banker’s Association of the Philippines (BAP) has its own credit bureau, which the Rural Bankers Association of the Philippines, the association of rural banks, is also using. BAP’s credit information database contains approximately 3.8 million accounts and information pertaining to unpaid loans, loans under litigation, bounced checks and credit card debt. To encourage rural banks to subscribe to the database BAP-CB lowered the fee for each inquiry from PHP11 (US$0.25) to PHP5.6 (US$0.13) and removed the upfront subscription fee. As of January 2011, twenty rural banks had joined the bureau. Access to credit information can help rural banks identify whether loan applicants already have outstanding loans and avoid the problem of over-indebtedness, which can be harmful to the borrowers, the banks and the sector as a whole. BAP’s credit bureau is almost exclusively for non-microfinance clients, however. Multiple indebtedness of clients remains one of the biggest concerns for the microfinance sector. However, unregulated NGO-MFIs and co-operatives, although they are large players in the industry, are not using it.(Symbiotics Newswatch, January 2011, April 2011; MIcroCapital Monitor January 2011; personal interviews June 2011.)(BNR, 2009; personal interviews, March 2010 and July 2011.)(World Bank, Doing Business 2011; personal interviews: June-July 2009, April 2010; June 2011.) (World Bank Doing Business 2010; Personal interviews, July 2011; Microfinance Institutions in Sri Lanka 2009; Legal Study on the Microfinance Sector in Sri Lanka 2009; various press articles; EIU Microscope survey, July 2011.)

(World Bank, Depth of credit information index, Accessed July 2011; Survey and personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)For banks branches are hard to establish, although their presence in urban areas can lower costs. For NGOs and co-operatives, establishing a branch is more straightforward, as they tend to locate in rural areas (most clients are involved in the agricultural sector), and because rural clients are most familiar with face-to-face transactions, this is also the most efficient means of doing business. In terms of innovation, there does appear to be appetite for more varied ways of carrying out transactions. However, because of the delineation between rural and urban patterns of doing business, banks have greater capacity to utilize technology. The structural capacity to handle technological advances in rural areas does not yet exist, and the complicated nature of modern technology means that microfinance clients often see mobile phone or wireless transactions as being too complicated. Regulators are responsive to development in this area, but there is still a reliance on physical networks, as well as telephone. As a result of the technological demands, POS transactions are usually the domain of the banking sector, and usually those with an urban presence. Mobile phone regulations do not exist, so it is partly a regulatory matter. However, there are trials in the correspondent banking sector, such as that of internet banking, and obtaining up-to-date details of an individual’s transaction history via email and text. However, this kind of development has yet to disseminate to the microfinance sector.

(Personal interviews: June 2011; MicroDinero, November 2010)(Personal interviews: June-July 2011)(SBS/CGAP 2010; personal interviews: June 2011)(Sources: BSP; Microfinance Gateway, May 2011; personal interviews June 2011).(Republic of Rwanda, 2010; personal interviews, March 2010 and July 2011)(Personal Interviews June-July 2009, April 2010, June 2011; Rapport d’etape sur l’etude de faisabilite mobile banking au senegal, 2009; Mix Microfinance World WAEMU Microfinance Analysis and Benchmarking Report, 2010; “Societe Generale and Obopay Bring Mobile Money to Africa” Press release, June 2010; BCEAO Instruction N°01/2006/SP)(Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews July 2011; various press articles, EIU Microscope survey, July 2011.)(GTZ-AMFOT, July 2010; NBT website: accessed July 2011; Survey and Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)

Although there is high exposure to risk in Panama, there has been no political development, current or predicted, that may have an adverse effect on the microfinance sector. Ricardo Martinelli remains a relatively popular president. His business-style approach to governance has allowed him to make rapid progress on his reform agenda, but this progress has attracted criticism that some reform bills have been poorly thought through or have not been submitted in the correct manner, forcing an about-turn in government policy in the face of public opposition. There are no elections due in the near future; the next presidential and legislative elections are scheduled for May 2014. In the meantime, the government will seek to introduce electoral reforms to strengthen its hold on power.(EIU Risk Briefing, July 2011; EIU Microscope Survey, July 2011)(Personal interviews: June-July 2011; EIU Country Report, July 2011)(Personal interviews: June 2011)(Personal interviews, June 2011.)(EIU Analysis, July 2011.)(Personal interviews, June 2011)(Economist Intelligence Unit Risk Briefing, April 2011; Legal Study on the Microfinance Sector in Sri Lanka 2010; Microfinance Industry Report 2009; Microfinance Institutions in Sri Lanka 2009; personal interviews July 2011; Sri Lanka Connecting Regional Economies Microfinance Sector Assessment 2009; World Bank, Doing Business 2010; various press reports.)(Media reports; Personal interviews: June-July 2011.)(Microscope 2010; Personal interviews: June-July 2011, Gerda Piprek, July 2007, Veneranda Mgoba, June 2007.)

Thailand Turkey Uganda Uruguay Venezuela Vietnam YemenTrinidad and

Tobago

(Bangkok Post, May 31, 2011; Microfinance Gateway; Microfinance Thailand website; personal interviews: March 2010, June 2011)(Financial Institutions Act; Personal Interviews: June-July 2011; Economist Intelligence Unit (EIU) Microscope Survey, July 2011)(Personal Interviews 2011 July, MixMarket 2011, CGAP, MFI, IFC and Bank websites)While the government is the 100% owner of some financial institutions, such as PostBank Uganda Ltd, a Tier-2 financial institution, and Pride Microfinance Ltd, a Tier-3 MDI, it does not subsidize their financial activities. A government-sponsored “Bonna Bagaggawale,” or “Prosperity for All,” programme supports the development of Tier-4 institutions, but informants report that the effects to date have not hugely impacted the operations or profitability of regulated institutions.(AllAfrica article, June 29, 2008; BoU website; BoU Financial Institutions Regulations: Capital Adequacy Requirements 2005; BoU Licensed Microfinance Deposit-Taking Institutions as at 31st Dec 2010; BoU Micro Finance Deposit-Taking Institutions Regulations: Licensing, 2004; Co-operative Societies Regulations, 1992; EIU Microscope Survey 2011; GIZ (formerly DED) website; The Observer, April 6, 2011; personal interviews: June 2011; Microscope 2010; PRIDE Microfinance website; World Savings Banks Institute Membership Directory)

República Microfinanzas (a separate SA under BROU) started operations in early 2010. So far, it does not appear to be undermining competition through subsidised rates, and interviewees stated that the new entity could lead to increased competition among players.(EIU Microscope Survey 2010 and 2011; Inter-American Development Bank, IDB, internal project document, August 4th 2005; personal interviews: June 2009, March-May 2010, June 2011; Interest-rate and Usury Law 18,212 of December 2007)(Economist Intelligence Unit, Country Finance, July 2009 and July 2010; Economist Intelligence Unit, ViewsWire, June 2009; Economist Intelligence Unit, Country Risk, April 2011; Economist Intelligence Unit, Financial Services, November 2010; Microscope Survey, March-April 2010, June 2011; personal interviews: June 2009, April 2010, July 2011; Law of Banking Sector Institutions, December 2010).(Personal interviews, June 2011; Nguyen and Vogel, 2011; State Bank of Vietnam, 2009; Trang, 2011; Van, 2011; Microfinance Information Exchange (MIX) Market: Vietnam Country Profile, Accessed July 2011; Duflos, 2011; Economist Intelligence Unit, Microscope Survey 2011.)(Personal interviews: June 2011; Social Fund for Development; 2010 SFD Annual Report; Yemen Microfinance Network website; Economist Intelligence Unit Microscope Survey 2011.)

(BOT, Financial Services Master Plan Phase II; Ministry of Finance, Microfinance Master Plan; Microfinance Gateway; Microfinance Thailand website, July 2010 blog post and “Institutional Options”; IMF 2010; personal interviews: March 2010, June 2011.) (Personal interviews, June-July 2011)(Personal Interviews 2011 July, Bank Websites, Central Bank, Hurriett Daily News, MixMarket, CGAP)

Since 2003, three MDIs have successfully scaled up to become credit institutions, most recently Faulu in 2009, which gradually transformed into a commercial bank. Banks are free to create microfinance divisions, but of the 23 commercial banks currently operating in Uganda, none has done so other than the Centenary Rural Development Bank and the new Equity Bank.(BoU, Licensed Commercial Banks in Uganda as at March 31, 2011; International Conference on Microfinance Regulation, March 15-17, 2010; Microscope 2010; personal interviews: June-July 2011)(IDB, internal project document, August 4th 2005; EIU Microscope Survey 2010 and 2011; personal interviews: June 2009, March 2010, June 2011; Economist Intelligence Unit, Country Commerce Uruguay report, April 2010 and April 2011).(Microscope Survey, March-April 2010; personal interviews: June 2009, April 2010, July 2011.)(Personal interviews, June 2011; Government of Vietnam, 2007; Government of Vietnam, 2004; National Assembly, 2010; EIU Microscope Survey 2011.)(Personal interviews: June 2011; 2009 Microfinance Law; Microfinance Network website.)

(Microfinance Gateway; Microfinance Thailand; MIX Market, 2010; personal interviews: March 2010, June 2011.)(Ministry of Finance Regulations; Personal Interviews: June-July 2011; Financial Institutions Act)(Personal Interviews July 2011, MixMarket, CGAP, Company Websites, Central Bank, Law on Foundations 2004) NGOs providing microcredit and SACCOs are both free to join Uganda’s umbrella MFI organization, the Association of Microfinance Institutions in Uganda (AMFIU), whose key reasons for existence include lobbying government, networking nationally and internationally and providing a forum where MFIs can have a common voice. As of 2009, AMFIU had 117 members, representing all four MFI tiers. While both AMFIU and SACCO apex organization UCSCU promote self-regulation and best practices, there is little evidence that self-regulation is widely followed.(ACCOCSA Facts: Uganda; All Africa, January 5, 2011; AMFIU website; AMFIU Member Directory 2009; EIU Microscope Survey 2011; Microscope 2010; personal interviews: June-July 2011; UCSCU website; UCSCU announcement March 15, 2011; Uganda Radio Network, July 8, 2010)(DIPRODE-OPP website, August 2010, June 2011; EIU Microscope Survey 2010 and 2011; personal interviews: June 2009, March-May 2010, June 2011.)(Microscope Survey, June 2011; Personal interviews: June 2009, April 2010, July 2011.)(Banking with the Poor Network, 2009; Personal interviews, June 2011; MIX Market: Vietnam Country Profile, Accessed July 2011.)(CGAP diagnostic report 2005; personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)

(Department of Co-operatives Promotion and the Department of Co-operative Auditing; BOT (2009), Financial Services Master Plan Phase II; The Nation, May 2011; personal interviews: March 2010, June 2011.)(Personal Interviews June-July 2011; Central Bank Regulations)(Personal Interviews July 2011, Central Bank, MixMarket, CGAP, IFC)The BoU Banks Supervision unit is divided into two departments, the Commercial Banking Department, which is responsible for Tier-1 institutions, and the Non-Bank Financial Institutions (NBFI) Department, which includes Tier-2 and Tier-3 institutions. The NBFI Department conducts annual on-site visits to MDIs and follows up with institutions to enforce off-site reporting requirements for the three existing MDIs and the three credit institutions. All examiners get specialised training to conduct adequate microfinance supervision and informants report that the regulatory restrictions are strongly enforced. This has not prevented criticism based on the argument that the BoU applies commercial banking standards to MDI supervision. The range of products that Tiers 1 through 3 may offer is clearly specified and communicated, and the BoU is perceived as having enforcement capacity. Tier-4 institutions are not properly supervised, however, and the Government of Uganda currently does not have the capacity to supervise the hundreds of SACCOs and NGOs offering microfinance services in the country. (BoU website, Supervision and Regulation FAQ; EIU Microscope Survey 2011; International Conference on Microfinance Regulation, March 15-17, 2010; Microscope 2010; personal interview: June 2011)

A Microfinance Observatory (Observatorio de Microfinanzas) was also established in August 2010 through collaboration by the government and Uruguay’s Universidad Católica. This bureau aims to strengthen transparency in microfinance services (information sharing and transparency) and it is working to create and manage an information system of supply-and-demand data.(Economist Intelligence Unit, Country Risk Service, April 2009 and April 2011; EIU Microscope Survey 2010 and 2011; personal interviews: June 2009, March 2010, June 2011; International Monetary Fund Article IV on Uruguay, January 2011; World Bank Doing Business 2011 Survey.)(Economist Intelligence Unit, Country Finance, July 2009 and 2010; Economist Intelligence Unit, Financial Services, November 2010; IMF, Working Paper 06/225, R. Blavy, “Assessing Banking Sector Soundness in a Long-Term Framework: The Case of Venezuela”, September 2006; personal interviews: June 2009; April 2010, July 2011.)(Government of Vietnam, 2007; National Assembly, 2010; Personal interviews, June 2011.)(2009 Microfinance Law; Personal interviews: June 2011; Al Amal website.)

(Microfinance Industry Report, 2010; Banking with the Poor Network, accessed June 2011; BAAC website; financial sector assessments) (Cooperative Societies Act; Financial Institutions Act; EIU Microscope Survey, July 2011)(Personal Interviews July 2011, Central Bank)(BoU Annual Report 2009/2010; BoU Financial Institutions Act, 2004; David Kalyango, “Uganda’s Experience with the Regulatory and Supervisory Framework for Microfinance Institutions,” BoU, 2005; International Conference on Microfinance Regulation, March 15-17, 2010; Uganda Ministry of Finance, Planning and Economic Development, “The Background to the Budget 2011/12 Fiscal year,” June 2011)(Sources: Central Bank of Uruguay website; Personal interviews, June 2011.) (Economist Intelligence Unit, Country Finance, July 2009 and July 2010; Economist Intelligence Unit, ViewsWire, June 2009; Economist Intelligence Unit, Country Risk, April 2011; Economist Intelligence Unit, Financial Services, November 2010; Personal interviews: June 2009, April 2010, July 2011; Microscope Survey, June 2011)(Personal interviews, June 2011; Nguyen and Vogel, 2011.)(2010 SFD Annual Report; Central Bank of Yemen, 2009 Microfinance Law and Yemen Deposit Corporation Insurance Law.)

(PWC web pages for Thailand, accessed June 2011; Deloitte (2008), IFRS and GAAP in Thailand; personal interviews: March 2010, June 2011; World Bank 2007)(Ministry of Finance; Deloitte IAS Plus; Microfin; Institute of Chartered Accountants of Trinidad; Personal Interviews: June-July 2011; Latin American Venture Capital Association Scorecard 2011)(Personal Interviews July 2011, Deloitte IAS Plus 2011, World Bank Doing Business 2011)(BoU Financial Institutions Act, 2004; BoU Micro Finance Deposit-Taking Institutions Act, 2003; BoU Financial Institutions Act, 2004; BoU Micro Finance Deposit-Taking Institutions Regulations, 2004; EIU Microscope Survey 2011; Microscope 2010; personal interviews: June-July 2011)(Economist Intelligence Unit, Country Commerce, April 2009 and April 2011; IAS PLUS/Deloitte; MIX Market; World Bank, Report on the Observance of Standards and Codes, January 2006.) (Deloitte/IAS PLUS; eStandards Forum; Economist Intelligence Unit, Country Finance, July 2010; FCCPA website; Inter-American Accounting Association (IAAA); personal interviews: June 2009, April 2010, July 2011.)(Deloitte/IAS Plus; Personal interviews, June 2011.)(Personal interviews: June 2011; MIX Market website; Central Bank of Yemen, Commercial Banks Law; Economist Intelligence Unit, Microscope Survey 2011.)(Asian Development Bank 2003; MIX Market; personal interviews: March 2010, June 2011; World Bank, Banking the Poor report 2009.)(EIU Survey Results 2011)(Personal Interviews July 2011, Central Bank, World Bank Doing Business 2011, Media Articles, Company Websites)(AMFIU Consumer Code of Practice for Microfinance Institutions in Uganda (CCP) brochure; AMFIU Member Directory 2009; BoU statement, “BoU Releases Framework for Financial Literacy, Financial Consumer Protection in Uganda,” April 2011; personal interview: July 2011; BoU website; Financial Institutions Act No. 2, 2004; Micro Finance Deposit-Taking Institutions Act No. 5, 2003; Microscope 2010)(Economist Intelligence Unit, Country Commerce, April 2009; EIU Microscope Survey 2010 and 2011; MIX Market; personal interviews: June 2009, March 2010, June 2011; Corporation Nacional Para el Desarrollo (government agency); Observatorio de Microfinanzas website)(Microscope Survey, June 2011; Personal interviews: July 2011.)(National Assembly, 2010; Personal interviews, June 2011; Economist Intelligence Unit, Microscope Survey 2011.)(Personal interviews: June 2011.)(Global Legal Group-CDR, 2011; personal interviews: June 2011)(Personal Interviews: June-July 2011; Ministry of Legal Affairs of Trinidad; Heritage Foundation Economic Freedom Index 2011)(Personal Interviews July 2011, Central Bank, World Bank Doing Business 2011, Media Articles, Company Websites)(AMFIU website; CGAP Financial Inclusion Regulation Center: Uganda; BoU statement, “BoU Releases Framework for Financial Literacy, Financial Consumer Protection in Uganda,” April 2011; BoU & GIZ, “Towards an Effective Framework for Financial Literacy and Financial Consumer Protection in Uganda, March 2011; interviews: June 2011)(Personal interviews: June 2011; World Bank Doing Business 2011 Survey. Uruguayan government website on Consumer Protection)(Personal interviews: July 2011; World Bank Doing Business 2011 Survey; Economist Intelligence Unit, Country Commerce, October 2010; Economist Intelligence Unit, Country Report, June 2011; Transparency International 2010 Corruption Index.)(Personal interviews, June 2011.)(Personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)(IFC Bulletin No 31 (2008); Microfinance Gateway; personal interviews: March 2010, June 2011; Banking with the Poor, 2010; World Bank, 2006; Bangkok Post, February 2010; World Bank, Doing Business 2011.)(EIU Microscope Survey, 2011; Personal Interviews: June-July 2011; World Bank Doing Business 2011)(Personal Interviews July 2011, Central Bank, World Bank Doing Business 2011, Media Articles, Company Websites)

Uganda currently scores 4 out of 6 in the World Bank Doing Business’ depth of credit information index. Only 1.1% of the population is covered by the credit bureau.(BoU Financial Institutions Regulations: Credit Reference Bureaus, 2005; Compuscan case study, 2011; personal interview: June 2011; World Bank Doing Business Credit Information Index 2011)(Microscope Survey, March-April 2010; personal interviews: June 2009, March 2010, June 2011; World Bank, Doing Business 2010 and 2011; CGAP/INCAE’s Portal de Microfinanzas)(Personal interviews: June 2009, April 2010, July 2011; World Bank, Doing Business 2011.)(World Bank Doing Business Credit Information Index; Government of Vietnam, 2010; Personal interviews, June 2011.)(World Bank Doing Business 2011; personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)

(BOT Payment Systems Roadmap 2010; BOT working paper, 2010; personal interview, June 2010; Bangkok Post, August 2010 and November 2010; Thai-Asean News Network, May 2011; Royal Decree, 2008) (Personal Interviews 2011; General Banking Law; Microscope Survey Results 2011)(Personal Interviews July 2011, Central Bank, Media Articles, Company Websites)(Bank of Uganda website, April 2010; EIU Microscope Survey 2011; Mobile Money Africa, “Mobile money: So far so good, but…” April 16, 2011; Mobile Money Africa, “MTN Mobile Money reaches $90m monthly in Uganda,” April 3, 2011; Mobile Money Africa, “MTN Uganda Partners With StarTimes TV For Convenient Payments,” July 12, 2011; IT news online, February 26th 2010; personal interviews, April 2010, June 2011; Pyramid Research website, June 2009.)(Microscope Survey, March-April 2010; MIX Market; personal interviews: March 2010, June 2011)(Personal interviews, July 2011.)(Duflos, 2011; Personal interviews, June 2011.)(2010 SFD Annual Report; personal interviews, June 2011.)

(EIU “Risk Briefing” analysis; media reports; personal interview, June 2011.)(IMV Article IV Review February 2011; Personal Interviews 2011; EIU Microscope Survey, July 2011)Turkey is a stable democracy with a mature banking sector that is Western-oriented. On the surface there are no political tensions that would adversely impact the development of microfinance. The main obstacle for development of Turkey’s microfinance sector is that there is limited political will to actively promote the development of non-bank microcredit institutions.(Personal Interviews July 2011, EIU Risk Wire, World Bank Doing Business 2011, Media Articles)(Personal interviews: July 2011)

Uruguay's institutions provide checks and balances to executive power, limiting radical changes in policy affecting business. Elections are free and fair, and apart from the period of military rule (1973-85), Uruguay has a good record of stable democracy. (Economist Intelligence Unit, Risk Briefing, April 2010 and 2011.)(Economist Intelligence Unit, Country Risk, May 2011; Economist Intelligence Unit, Country Finance, July 2010; Economist Intelligence Unit, Country Financial Services, November 2010) (Duflos 2011; Personal interviews, June 2011.)

At the time this report was being compiled (June-July 2011), the political and security situation in Yemen was alarmingly unstable. Violence and unrest has afflicted provinces across Yemen, and the central government has lost control over large swathes of the country. Many banks have closed their doors, and foreign diplomatic staff have pulled out the country. Inevitably, the microfinance sector has been disrupted, and a number of the MFI NGOs, especially those in Abyan, Aden, Taiz and Sanaa, may be particularly badly affected. The latest survey by the Microfinance Network shows that the operations of 88% of its members have been disrupted, with, among other things, credit officers in some areas severely restricted in their movements (and thus unable to collect repayments) and often struggling to locate their clients (some of whom have fled the worst-affected areas). In addition, 50% of MFIs have reported that communication between staff has also been hindered, and all have complained that thus far no external aid has been forthcoming. As a result, many MFIs have chosen to stop disbursing new loans for the time being, with Al Amal, for example, overseeing a reduction in its number of borrowers from 17,000 to 15,000. Meanwhile, the SFD headquarters is located close to where much of the worst of the fighting has been in the capital, Sanaa, and as such many of its staff have periodically been unable to work (and, even when the office has been open, repeated electricity outages have interrupted their work). Once the situation has calmed down, there will probably have to be a wholesale re-evaluation of the balance sheets of most of the country’s MFIs. (personal interviews, June 2011)(Personal interviews, June 2011.)

(Personal interviews: June 2011; Social Fund for Development; 2010 SFD Annual Report; Yemen Microfinance Network website; Economist Intelligence Unit Microscope Survey 2011.)(Personal interviews: June 2011; 2009 Microfinance Law; Microfinance Network website.)(CGAP diagnostic report 2005; personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)(2009 Microfinance Law; Personal interviews: June 2011; Al Amal website.)(2010 SFD Annual Report; Central Bank of Yemen, 2009 Microfinance Law and Yemen Deposit Corporation Insurance Law.)

(Personal interviews: June 2011; MIX Market website; Central Bank of Yemen, Commercial Banks Law; Economist Intelligence Unit, Microscope Survey 2011.)(Personal interviews: June 2011.)(Personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)(World Bank Doing Business 2011; personal interviews: June 2011; Economist Intelligence Unit, Microscope Survey 2011.)(2010 SFD Annual Report; personal interviews, June 2011.)

At the time this report was being compiled (June-July 2011), the political and security situation in Yemen was alarmingly unstable. Violence and unrest has afflicted provinces across Yemen, and the central government has lost control over large swathes of the country. Many banks have closed their doors, and foreign diplomatic staff have pulled out the country. Inevitably, the microfinance sector has been disrupted, and a number of the MFI NGOs, especially those in Abyan, Aden, Taiz and Sanaa, may be particularly badly affected. The latest survey by the Microfinance Network shows that the operations of 88% of its members have been disrupted, with, among other things, credit officers in some areas severely restricted in their movements (and thus unable to collect repayments) and often struggling to locate their clients (some of whom have fled the worst-affected areas). In addition, 50% of MFIs have reported that communication between staff has also been hindered, and all have complained that thus far no external aid has been forthcoming. As a result, many MFIs have chosen to stop disbursing new loans for the time being, with Al Amal, for example, overseeing a reduction in its number of borrowers from 17,000 to 15,000. Meanwhile, the SFD headquarters is located close to where much of the worst of the fighting has been in the capital, Sanaa, and as such many of its staff have periodically been unable to work (and, even when the office has been open, repeated electricity outages have interrupted their work). Once the situation has calmed down, there will probably have to be a wholesale re-evaluation of the balance sheets of most of the country’s MFIs. (personal interviews, June 2011)(Personal interviews, June 2011.)

(Personal interviews: June 2011; Social Fund for Development; 2010 SFD Annual Report; Yemen Microfinance Network website; Economist Intelligence Unit Microscope Survey 2011.)

(Personal interviews: June 2011; MIX Market website; Central Bank of Yemen, Commercial Banks Law; Economist Intelligence Unit, Microscope Survey 2011.)

At the time this report was being compiled (June-July 2011), the political and security situation in Yemen was alarmingly unstable. Violence and unrest has afflicted provinces across Yemen, and the central government has lost control over large swathes of the country. Many banks have closed their doors, and foreign diplomatic staff have pulled out the country. Inevitably, the microfinance sector has been disrupted, and a number of the MFI NGOs, especially those in Abyan, Aden, Taiz and Sanaa, may be particularly badly affected. The latest survey by the Microfinance Network shows that the operations of 88% of its members have been disrupted, with, among other things, credit officers in some areas severely restricted in their movements (and thus unable to collect repayments) and often struggling to locate their clients (some of whom have fled the worst-affected areas). In addition, 50% of MFIs have reported that communication between staff has also been hindered, and all have complained that thus far no external aid has been forthcoming. As a result, many MFIs have chosen to stop disbursing new loans for the time being, with Al Amal, for example, overseeing a reduction in its number of borrowers from 17,000 to 15,000. Meanwhile, the SFD headquarters is located close to where much of the worst of the fighting has been in the capital, Sanaa, and as such many of its staff have periodically been unable to work (and, even when the office has been open, repeated electricity outages have interrupted their work). Once the situation has calmed down, there will probably have to be a wholesale re-evaluation of the balance sheets of most of the country’s MFIs. (personal interviews, June 2011)









