The committee deserves all appreciation for the swift action and studied assessment of the sector. The quick report did bring back a bit of sanity to the sector, which has been battling all odds, including the media with many informed and uninformed comments. The Committee also deserves admiration for bringing the focus of microFinance back to its clients as also a grievance redressal and protection system, which was earlier, largely neglected with excessive focus on institutional sustainability. Having been associated with the sector and also being an ardent follower and independent enthusiast, I wish to place a few points for due consideration of RBI – some pertaining to the aspects already covered in the report and a few which could be suitably considered for inclusion by RBI. Further, it may also be added that some of the recommendations of the Committee do not seem to be in-sync with the microFinance sector and its accepted practices and a few recommendations could likely stifle fledgling microFinance institutions, making it near impossible to operate:
| No | Recommendation | MY Observations |
| 1 | A net worth requirement of Rs 15 Cr for mFIs | · The minimum Rs 2 cr networth requirements prescribed as of now needs to be restored orelse many of the start-ups NBFC-mFIs could be forced to close down. This recommendation would favour larger existing mFIs. Therefore, the recommendation of mF Task Force (1999) of Rs 2cr may be considered or restored. · Most of the equity funding that has been done under the NABARD’s mFDEF equity funding support / other equity providers covers many start up organizations with low equity base. · Further, the present RBI instructions stipulate a mere Rs 5 cr equity requirement for establishing LABs under the BR Act which also accesses public deposit(even though no new licenses are being issued at present). Thus mFI’s requirements stipulated by the Committee for non-deposit taking NBFC seem too indomitable |
| 2 | A limit on annual family income of Rs.50,000/- for clients to be serviced by mFIs | · While it would be desirable to bring greater focus at the poor clients being serviced, however, the practical selection process would be difficult not for mFIs, but also for the supervisor or regulator to cross check. · Therefore, it would be better for the mFI to clearly specify the basis or norms for client selection / identification viz; casphor housing index, landless people, not more 0.5 ac of un-irrigated land owners etc or the 9 risk parameters identified by clients in the UN project in kerala, as these are easily identifiable, verifiable and implementable. · If such easily identifiable risk parameters are chosen and declared by the mFI, this could also be effortlessly verified by any independent body or the regulator. |
| 3 | Individual ceiling on loans to a single borrower to be restricted to Rs.25,000/- | · The recommendation appears restrictive, especially when the existing definition allows loans upto Rs 50,000 to be classified as microCredit with a special clause for housing loans. Thus, reducing the limit by half after a span of 7-8 years after the present limit is fixed would be viewed restrictive and could limited debt / borrowing possibilities even from a client’s perspective. · A limit of Rs 25,000 would not enable a poor HH to buy a two milch animal unit, which is often considered as a minimum economic unit in the dairy sector. This limit would be very restraining to poor HH to pursue many such common livelihood supportive activities. · This, monetary restriction would also limit progressive financing of clients by mFIs who tend to accept or take higher loans after establishing a credit history. Thus, there is a need for enhance the limit to atleast to Rs 50,000 or restore the existing limits. |
| 4 | Not less than 75% of the loans given by the MFI should be for income-generating purposes | · This clause pertaining to 75 % of the loans being for IGA looks limiting, as in the start up financing by mFIs and initial stages there is every likelihood of institutions serving the consumption needs; which often is very predominant. · This approach could question the very basis of micro finance. The approach somehow also highlights the committees bias towards microCredit /credit (as the only / major financial service needed by client) and not micro Finance service to be provided by these institutions. |
| 5 | Margin cap of 10 % for mFIs with a loan outstanding of Rs 100 cr and 12 % for smaller mFIs & an individual loan cap of 24 % p.a. | · Large no. of factors influence interest pricing, however, the approach of margin cap is welcome instead of a interest cap. · However, the interest cap is to be pegged with a reference rate say viz; base rate or an average cost of funds of an mFI - as these vary substantially for small / fledgling organizations / start up and established mFIs. · Studies by experts on computing APR and EIR have clearly shown that the “Devil is in the dates”. ie; to say that by manipulating a few dates and collection systems, how the EIR and APR could be manipulated, while keeping the caps at 10 % or 12 % margin. |
| 6 | The NBFC-MFI will hold not less than 90% of its total assets (other than cash and bank balances and money market instruments) in the form of qualifying assets | · The 90 % qualifying asset requirement stipulated by the Committee seems rather high. Assessments have shown that even willing and well functioning mFIs normally have loan portfolios, which on itself forms around 65-75 % of the asset base only. · With high and quick turnover of funds in mFIs it could perforce hasten the processes of credit dispensation, which could result in inadequate client education and client supportive activities – especially in good functioning and client supportive mFIs. · Its desirable that the ceilings could be prescribed on investments retained (< 20 %) to total assets only instead of ceilings on qualifying asset – as these prescriptions are more intended for creditors of mFIs like banks for their mandated lending. |
| 7. | Restriction on Loan tenure and collection frequency being specified | · Often among poor clients there could be multiple loan requirements, which also include debts for very short periods like 15 days – 2 months. These requirements enable poor HH to set up small trading stalls during exhibitions and local hatts for very short durations, or meet school fees of children or small medical requirements, which are very shorter term, finance requirements. Restricting lending operations to minimum 12-18 months etc may not reflect the actual requirements of poor HH. Absence of these accommodation could revert poor HH to get back to informal sector · Studies on cash flow gaps / funding requirements done on poor HH using financial dairy techniques, suggest need for very short-term requirements. (Eg ref:. The Deluge of Debt: Under-standing the Financial Needs of Poor Households by B.S Suran and D.Narayana, Centre for Development Studies: July 2009: Working paper 412- : www.cds.edu ) |
| | Issues not mentioned in the report, but, could be considered by RBI | |
| 8 | MFIS not allowed to mobilize savings / No space for thrift? | · The studies by different agencies have clearly brought out the fact that in the hierarchy of financial services needs of the poor HH, the position of thrift precedes credit or other financial services. For poor taking care of the money, when they spend less than what they earn is critical. Therefore, appreciating the criticality of this service, thrift atleast among enrolled members in a regulated NBFC, needs to be clearly considered. This suggestion is being made for non-SHG clients / individuals and are also important clients of mFIs. · Perhaps the condition of institutional rating of the mFI and ceiling on thrift mobilized viz; as multiples of networth of the mFI could be considered. This is being suggested more as a need for fulfilling an important client need as also the national agenda of financial inclusion. · Another aspect why this is worthy of due consideration is because, poor often view small thrifts / savings set aside as an important substitute for insurance. |
| 9 | Restriction on CEO and top executive remuneration | · Executive pay is often as a mixture of salary, bonuses, shares, call options on the company stock, etc. Executive pay of some of the larger mFIs operating in the country has risen dramatically and often exceeds the largest of banking companies in the world. While this is an important aspect of the corporate governance, however, the BOD approves it. What is critical is not the pay per se, but how it upwardly influences the transaction cost of the financial service being provided by the mFIs. · As a guideline it would be desirable to prescribe benchmarks for the same. Studies in USA after the introduction of Troubled Asset Relief Programme and executive programme have not exhibited any negative influence on performance / output. |
| 10 | Need an Institutional assessment format (Indian) which reflects the clear picture of the interest cost and non-interest levies on client | · The present practice is to use formats of CGAP or others with variations and to report FSS, OSS or other ratios at based on the decision of the mFI or its management. · There is a need for introducing a simple uniform institutional assessment framework for reporting and assessing mFIs in our country. These could be comparable with LABs or even RRBs . As it would provide a comparative assessment of the success of these institutions in terms of outreach, cost and delivery of services and also its sustainability. |
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