Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy Symbols Introduction Definition Example Remember Further Reading Video Lecture 6. edition 9/2016 © 2016 Frankfurt School of Finance & Management, Sonnemannstr. 9 – 11, 60314 Frankfurt am Main, Germany All rights reserved. The user acknowledges that the copyright and all other intellectual property rights in the material contained in this publication belong to Frankfurt School of Finance & Management gGmbH. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without the prior written permission of the publisher. Violations can lead to civil and criminal prosecution. Printed in Germany Content 1 High-Level Risk Identification .................................................... 5 2 High-Level Risk Dimensions - Initial Definitions ..................... 9 3 Reputation Risk ......................................................................... 13 4 Strategy Risk ............................................................................. 19 5 Exercises.................................................................................... 25 © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 1 Abbreviations ABC Activity Based Costing ALCO Asset and Liability Management Committee ALM Asset-Liability Management ATM Automated Teller Machine ATTF Agence de Transfer de Technologie Financière BCBS Basel Committee on Banking Supervision BSC Balanced Scorecard CAR Capital Adequacy Ratio CGAP Microfinance Secretariat at the World Bank COSO Committee of Sponsoring Organizations of the Treadway Commission EAD Exposure at Default EL Expected Loss ERM Enterprise Risk Management EUR Euro currency FRM Financial Risk Manager - professional designation HR Human Resources ISO International Standards Organization KPI Key Performance Indicator KRI Key Risk Indicator LGD Loss given Default MFI Microfinance Institution MIS Management Information System MIV Microfinance Investment Vehicle MSME Micro-, Small and Medium Enterprise NBFI Non-Bank Financial Institution NGO Non-Governmental Organization NPL Non-Performing Loan OHSAS Occupational Health & Safety Advisory Services PAR Portfolio-at-risk PD Probability of Default PMI Project Management Institute PMI-RMP PMI Risk Management Professional designation PRM Professional Risk Manager professional designation ROA Return On Assets ROE Return On Equity SME Small and Medium Enterprise TA Technical Assistance USD US Dollar © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 2 Learning Outcomes This Unit establishes a macro risk map for microfinance and small business banking. It provides a reference framework for high-level risk identification and develops initial definitions for all principal sources of risk in traditional banking book operations. The learning outcomes of this Unit are: being able to establish a macro risk map and an initial high-level severity/probability risk profile of your financial institution. understanding the conventional definitions of all principal risk dimensions in banking book-only financial services. describing the transmission function of reputational and behavioral factors between core risk sources and downstream liquidity and capital adequacy exposures. the high cost of microcredit being a key reputational vulnerability in microfinance, one should be able to correctly calculate annual effective interest rates on various types of loan products. designing an inclusive strategic planning process that identifies suitable strategic initiatives and gives due consideration to the downside risks of associated adverse scenarios. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 3 © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 4 1 High-Level Risk Identification Sorry, but we decided to make you work through one more rather generic introductory Unit. We understand that everyone is eager to finally run some numbers and do a foreign exchange rate stress test, for example. We promise to keep this short. Yet, a bit more high-level risk discussion now will help us maintain a holistic perspective on the risk profile of our organization, while we are digging deep into the details on a particular type of exposure. Just a few more definitions and introductions This Unit is about establishing a high-level, "macro" risk map for SME banking and microfinance. The objective is to bring some conceptual order to the many different dimensions of risk that we hear about in connection with banking and microfinance. The worst is to be blindsided by unknown unknowns, i.e. by potential losses arising from categories of uncertain events that we do not even have on our radar. This would mean that we also do not have processes and tools in place to measure and mitigate these exposures. Therefore, it is critical to set up a macro risk map that is as broad and allinclusive as possible and provides a terminological anchor for any and all possible risk dimensions and events. For example, the new board member might ask the Risk Manager: "Have you thought about the risk of loan officers using physical intimidation to collect from micro-borrowers and a journalist picking up on this and turning it into a national news story on the abuses of microfinance? And then many more clients would be refusing to pay these 'microcredit bandits' as a consequence". The Risk Manager throws up the Macro Risk Map on the projector and responds: "Yes, that's covered. It is called the reputational dimension of operational risk and it relates to the adherence of staff to documented policies and procedures. Any abuse should be picked up during internal control site inspections or through the client complaint hotline." Again, at this high-level, the macro risk map is about broad coverage of the risk universe. Any conceivable risk that an institution may face must be subsumed under one of the top-level risk dimensions that we have identified. That way, we have some reasonable assurance that the identification and measurement processes that we put in place will pick up any actual exposures and give us a chance to manage them, before they can bring down the house. And since the activities of large-scale commercial deposittaking microfinance are fundamentally similar to those of conventional retail and SME banks, the macro risk map for microfinance is essentially identical to a retail banking risk map. Macro map must cover entire risk spectrum The principal difference vis-à-vis the risk landscape of a large full-service bank is that our MSME banking risk map relates to banking-book activities only. There is no proprietary trading for short-term gain in marketable financial instruments (stocks, bonds, commodities, derivatives, etc.) and there will not be any complex structured credit products, no syndicated lending, no project finance, no investment banking or securities underwriting. Off-balance sheet contingent rights and obligations will be minimal. They might arise only from occasional guarantees received or granted or from some banking-book related forward and swap transactions, e.g. in order to hedge some interest rate or foreign exchange rate exposures. MSME Finance is banking book only business © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 5 Under BCBS rules on capital adequacy, banks divide their activities into two main categories, i.e. traditional banking versus trading, whereby banks' assets and liabilities either belong to the banking book or to the trading book. Banking book vs. trading book The banking book is defined by its relationship to traditional client transactions and instruments such as loans, deposits, guarantees, international trade finance and payments etc. The banking book also includes the funding transactions, liquid asset holdings and hedging instruments that support the client-related business. In contrast, the trading book contains assets and liabilities that are created or held for short-term (proprietary) trading including the liabilities that fund these activities as well as hedging instruments associated with trading book items. We should note that the same type of instrument, say a forward transaction in currencies, can be found in the trading book or in the banking book. It is the functional purpose of the transaction that determines the classification, not whether by its nature the instrument has more of a trading room flair or is a traditional client contract. So, suppose a MFI invests its liquid asset reserve in government bonds and occasionally buys and sells bond holdings to accommodate funding requirements from microcredit and deposit operations. Are these bond holdings in the trading book or in the banking book? In the banking book, of course. The bonds support the core retail banking activities as a cash buffer that meets regulatory liquidity requirements. The MFI is not a market maker in government bonds and the motive for holding bonds is not to trade them on an intraday basis for shortterm profit. IAS 39 / IFRS 9 classification While we are on the subject of banking book versus trading book we should mention that there is a similar overlapping classification system of assets and liabilities that comes out of IAS 39, which is also being carried forward into the new IFRS 9. Under IAS 39 / IFRS 9, assets are classified into three categories: (1) Held for Trading, (2) Available for Sale and (3) Held to Maturity or Loans & Receivables. Without going into the finer details at this point, one can roughly equate Held for Trading assets and liabilities to the Trading Book and everything else to the Banking Book. Coming back to the banking-book-only risk landscape in micro and SME banking: If we go with this simplified version of the risk universe, it must be clear that whatever is not on the macro risk map must indeed be forbidden territory. Otherwise, we could imagine a treasurer drifting off into day-trading in speculative penny stocks as a way to "optimize" the yield on the MFI's liquid asset reserve. Permitted and prohibited activities & products The particular problem of risky treasury investments can be avoided by clearly defining eligible investment instruments and counterparties for treasury transactions in the liquidity management policy. But more importantly still, the board should remind management first off that everything the institution does, buys, sells, or invests in must clearly support the stated mission and mandate. If one cannot explain how short-selling penny stocks is related to the inclusive low-income financial services mission of the institution, then it is simply not allowed, end of discussion. Compare section "2 Business Model and Risk Tolerance" in the model ALM framework policy provided at the end of Unit 2. This gives an example of how one can © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 6 directly link the mission of the institution to permitted and prohibited activities and products. Let's look at our attempt to draw up such a macro risk map for micro- and SME finance in Figure 1. Strategy & Business Risk Liquidity Risk Credit & Counterparty Risk Operational Risk & AML / CFT Interest Rate Risk Foreign Exchange Rate Risk Strategy & Business Risk Strategy & Business Risk Reputation & Behavioral Risks Reputation & Behavioral Risks Strategy & Business Risk Figure 1: Macro Risk Map for Microfinance and SME Banking Figure 1 structures the MSME risk universe into four interdependent risk layers: 1) 2) 3) 4) the core sources of risk in the grey boxes in the middle, a transmission layer of reputation and behavioral risks that radiate out into ... the downstream dimensions of liquidity, covenant and capital adequacy risk, and finally ... a strategy & business risk layer that interacts with all other risk dimensions. Four interdependent risk layers We find this layering approach quite helpful in thinking about the practical interdependencies between the conventional risk dimensions encountered in microfinance. The boxes at the core are the original sources of risk. This is where generally the trouble starts: If a MFI goes down in flames, it is almost always due to a high level of loan losses (credit risk) in combination with fraud and negligence in following policies and procedures (operational risk). Interest rate risk and foreign exchange rate risk can also cause major losses for MFIs, when poor risk management meets bad luck. But we have trouble © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 7 Credit + operational risk is the killer in microfinance naming an institution that failed strictly because of interest rate or forex risk, while we could fill books with cases of the deadly credit risk / operational risk combination. Transmission function of reputational risk We placed reputation and behavioral risks in a "transmission layer". This requires some further explanation: A good reputation for solid finances and honest, socially responsible client service is never lost out of the blue by an act of God. The financial reputation suffers, when actual losses incurred by the institution in the core risk dimensions become public knowledge. In the same vein, changes in client behavior may be triggered by reputational damage or by financial losses that emanate from the core risk dimensions. Now that your MFI is in the news as having financial difficulty, it is not surprising that depositors might change their prolongation behavior or that the willingness of borrowers to repay their loans may have suffered. The loss of reputation and the behavioral changes (lower deposits & lower loan collections) work like an accelerator for the transmission of losses in the core dimensions to the downstream risks in the third blue layer. As the institution is losing client goodwill, is bleeding cash and booking losses, it becomes increasingly difficult to remain in compliance with liquidity norms, borrowing covenants and capital adequacy rules. Strategy is the wraparound risk layer And finally, strategy interacts naturally with every other risk dimension: Initiatives like pushing into agri-lending, moving up-market into SME finance, increasing outreach to poor households in remote areas, rolling out a new technology platform etc. all have risk/reward profiles that need to be carefully examined in each of the risk dimensions on the macro map. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 8 2 High-Level Risk Dimensions Initial Definitions Before we unpack each of the key risks in great detail in the following Units, it will be useful to round out our overview of the risk dimensions on the macro map with some short initial definitions. For strategy and reputation risk, this initial review will be a little bit more involved, because we will not come back to these two more elusive, less quantitative risk dimensions later within a dedicated Unit. Credit risk is defined as the possibility that a borrower or other contractual counterparty might default, i.e. might fail to honor their contractual obligations. Counterparty credit risk in microfinance would relate to investments with other financial institutions or to the settlement obligation of a bank towards the MFI resulting from a currency forward transaction, for example. But for the largest part, naturally, credit risk is related to small businesses and individual borrowers failing to meet their payment obligations under their loan agreements with the MFI. Credit Risk is commonly subdivided into a transaction risk and a portfolio credit risk component. Transaction risk refers to individual loans and essentially measures (1) the standalone probability that the borrower will be able to repay as well as (2) the ultimate loss in the case of a borrower default after use of collateral and other mitigating factors. Portfolio credit risk is concerned with measuring correlations between individual borrower defaults, the effects of diversification, the cyclicality of collateral values and the implications of reputation and contagion effects in micro- and consumer credit. For operational risk we will use the widely accepted BCBS definition as per Basel II June 2006, no. 644 and the 2011 Sound Principles: The BCBS defines operational risk as the possibility of “losses resulting from inadequate or failed internal processes, people and systems or from external events. This definition includes legal risk, but excludes strategic and reputational risk. Legal risk includes, but is not limited to, exposure to fines, penalties, or punitive damages resulting from supervisory actions, as well as private settlements.” Operational risk in a way is the residual catch-all category of risk. It is as diverse as the things that can go wrong with people, processes and systems. It includes fraud by staff, ordinary burglaries, loans not processed and revenue lost due to a network outage, as well as mundane issues such as staff leaving the air-conditioning on over the weekend and running up the electricity bill. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 9 Always examine operational risk events in terms of reputational impact We should point out that in microfinance much of the reputational damage that can be imagined comes from operational risk events. Think of major fraud, abusive sales practices and service disruptions. Although reputational risk is broader than just the consequences from operational events, we will always examine every operational risk exposure and every materialized loss very thoroughly in terms of its reputational impact. Let's turn to the market risks in MSME finance. Market risk is the potential of losses to income or the value of assets, liabilities and equity arising from changes in market prices. Such market prices may include reference interest rates, foreign exchange rates, traded prices of equity shares, prices of precious metals and other commodities etc. The relevant market risks in MSME finance are interest rate risk in the banking book and foreign exchange rate risk. Interest rate risk is a bit of an abstract risk dimension that is often not well understood by microfinance practitioners. It also has an aura of highpowered financial math about it. This actually creates another risk in itself, namely that we end up with a nice black box with differential equations inside, where nobody knows what this thing is even measuring. On the other hand, one can argue that the market rate component of the microcredit rate charged to clients is small relative to the required operating cost margins. So, why worry about market interest rates going up or down by just one or two percent per annum? In our Unit on interest rate risk, we will try to find a reasonable middle ground between Nobel-prize winning formulas and just bypassing the whole interest rate risk complexity. Here now, is our definition of interest rate risk: Interest rate risk is the danger of an adverse impact on net income and on the value of assets and liabilities in response to changes in the prevailing interest rate levels in the market. Its most important drivers of loss are (1) repricing risk which occurs via timing differences in the maturity of fixed-rate assets and liabilities and the repricing dates of floating-rate items and (2) basis risk which stems from the imperfect correlation in the adjustment of the rates earned and paid on different instruments with otherwise similar repricing characteristics. Yes, exactly, it's a little abstract. But don't worry, we will take interest rate risk apart step by step with lots of hands-on calculation models. Look forward to Unit 4.3 on interest rate risk. There is more to currency risk than just exchange rate movements When we speak about foreign currency risk, most people immediately think of the narrow concept of foreign exchange rate risk. That is guys in sharp suits in front of a wall of flat-screens playing the EUR/USD exchange rate with million dollar bets. But there are a number of other elements in the currency risk picture that should not be forgotten. These other currency risk dimensions are particularly relevant for emerging markets and developing countries where microfinance institutions operate. Often, the national currency is structurally weak and prone to inflation and there is heavy reliance on a parallel foreign currency in everyday transactions among © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 10 residents (dollarization). Many developing and emerging countries also still have currency regulation in force or could easily re-introduce such regulation that limits access to foreign currency and its transfer in and out of the country. So, here are the definitions for the full spectrum of currency risks that MFIs and SME banks might face: Convertibility risk is the possibility that the government or the central bank restrict access by domestic payers with obligations in hard currency to the foreign exchange markets thus making it impossible to buy the required currency, even if the counter-value in local currency was available. Transfer risk refers to the possibility that the local authorities will not allow foreign currency to leave the country regardless of its source. This could mean, for example, that a resident entity might have a USD balance in a bank account with a local bank, but that it would be forbidden from transferring these funds to a foreign recipient in order to pay an installment on a foreign borrowing. Currency Induced Credit Risk (CICR) arises when residents take on unhedged borrowings in foreign currency: Austrians taking out Swiss Franc mortgages, Turkish borrowers taking USD car loans, Kenyans borrowing USD for home improvements etc. The risk consists of a devaluation of the local currency, which will make debt service on the foreign currency borrowing more expensive in local currency and ultimately may lead to default of the borrower. Foreign exchange rate risk (forex risk) in a narrow sense arises from unexpected movements in the level of exchange rates that may lead to losses in the home or reporting currency of the entity concerned. More specifically, forex risk results from a mismatch between assets and liabilities in a particular currency and their associated cash flows in respect of size and maturity. We now move on to the definitions of the downstream secondary risks in the third blue layer in Figure 1. The transmission layer of reputation and behavioral risks will be discussed in a separate Chapter 3 immediately following. Liquidity is defined as the ability to honor all cash payment commitments as they fall due. Meeting all payment obligations involves the use of current cash inflows, the stock of cash holdings, borrowing cash and converting liquid assets into cash. Liquidity risk is shown as a downstream transversal risk dimension in Figure 1 as a way to emphasize its cross-sectional nature that interacts with all other risk categories. Similarly, covenant risk and capital adequacy risk can be seen as crosscutting operating constraints that are not a primary source of risk in themselves. Instead, they represent a compliance risk that is driven by the institution’s positioning and loss experience in the core risk areas shown at the center of Figure 1. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 11 Covenant Risk is the possibility of breaching a financial limit or constraint imposed on the entity by creditors in a loan agreement or similar contract. As a consequence of a covenant breach, creditors may cancel a loan agreement and demand immediate repayment of the entire balance outstanding, which might further aggravate the financial situation of the borrower. Capital Adequacy Risk is the threat of non-compliance with regulatory capital requirements, which could entail regulatory consequences ranging from fines to restrictions on activities up to placement under administration and forced liquidation of the entity. Before we move on to a more detailed look at the reputation / behavioral and strategy risk layers, let us try to position all of the risk dimensions in the macro map defined this far within a risk severity / risk probability taxonomy. This would be similar to the quadrant chart introduced in Unit 1, Figure 1. The idea is to classify the risk dimensions into the severity / probability matrix in their raw form as encountered by a particular MSME finance institution within its operating environment, before the effect of specific mitigation measures. Operational Risk Forex Risk Interest Rate Risk Credit Risk Covenant CounterRisk party Risk Low PROBABILITY High Transpose macro map to severity / probability matrix Low Liquidity Risk Capital Adequacy High Figure 2: MSME Finance Risks in a Severity / Probability Matrix Use matrix for board level discussions on risk profile We should emphasize that the result of the classification into the severity/probability matrix above will not be universal for every MFI in every operating context. Figure 2 just gives one plausible result for a "typical" deposit-taking large-scale microfinance institution. Filling out such a matrix for your institution might be an excellent exercise in a workshop to get the board and senior management thinking systematically about the risk profile of your organization. Of course, one would not stop there. The next step is to develop specific metrics for each dimension that help quantify exposures and monitor materialized losses. That is what the following Units 4.1 - 4.5 will be all about. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 12 3 Reputation Risk We now turn to the transmission layer in Figure 1, the area of reputation and behavioral risks. Just like reputation risk, behavioral risk really is not a free-standing original source of risk but a latent type of exposure that is activated by significant losses in other core risk dimensions. This can happen directly, or indirectly with a detour via reputation risk. A direct activation could occur via falling market interest rates and an emerging real estate price bubble. If retail savers are scrambling to join the real estate party and buy a piece of land or small apartment in order to not miss the boat, it becomes harder and harder to retain savings deposits even in a lowincome focused MFI. This is an example of interest rate risk directly activating a behavioral change in depositors. The indirect transmission via a reputation effect would, for example, first see losses occurring from a large un-hedged foreign currency borrowing, which are becoming public knowledge. Savers then begin to worry whether their deposits will be safe at the MFI and will prefer to not roll-over their time-deposits and even begin to close-out their passbook accounts. This could lead to a classic chain reaction as follows: core risk loss -> reputation impact -> change in depositor behavior -> liquidity crisis -> bankruptcy and liquidation. For practical purposes, we will generally lump together the reputation and behavioral stages in this transmission chain. They will almost always occur together and in various combinations of direct, indirect and second-round effects. Therefore, we don't want to begin splitting hairs over what came first, the behavioral change or the reputation impact. Let's just use it as one word from now and simply say "reputation-and-behavioral risk" or "reputation risk" for short. Reputation (and behavioral) Risk is the potential that an organization may not attain its objectives due to unfavorable perceptions of its activities, motives and representatives that may arise among various stakeholders and the general public. Stakeholders may include clients, members, shareholders, creditors, staff, suppliers, competitors, regulators, political opinion leaders etc. Reputation risk is closely linked with another key term in development finance, i.e. social performance management. The Social Performance Management Network (spmnetwork.net) defines Social Performance as the effective translation of an institution’s mission into practice. Social Performance Management consists of the processes an institution uses to translate its mission into practice. These include: (1) setting social targets, (2) measuring the progress toward these targets and (3) using the results for strategic decision-making - namely in order to improve products, services, and delivery channels. Social performance management is essentially about managing reputation risk. If you make an honest effort at mitigating reputation risk at its source, i.e. by eliminating bad corporate behavior and excessive profit maximization, then you are doing proper social performance management. So, it's about © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 13 Interactions between reputation and behavioral risks serious reputation management, by way of actually earning a good reputation rather than by means of superficial window dressing. If we share this understanding of the sources of reputation risk, it is clear that reputation is: No reputation windowdressing, please a long term issue, an emotional association of the stakeholders to the institution, about living and implementing the institution’s adopted values, and putting in place best practices: governance, policies, code of ethics, health & safety, redress for grievances … Because reputation risk management is such a long-term sustained investment in good practices, the temptation is large to resort to quick fixes. Such fixes would try to shape the reputational perception rather than cultivate stakeholder affinity by consistently doing the right thing and living up to the dual commercial and social missions of the institution. Unfortunately, in microfinance, there is a lot of half-hearted, superficial reputation management out there: Need to quantify social impact of microfinance funders who are afraid to ask the tough questions about actual social impact, because they may not like the answers and MFIs who just want to do a few easy adjustments and otherwise change nothing. Hanging up a few complaint boxes just does not cut it anymore. Since the global financial crisis and the microfinance excesses in India (see box below), the love affair between development aid and microfinance has cooled off. Sponsors of microfinance now want to see a social mission put into daily practice and hard evidence of development impact: Can you quantify the social & development return on microfinance investment? Without solid evidence of how microfinance services are actually helping clients improve their livelihoods sustainably, the grants, technical assistance and subsidized funding just won’t be coming like they used to. In fact, social and financial performance in microfinance must not be at odds with each other. Social performance can also be good business: adding value to low-income clients’ lives through quality services at advantageous terms delivered by a well-respected organization with impeccable ethics … how else are you going to cultivate client loyalty? © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 14 A study by Incofin Investment Management (www.incofin.com) on a portfolio of over 70 microfinance investments points to a positive correlation between financial and social performance scores: Figure 3: Financial vs. Social Performance Scores. Scatter diagram and regression line. Source: Incofin Investment Management. Reputation Risk Disasters in Microfinance: SKS implicated in borrower suicides in Andhra Pradesh, India Microfinance "Hundreds of Suicides in India Linked to Microfinance Organizations", Feb 2012 24 MUMBAI, India (AP) — First they were stripped of their utensils, furniture, mobile phones, televisions, ration cards and heirloom gold jewelry. Then, some of them drank pesticide. One woman threw herself in a pond. Another jumped into a well with her children. Sometimes, the debt collectors watched nearby. More than 200 poor, debt-ridden residents of Andhra Pradesh killed themselves in late 2010, according to media reports compiled by the government of the south Indian state. The state blamed microfinance companies - which give small loans intended to lift up the very poor - for fueling a frenzy of over-indebtedness and then pressuring borrowers so relentlessly that some took their own lives. (…) Both reports said SKS employees had verbally harassed over-indebted borrowers, forced them to pawn valuable items, incited other borrowers to humiliate them and orchestrated sit-ins outside their homes to publicly shame them. In some cases, the SKS staff physically harassed defaulters, according to the report commissioned by the company. Only in death would the debts be forgiven. One woman drank pesticide and died a day after an SKS loan agent told her to prostitute her daughters to pay off her debt. She had been given 150,000 rupees ($3,000) in loans but only made 600 rupees ($12) a week. Another SKS debt collector told a delinquent borrower to drown herself in a pond if she wanted her loan waived. The next day, she did. She left behind four children. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 15 One agent blocked a woman from bringing her young son, weak with diarrhea, to the hospital, demanding payment first. Other borrowers, who could not get any new loans until she paid, told her that if she wanted to die, they would bring her pesticide. An SKS staff member was there when she drank the poison. She survived. (…) The deaths came after a period of hyper-growth leading up to the company's hugely successful August 2010 initial public offering. Originally developed as a non-profit effort to lift society's most downtrodden, microfinance has increasingly become a for-profit enterprise. As India's market leader, SKS has pioneered a business model that many others hoped to emulate. But the story of what went wrong at SKS has led current and former employees and even some major shareholders to question that strategy and raises fundamental questions for the multibillion-dollar global microfinance industry. (…) Social performance is both opportunity and vulnerability in microfinance Although social performance and reputation risk should be a concern in any business which relies on the goodwill of a broad-based clientele, MSME finance is special in this respect. This is because expectations have been raised about the power of MSME finance in uplifting millions of poor in developing countries. MFIs absorb massive subsidized funding, grant capital and "free" technical assistance. Most MFIs have social objectives enshrined in their corporate mission and vision statements. Nothing is more disappointing and disastrous for the reputation of a MFI than to be found out as a dressed-up loan sharking operation with Muhammad Yunus posters on the wall. 1 The single biggest reputation risk factor in microfinance is the high cost of microcredit. All it takes is that the media run a story about your institution and the exorbitant interest rates that are being charged to poor people and you can have a reputation firestorm on your hands. The problem with this particular reputational vulnerability is that all too often, it is true. The effective cost of microcredit really is scandalously high. For years, microfinance practitioners have been singing themselves to sleep on this issue with the usual arguments: The cost of outreach is so high, so we must charge high rates to recover costs. If we don't recover the cost, then microfinance is not sustainable. And somehow that is a problem not just for us who work in microfinance, but also for the poor clients. Rates don't really matter because the loan amounts are so small. Annual effective rates are not realistic, because loans are generally for shorter periods than one year. Clients don't care about the high rates, because it is about convenience and access. Microcredit rates do matter, of course Really? We are not convinced and firmly believe that the price of microfinancial services does matter. If lending $200 to a poor family is supposed 1 South African microlender Blue Financial Services (www.blue.co.za) would be my best example of a cynical loan sharking business that was able to tap into development finance funding just by talking a bit of microfinance jargon and putting photos of women with fruit stands in their annual report. Blue also has operations in Ghana, Uganda, Zambia, Botswana and other African markets. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 16 to be a life changing development intervention, how can paying $250 a year interest for using the $200 working capital be irrelevant? How can cost not be the single most important index of quality in a dematerialized financial service? Ok, but which reputable microfinance institution would charge more than 100% per annum interest? A great many of them, actually. Consider the following real example from a community-based savings and loan company in Ghana : GHS 1,000 microloan for 9 fixed monthly installments at 3% per month "flat", 15 GHS upfront charge, 5 GHS monthly membership. What is the effective annual rate? The shocking result is 105.55% effective per annum, fully compounding as per EU consumer credit directive. In the exercises section at the end of this Unit we will give detailed instructions and plenty of additional examples of how to calculate US-style Annual Percentage Rates (APR) and correct EU-style effective rates. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 17 © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 18 4 Strategy Risk Finally let's discuss strategy risk (or strategic risk) in more detail, because we will not come back to strategy in a separate Unit. In Figure 1 we depicted strategy and business risk as the grey all-enveloping risk layer: Strategic decisions may have an impact on exposures in every known dimension and may even activate new, hitherto unknown types of risk. There is also a direct feedback from risk to strategy, because strategies largely succeed or fail because of the risks that they entail and that may materialize at the most inopportune moment. As the corporate practice of risk management evolves, directors and members of supervisory boards have become increasingly aware of their fiduciary obligation to manage risks that could prevent the organization from achieving its strategic objectives. This fiduciary wake-up call manifests itself in two ways: 1) It is becoming increasingly common that directors in MSME finance institutions request Directors & Officers insurance coverage paid by the institution, which would protect them from stakeholders who might seek redress for dereliction of fiduciary duty as a board member. 2) More productively maybe, board members and international investors in microfinance are pushing for more formalized approaches to risk management and a better alignment between strategy and risk. This push for better governance of risk means in effect that the consideration of risk must be woven directly into strategy setting. How else can a board properly determine strategy, other than by considering the risk dimension alongside every strategic option? Again, it is about the conscious simultaneous deliberation of strategy and risk, not about minimizing risk at all cost. We must keep in mind that what in retrospect are the biggest strategic successes in microfinance, were at decision-time often also the riskiest gambles. Beasley & Frigo point out that successful deployments of ERM in strategic planning seek to maximize value when setting strategic goals by finding an optimal balance between performance objectives and related risks. 2 As management assesses various strategic alternatives designed to reach performance goals, it evaluates related risks across each alternative to determine whether the potential returns are commensurate with the risks that each alternative brings with it. It also considers how one strategic initiative might introduce risks that are counterproductive to goals associated with another strategy. With this information, management is in a better position to study the resulting enterprise-wide risk profile and ensure that it remains in line with the risk appetite and supports the overall desired strategic direction. 2 Mark Beasley & Mark Frigo "ERM and its Role in Strategic Planning and Strategy Execution", p.34. In Fraser & Simkins eds., Enterprise Risk Management. 2010. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 19 Strategy risk management a fiduciary duty Deliberation of risk must be woven into every strategic decision Now consider an example of a strategic decision in microfinance. A leading MFI in Cambodia is entertaining an offer from a bank in Singapore to become their low-income banking front end in the Cambodian market. The bank would provide "unlimited" senior debt funding for MSME portfolio expansion and support joint marketing of trade finance services to small Cambodian businesses that are importing consumer goods from China, for example. The CEO and the Credit Manager see the proposal like a strategic partnership made in heaven: unlimited long-term funding at attractive rates, less relationship management effort with various microfinance investment vehicles just to pick up small lots of senior debt, no real competitive threat from the partner in Singapore, because they do not have an operating subsidiary in Cambodia. At the next Board meeting, however, the CFO and the Risk Manager raise the following issues: The CFO is concerned that the MFI might neglect the relationships with international development finance institutions and have reduced visibility within global microfinance networks. This could cut the institution off from grants and technical assistance that would have helped them keep abreast of international best practices. The Risk Manager raises the scenario that through no particular fault of the Cambodian MFI, the bank in Singapore could lose interest in the Cambodian market and abandon the partnership. After all, Cambodia is but one of many small emerging markets in the region and this partnership is a big deal to the MFI, but really just a small experiment to the partner bank. Essentially, the partnership could create an unfavorable strategic dependency. If the bank abandons the arrangement, the MFI would be hard pressed to quickly replace the funding, particularly if other sources of long-term borrowing have been neglected. There is also no guarantee that the bank may not price the funding less favorably in the future, as a way to extract higher returns, once the local partner is locked into the partnership. The Risk Manager is also concerned that the senior managers at the foreign bank partner really do not understand microfinance and may have little respect for the social double-bottom line mission of the MFI. Therefore, they may later pressure the MFI to move away from the low-income rural markets and push into consumer lending to more affluent urban populations. There is also a risk that even though the bank is not present with an operating unit in Cambodia, some of the MFI's deposit base may be lost to off-shore accounts in Singapore. This could be the case for the MFI's best clients whose businesses have grown into regular SMEs with regular import-export business. If the MFI loses the lowcost deposit float from these businesses, is the overall cost of funding under the partnership agreement still as attractive as was first believed? The Board decides to move ahead with the partnership nonetheless, but © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 20 asks the CEO to negotiate a special client protection clause into the partnership agreement that includes a revenue sharing on any off-shore deposits generated from the MFI client base. Separately, the CFO is instructed to maintain active borrowing relationships with at least three major international microfinance investors as a way to diversify the funding base, even though the MFI does not need the incremental liabilities at this time. Beasley & Frigo (p. 36f) recommend scenario analysis as the most suitable approach to assessing strategic business risk. We agree, because a probabilistic approach to strategic risk management appears rather pointless. Strategic decisions are singular, time limited events. These situations are very different from stochastic experiments, where we get to play a game many times, until we can detect a probability distribution of the outcomes. Market risk would indeed be more like a stochastic process, but not strategy risk. In exchange rate and interest rate risk, for example, we can look at every business day as a new game of chance where rates might move up, down or sideways. Evaluating strategic risks through scenario analysis The famous Harvard professor Michael Porter in his book "Competitive Advantage" (1985) defines risk as a function of how poorly a strategy will perform if the 'wrong' scenario occurs. This perspective on strategic business risk is very similar to the notion of a stress test. We will frequently employ stress tests later in other contexts, where we contemplate rare but potentially catastrophic risk events. Risk analysis must "stress-test" strategic initiatives In a strategic decision situation, just like in a liquidity stress test, for example, it is difficult to say ex ante what the percentage probability will be of the adverse scenario occurring. But one can nonetheless plausibly imagine how the scenario would play out, if it did occur. And it would be reasonable to expect that the organization adopt only such strategies, for which plausible downside scenarios would still be survivable. This is all good and well, but you are probably beginning to tire of the endless permutations of the risk - strategy - process trilogy. We share your unease about wanting to conceive a winning strategy by means of the risk management toolbox. The difference between Atari Computers and Apple Inc. cannot be explained by better strategic risk management processes. Exactly, how are your Netscape shares doing and where are the Palm Pilots in the smart phone store? In the end, it comes down to having the right people with the right vision make bold strategic decisions at the right time. However, we should also not pivot to the other extreme and say strategic risks cannot be managed, so let's just blindly follow our CEO's every strategic twitch in his left toe. The smart middle ground is in giving senior management space for bold strategic initiatives, but to nonetheless temper them with a candid, independent analysis of the downside scenarios, so that not everyone loses their job on another one of the CEO's brilliant ideas. And since most companies don't have a visionary Steve Jobs as boss, it would help to define the strategic initiatives in a broad inclusive consultation. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 21 Thus, the Risk Manager should not just analyze the downside scenarios of the strategic alternatives proposed by senior management, but he/she should intervene well before by ensuring that strategic initiatives are conceived through a consultative strategic planning process. This should improve the quality of the initiatives under consideration and will subsequently reduce strategy execution risk, because staff feel empowered by having contributed to the strategy definition and everyone will have a better understanding of what they are being asked to implement. Balanced Score Card for inclusive financial services A frequently used tool in the strategic planning process that facilitates the inclusive discourse about strategic initiatives and associated risks is the balanced score card method (www.balancedscorecard.org). The balanced scorecard (BSC) is a strategic planning and management system that is used extensively in industry, finance and nonprofit organizations in order to align business activities to the vision and strategy of the organization, improve internal and external communications, and monitor organization performance against strategic goals. It was originated by Drs. Robert Kaplan (Harvard Business School) and David Norton as a performance measurement framework that added strategic non-financial performance measures to traditional financial metrics to give managers and executives a more 'balanced' view of organizational performance. Initiatives Targets Measures Objectives Stakeholders Initiatives Targets Vision and Strategy Measures Objectives Business Processes Initiatives Initiatives Targets Measures Learning & Growth Objectives Targets Measures Objectives Financial Figure 4: Balanced Score Card Framework for Financial / Social Double Bottom-Line Organizations © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 22 The version of the BSC framework in Figure 4 positions the stakeholder dimension of performance above the financial objectives of the organization. Financial performance metrics would normally be found at the top of the goal hierarchy in conventional for-profit organizations. This set-up of the BSC might better reflect the mission of a MSME financial services provider, where the economic and social development returns accruing to poor clients are at least on par with the profit maximization objective. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 23 In socially-responsible MSME finance, stakeholder objectives rise to the top © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 24 5 Exercises Review Questions Unit 3 Answer the following questions using the Unit text: 1. What are the objectives of establishing a macro risk map? 2. Do you expect major differences between macro-risk maps of the type in Figure 1 between individual SME banks and microfinance institutions? 3. Would you agree that the translation of the macro risk map to a severity / probability matrix similar to Figure 2 tends to produce identical results for a wide range of MSME finance providers across various national markets? 4. Why did we call reputation and behavioral risks a "transmission layer"? Describe what is being transmitted and how. 5. Give an example of a risk dimension that is generally well suited to probabilistic analysis and explain why strategy risk is not one of those risks. Define the following terms: 6. credit transaction risk, 7. credit portfolio risk, 8. operational risk, 9. interest rate risk, 10. currency induced credit risk, 11. reputation risk. Unit 3 - Exercise 1 Let's do a completeness check on the risk identification in the macro map in Figure 1. Following are a number of risk categories or potential loss events. Try to subsume them under the proper high-level risk dimension in the macro map: 1) A branch is flooded and the server room destroyed by sewage backing up through the basement. 2) Euribor interest rates jump 2%, the cost of your EUR variable rate funding goes up. It is impossible to adjust microcredit rates in local currency upward because of competitive pressure. 3) The senior imam at the mosque in one of your key urban markets mentions microcredit as a usurious practice that is not compatible with Islam. 4) After a few spectacular IPOs on the Kenyan stock market, the Safaricom © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 25 IPO is the next big deal. Even Nairobi taxi drivers are dreaming about getting rich quickly on the stock exchange. What might this mean for a MFI raising passbook savings in the slums of Nairobi? 5) A specialized agro-finance MFI lends exclusively in the "peanut basin" area of Senegal. 6) A consumer advocacy group has contacted the MFI about an error in the interest calculation method on microloans that may have resulted in overcharging clients relative to the disclosed cost of credit. The issue affects about 10,000 current and previously settled loans. Answers: 1) Natural disaster, external event, operational risk. 2) Interest rate risk. 3) Reputation risk. 4) Directly transmitted behavioral risk not triggered by prior core risk loss event. 5) Case of high portfolio concentration, lack of geographic and industry diversification, portfolio credit risk. 6) Legal risk, part of operational risk. Unit 3 - Exercise 2: Effective Cost of Credit Calculations Background on Effective Rate Calculations EU Directive 9948/2/07 on "Credit Agreements for Consumers and repealing Council Directive 87/102/EEC" defines the "Annual Percentage Rate of Charge" in Annex 1 as a fully compounding internal rate of return on the loan product cash flows from the customer perspective. This confirms the longstanding practice in national consumer protection law in most member states. The US Annual Percentage Rate (APR) as per the 1968 Truth in Lending Act is similar but does not fully compound on a sub-annual basis. The calculation method for US-style APR and EU-style effective rates are otherwise identical, i.e. except for the distinction in the compounding for subannual period increments. The contractual payment interval and interest invoicing frequency determine the period increment for effective rate calculations. Most commonly in retail credit, interest is invoiced and installments are collected in monthly intervals. Hence, interest-on-interest, i.e. "compounding", occurs monthly and effective rates should be derived for monthly period increments. However, if interest is invoiced and installments are due on a weekly or fortnightly basis, then it will be necessary to calculate effective rates based on 52 or 26 sub-annual periods. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 26 A calculation tool for effective rates is available at mftransparency.org. However, we find this tool rather complicated and would recommend that you perform effective rate calculations yourself using the principles described here. Then you know that the result is correct and how you got there. It is really not difficult at all. The first step in calculating an effective rate is always to establish the required cash flow profile of the loan product from the perspective of the borrower: In order to get x cash in hand, how much do I have to pay back and when? This is easy to capture in a cash flow table in Excel like this: Period Cash Flow 0 +1000 1 -400 2 -400 3 -400 Let's assume the above cash flow profile was a real loan for three months. What is the effective annual rate? You type into Excel =RATE(3,-400,1000) and obtain the result of 9.701%. But attention, this is the period effective rate for a month. The equivalent annual rate, fully compounding, is found by =(1+0.09701)^12 - 1 = 203.8% That is shocking, but it is the reality. When interest rates are generally low, then the difference between the correct EU-style effective rates and the US-style approximation is small. However when rates are generally high, as in microfinance, the difference in disclosed annual effective rates is large: A monthly effective rate of 9.701% gives 203.8% annual EU-style and 12*9.07% = 116.4% APR US-style. For a conventional mortgage loan, the monthly effective rate might be 0.5%, leading to US-style disclosure of 6.0% per annum and EU-style effective of 6.17%. Why is it correct to use full sub-annual compounding? Because it is the reality of what the loan costs: An effective rate is supposed to be a unitary index of the overall costliness of a loan that can be compared across various different rate conventions and combinations of interest and fees. It answers the question of how much it costs to have use of 1 dollar for one year under this particular loan arrangement. The 203.8% effective rate from above means that it costs 2.04 dollars to have use of one borrowed dollar for one year. So, the example of 1,000 repayable in three monthly installments of 400 has the same per-dollar annual cost as a loan that gives you one dollar today and for which you pay back 3.04 dollars principal and interest exactly one year later. If the client in the example (1,000 for 3 months) really needed to use 1,000 for a full year, he would already have to borrow 400 again at the same rate one month after disbursement. One month later, he would re-borrow the next 400 installment plus the interest and principal payment on the 400 taken the previous month and so forth. If he kept rolling his debt and interest forward such that he always has use of exactly 1,000, the client would have paid exactly 3,038 dollars over the year. That is 2,038 in interest and the 1,000 © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 27 principal returned on the last day. Thus is the reality of the payday loan store customer. They keep coming back faster and faster to re-borrow the same 500 dollars and easily end up paying 1,000 over the year for that "service". Now, microcredit is not necessarily all that different from a payday loan store. Most microentrepreneurs actually have a permanent need for revolving working capital. They also have a tendency to quickly re-borrow the funds that the MFI is pulling back in via the short-term, high-rate loan schedule. So, "(1+monthly effective)^12 -1" is much more realistic than "monthly effective times 12", also in microcredit. Back to step 1: we establish the cash flow profile of the loan from the client perspective. If there is one disbursement and a number of identical evenly spaced repayments, we have a simple annuity and we can use =RATE() in order to find the period effective rate. Technically, this period effective rate is the internal rate of return which sets equal the present value of the debt service payments to the initial disbursement received by the client. If the loan payments are not a fixed installment and/or are not scheduled in fixed intervals, we cannot use =RATE(). We now must actually put the cash flows into a period-by-period timetable and calculate the internal rate of return on this flow profile with the Excel function =IRR(). For example, the IRR of the following profile Month 0 1 2 3 4 5 6 7 Cash Flow +1000 -400 -300 0 +20 -150 -200 -50 is 2.67% per month or 37.2% per annum. The cash-flow time table approach is also critical in order to get a handle on various complicated interest rate and fee conventions. It is not necessarily illegal to calculate "flat" interest versus declining balance, quote nominal interest per month rather than per annum, or quote a low interest rate but charge high service fees. (For those new to microcredit: 2% per month "flat" interest over 9 months means that the institution would charge 2% on the initially disbursed amount every month for nine months together with 1/9 of the disbursed amount in principal every month.) When you are all done with the flat/declining/increasing balance shenanigans, you have to tell the client how much she will get disbursed cash in hand and how much she will have to pay back and when, all service fees, document charges, interest and account maintenance included. That gives © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 28 you the cash flow profile, which is the only thing that really matters. The annualized period IRR of the client cash flow profile is the proper effective rate! So far, easy. The tricky part in effective rate calculations is the notion of connected services. The general rule is that any additional product or service that the lender requires the borrower to purchase as a precondition to receiving the loan should be added into the cash flow profile. Suppose the lender asks that the client purchase a loan booklet for 10 dollars in order to receive the loan. That's obvious. A loan booklet has no independent value. The lender would never sell just a loan book without a loan. Therefore, the loan booklet is just another fee that must be added into the cash flow profile of the loan. Next, think of credit life insurance. That's more difficult. If the life insurance is provided by a captive insurance company owned by the lender, if there is no cash benefit to the borrower and the insurance covers only the outstanding balance, then indeed we have an interest replacement therapy on our hands. The premium then is part of the cost of credit and must be factored into the cash flow profile of the loan before calculating the IRR. However, if the lender simply requires that borrowers have life insurance, and borrowers can bring coverage certificates from another insurance company, then the insurance is a free-standing financial contract and does not have to be factored into the cost of credit. Now the big deal: cash collateral or parallel compulsory savings. In European consumer protection rules, it is made quite clear that it is undesirable when banks lend to a consumer and then require that all or part of the proceeds be deposited with the lender as collateral. Unless the deposit earns the same effective rate as the loan costs, the differential between the deposit rate earned by the customer and the rate paid for borrowing your own money back should be included in the cost of credit. Technically, that's easy to do, you merge the two cash flow profiles of the loan and the required concurrent deposit into one. Then you run the IRR across the net cash flow profile to get the effective cost of receiving the net liquidity from the customer perspective. We know of no MFI that actually discloses this type of consolidated effective rate including the cost of the parallel collateral deposit to the client. Unless everyone does it this way, it is just too unflattering to be the only one who shows such a high cost of credit. But it is an interesting calculation nonetheless that reminds us how expensive microcredit really can be. See Exercise 2.6. © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 29 Exercise 2.1: Useful Excel Formulas for Loan Schedules Before you get started on the effective rate calculation exercises below, please familiarize yourself and experiment in Excel with the following financial formulas: =RATE() =PMT() =PPMT() =IPMT() - Period IRR in an annuity - Annuity payment - Principal component in an annuity payment at period n - Interest component in an annuity payment at period n =IRR() - Internal rate of return calculated on any equally spaced cash flow schedule. Not limited to annuities. =XIRR() - Internal rate of return calculated on an array of dates and payments. Payment dates may be irregularly spaced. For those using other language versions of Excel, we provide a table with formula equivalents in the file FormulaEquivalents.xls. Exercise 2.2: Annual Effective Interest Rate USD 1,000 loan over 12 months at 100 dollars fixed monthly installment. What is the annual effective rate? Use a direct calculation method first and also try to get the result using a cash flow table and the IRR function. Solution: 41.30% p.a. (See also attached Excel Workbook EffectiveRatesM3_Ex1.xlsx) Exercise 2.3: Annual Effective Interest Rate GHS 1,000 10-month loan at 36% p.a. on declining balance with linear principal payments. What is the Annual Effective Rate? Hint: This is not an annuity. You have to first figure out the payment schedule. Solution: 42.58% p.a. (See also attached Excel Workbook EffectiveRatesM3_Ex1.xls) Exercise 2.4: Annual Effective Interest Rate GHS 5,000 loan for 15-months, 36% p.a. nominal on declining balance with annuity-style fixed monthly payments. Plus commission and fees worked into the monthly payment amount. Commission: GHS 100 up front. Monthly account maintenance: GHS 5. What is the Annual Effective Rate? Solution: 50.02% p.a. (See also attached Excel Workbook EffectiveRatesM3_Ex1.xlsx) © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 30 Exercise 2.5: Annual Effective Interest Rate KES 100,000 loan for 26 weeks, fixed weekly interest and principal payments. 2% per month (= 2%/4 per week) flat interest. KES 1,000 application fee withheld from loan proceeds. What is the Annual Effective Rate? Solution: 68.26% p.a. (See also attached Excel Workbook EffectiveRatesM3_Ex1.xlsx) Exercise 2.6: Annual Effective Interest Rate PGK 2,000 microloan for 9 fixed monthly installments at 3% per month flat, 15% parallel collateral savings required that pay 4% p.a., 20 PGK upfront charge, PGK 5 monthly membership. What is the Annual Effective Rate, if you factor in the rate differential on the client's collateral savings? Assume that the full principal in the collateral savings account is blocked until the final loan installment is settled. Solution: 133.02% p.a. (See also attached Excel Workbook EffectiveRatesM3_Ex1.xlsx) © 2016 Frankfurt School of Finance & Management Certified Expert in Risk Management Unit 3: Risk Landscape and Taxonomy 31