Principle #1 – Avoidance of Overindebtedness A special presentation for YOUR INSTITUTION made possible by the Smart Campaign www.smartcampaign.org Client Protection Principles 1. Avoidance of over-indebtedness 2. Transparent pricing 3. Appropriate collections practices 4. Ethical staff behavior 5. Mechanisms for redress of grievances 6. Privacy of client data 2 Principle #1: Avoid Over-indebtedness Providers take reasonable steps to ensure that credit will be extended only if borrowers have demonstrated an adequate ability to repay and loans will not put the borrowers at significant risk of over-indebtedness. Similarly, providers will take adequate care that non-credit, financial products (such as insurance) extended to low-income clients are appropriate to their needs and means. 3 Principle #1: Avoid Over-indebtedness What it means for the clients: • Clients should make prudent decisions and assume responsibility for their actions. • Clients should be capable of making payments on their debt without sacrificing their basic quality of life. What it means for the institution: • A financial institution measures its compliance with this principle by carefully assessing the client’s capacity to successfully repay the loan. 4 What causes over-indebtedness? • Loans for amounts surpassing client’s debt capacity - multiple loans at one or several institutions. • Lack of information on existing liabilities (e.g. nonexistent credit bureaus or lack or reporting to credit bureaus by other lending institutions). • Incentives for loan officers to oversell credit products. • Products that do not match client’s business cycles (e.g. agriculture). • Institutions relying on guarantees as a substitute for capacity analysis. • Accidents, disease or natural disasters. 5 What does over-indebtedness mean for MFIs? Increase in client delinquency Portfolio provisioning prevents institutions from making other loans Slow and costly legal proceedings for collections Damage to the institution’s image and portfolio 6 What does over-indebtedness mean for clients? Borrowers and their family members work longer hours Savings depletion Sale of assets, including productive assets Reduction of consumption Less investment in productive assets and human capital Borrowers take new loans to pay off current debt Search for help from family, depletion of relatives’ assets Source: DAI 7 Photo of Presenter INSTITUTION: • Founding & Organizational Status • # clients Institutional Logo NAME, TITLE • Bullet about experience • Bullet about experience 8 Presenter Takeaways 9 Questions or comments for the presenter? 10 Photo of Presenter INSTITUTION: • Founding & Organizational Status • # clients Institutional Logo NAME, TITLE • Bullet about experience • Bullet about experience 11 Presenter Takeaways 12 Questions or comments for the presenter? 13 What actions can MFIs take? Solid Credit Methodology Adjust to Market Needs • • • • Standardized, well-documented implementation Track record of good credit evaluation Establish limits on lending to indebted clients Check credit bureaus where they exist • Offer loan consolidation products • Make loans based on business size and investment needs • Develop refinancing policies that take into account real repayment capacity • Require higher guarantee coverage ratios 14 Source: Apoyo Integral, El Salvador What actions can MFIs take? Monitor Portfolio Quality • Monitor client use of loans • Follow-up Credit Committee analysis with oversight on actual borrower capacity and delinquency • Goal-setting with clients on monitoring visits Good Customer Care • Decrease client incentive to take loans from multiple institutions • Quick, timely, and personalized customer service to increase loyalty • Additional service offerings (insurance, etc.) • Outreach to ignored market segments 15 Source: Apoyo Integral, El Salvador Beyond Codes: Indicators of Good Practice Management Awareness of Risks • Management regularly obtains information on client over-indebtedness and uses it to respond appropriately to risks. Management Monitors Lending Practices • Management regularly monitors product performance and lending practices and uses the information to improve operations. Effective Capacity Analysis • The loan approval process requires evaluation of borrower repayment capacity & loan affordability. Loan approval does not rely solely on guarantees (whether peer guarantees, co-signers or collateral) as a substitute for good capacity analysis. Clear Debt Thresholds • Credit approval policies give decision makers explicit guidance regarding borrower debt thresholds and acceptable levels of debt from other sources. 16 Beyond Codes: Indicators of Good Practice Check with Credit Bureau • When available, the financial institution checks a Credit Bureau for borrower current debt levels and repayment history. When not available, the financial institution maintains internal records and when possible, consults with competitors for same. Multiple or Flexible Products • The financial institution offers multiple loan products or flexible ones that address different business and family needs Incentives Should Balance Growth and Portfolio Quality • Incentives and productivity targets reward risk management. Productivity targets and incentive systems value portfolio quality at least as highly as other factors, such as disbursement or customer growth. Growth is rewarded only if portfolio quality is high. Internal Audit Monitors Adherence to Lending Methodology • Internal audits check household debt exposure, lending practices that violate procedures including unauthorized re-financing, multiple borrowers or co-signers per household, and other practices that could increase indebtedness. 17 Good Practices from Beyond Codes In addition to implementing a rigorous credit methodology to ensure that clients are capable of repaying their loans, one MFI in Bosnia-Herzegovina: • Tasks its internal audit department with following up on a sample of clients who have fallen behind on their payments. • Has the internal audit team conduct client interviews. • Focuses interviews on ensuring that loan officers followed proper procedures to avoid over-indebtedness. • Includes in the interview a focus on diagnosing the causes of the client’s repayment challenges. 18 Discussion We have talked about multiple examples of good practices that are currently in use, but overindebtedness continues as one of the key problems MFIs face in many countries. What do you see as the next steps to address this? 19 Next time… We will discuss Principle #2: Transparent & Responsible Pricing We will examine concrete examples: • What is transparency? • How can you tell if clients understand the information shared with them? • What role does financial literacy play? 20 Questions? Contact the Smart Campaign For more information visit: www.smartcampaign.org 21 Join the Campaign & Endorse the Principles of Client Protection www.smartcampaign.org Thank you! 22