i n s i g h t s D E V E L O P M E N T R E S E A R C H Finance matters Financial liberalisation: too much too soon? A n efficient and stable financial system is important for economic growth and poverty reduction. The financial crises that have afflicted many countries in recent times have been a costly and painful reminder of the disastrous consequences for development of weak financial markets. The recurrence of financial crises, at both the international and national levels, and the adverse effect they have had on economic growth and poverty levels, have highlighted the need for a policy framework which addresses the inherent vulnerability of financial markets to systemic instability and failure. Governments have always intervened in the financial sector and there are sound theoretical and practical reasons for doing so. Financial markets are characterised by problems of limited and unequal information, making them inherently imperfect and prone to failure. Financial regulation and supervision are therefore essential for efficient and stable financial market development. How should governments intervene? Have financial liberalisation and financial sector reform made financial systems more, or less vulnerable to instability and systemic crises? How can the process be better managed? What is the best policy framework for supporting financial sector development in low-income countries? Repression to liberalisation For many years, governments followed a policy of financial ‘repression’, which relied on fixing interest rates below market levels and controlling the allocation of credit. The economic distortions induced by these policies were considerable. Financial systems remained under-developed, lending patterns were inefficient and failed to achieve their distributional goals. Negative real interest rates led to low savings and encouraged capital flight. Macro-economic performance also deteriorated – countries with large negative real interest rates experienced lower allocative efficiency and growth rates. In the stateowned banking sector, poor lending decisions (often politically influenced) and low repayment rates led to bank insolvency and large budgetary bailouts of depositors and creditors. March 2002 A growing awareness of the economic costs of financial ‘repression’, led to financial ‘liberalisation’ as the dominant policy paradigm over the past two decades. Initially, the relaxation of controls on interest rates was the focus for financial reform which was often triggered by a financial crisis. The relaxation of controls on the financial sector was often part of a more general policy shift towards liberalisation of the domestic economy and opening up to the international economy. Liberalisation soon broadened therefore beyond interest rate liberalisation, to include a wide range of measures constituting a programme of financial sector reform. For many countries, financial sector reform was adopted under World Bank sectoral or structural adjustment lending conditionalities, the key elements of which included: privatisation of banks, entry of new domestic and foreign entrants into the banking sector, bank restructuring and recapitalisation, opening up of the capital account, strengthening bank regulation and supervision institutions. Has financial liberalisation worked? The period of financial liberalisation coincided with, or was soon followed by, heightened financial instability, culminating in the www.id21.org inside Better banking in Africa? A foreign affair Prudence pays? Crisis in Jamaica Bumpy road to Basel Regulating microfinance? Curbing capital flight dramatic financial crisis in East Asia in the second half of the 1990s. Clearly, financial liberalisation has not led to a smooth transition to a stable and efficient financial system. It would be wrong, however, to jump to the easy, but shallow, conclusion that financial liberalisation has ‘failed’. Firstly, the fact that the period of financial liberalisation coincides with a period of increased systemic instability does not prove causality. Secondly, no process of change comes cheap: a reasoned assessment of the costs and benefits of the policy change is needed. And thirdly, what would have been the outcome without the policy change? Finally, the impact of financial liberalisation will differ between countries, depending on each country’s economic and institutional characteristics. The more relevant research issue, therefore, relates to the design and timing of context-specific policy measures which will contribute to the development of an efficient and stable financial system. Could financial liberalisation have been managed better? If so, what policies are now needed? The articles in this issue discuss these questions by summarising the findings of recent research studies on the impact of financial liberalisation in developing countries. The commercial banks are the dominant component of the financial sector in low-income countries and are critical to the efficiency and stability of the financial system as a whole. Financial liberalisation was associated with a shift in prudential regulation from direct regulation of banks, by, for example, regular site visits, to an indirect approach based on the monitoring of bank capital to ensure that it remained adequate in relation to the risk being taken. Additional regulatory measures are insights 40 insights 40 also necessary to restrain the activities of the various policy interventions designed to privatised and other newly-established private strengthen commercial bank lending, banks. The regulatory and supervisory particularly to small-scale borrowers and startframework may also need to be extended, to up enterprises. cover microfinance institutions which have Financial liberalisation has resulted in developed significant depositincreased foreign participation in The experience with taking capacity. the domestic banking sector. financial liberalisation reveals Murinde and Tefula examine Llewellyn highlights the a strong correlation between the implications for subpotential problems of relying liberalisation and financial on a capital adequacy Saharan Africa and identify crisis. framework, as proposed in the the main benefits (such as Bank of International Settlements’ new improvements in quality, pricing and Basel Accord, as the main instrument for supply of financial services, increased regulating bank activities. Systemic stability competition) and the costs (increased and the safety and soundness of banks need exposure to capital flight for example) of to be considered in a wider ‘regulatory foreign banks. regime’ framework which should include Capital account liberalisation has been a official supervision, market discipline, incentive prominent component in financial structures for banks, and corporate liberalisation programmes. FitzGerald argues governance arrangements for banks. that premature capital account liberalisation Murshed identifies four main obstacles to can be highly destabilising. Theory and efficient banking regulation: a) information, experience indicate the desirability of contracting and monitoring problems, b) lack scheduling capital account liberalisation after of supervisory personnel, c) high operational appropriate domestic financial liberalisation. costs and d) poor credibility and regulation of To prevent massive capital inflows that regulatory bodies. The appropriateness of threaten effective domestic policy and raise various policy measures for dealing with these the probability of sudden reversal if capital constraints are discussed and ranked in terms flows, emerging market governments need to of their suitability for low-income countries. use market-based intervention instruments on What are the implications of allowing short-term capital flows. microfinance institutions to offer a range of Using the case of Jamaica’s policy response financing services beyond small-scale lending to the financial crisis of the mid-1990s, asks Maimbo? Drawing on research in the Tennant and Kirkpatrick compare the microfinance sector in Zambia, Maimbo approach adopted to a hypothetical ‘IMF considers options open to the regulatory model’ policy prescription arguing that authorities. Top of the list is a flexible, financial crisis management programmes are graduated regulatory structure, which more likely to succeed if they draw on natural encourages microfinance institutions to stakeholders’ expertise and knowledge. voluntarily increase their capital base in order Too much, too soon? to engage in a set of permitted activities. The experience with financial liberalisation The growth of commercial bank lending to reveals a strong correlation between the private sector following financial liberalisation and financial crisis. This can be liberalisation has been disappointing. Drawing explained partly by the exposure of existing on the experience in a number of sub-Saharan inefficiencies and distortions in the financial African countries, Brownbridge identifies Banking reforms in Africa What has been learnt? O ne of the major objectives of liberalisation is to boost bank lending to the private sector, which is regarded as the engine of economic growth. However, the growth of commercial bank lending to the private sector following financial liberalisation was disappointing in many countries, especially bank lending to small scale borrowers and start-up enterprises. Many countries in sub-Saharan Africa liberalised their financial sectors in the late 1980s or 1990s to encourage greater financial efficiency. Policy reforms included: removing interest rate controls, removing requirements on banks to lend to specific sectors, privatising state-owned banks, and allowing easier entry by private sector banks and non-bank financial institutions (NBFIs), including foreign banks. At structure, and partly by a failure to develop a strong regulatory and supervisory framework, prior to liberalisation. Weaknesses in the initial conditions affect the ability of the privatised banks and new market entrants, to operate on broadly commercial principles. Borrowers are often unable to service their loans, due to poor quality lending and high interest rates. Liberalisation of the capital account increases the inflow of foreign capital, but at the same time threatens the stability of the financial institutions, by increasing the exchange rate and domestic lending risks. The existing regulatory and supervisory system may be unsuited to a market-based environment. Consequently, across-the-board, ‘big-bang’ financial liberalisation and financial sector reform increase the likelihood of systemic crisis, where the institutional and human resource environment is weak. Much of the blame for post-liberalisation financial crisis lies, therefore, with the scale and sequencing of financial reform. What is needed is a more gradual and considered approach to financial liberalisation, which recognises that institutional strengthening, especially in the regulation and supervision capacity, is a prerequisite for creating a more efficient and stable financial sector which can contribute fully to achieving economic growth and poverty reduction in developing countries Colin Kirkpatrick Institute for Development Policy Management, University of Manchester, Oxford Road, Manchester M13 9GH, UK T +44 (0)161 275 2800 colin.kirkpatrick@man.ac.uk See also ‘Financial liberalization: how far, how fast?’ Cambridge University Press by G. Caprio, P. Honohan, J. Stiglitz, 2001 ‘Finance for Growth. Policy Choices in a Volatile World’, World Bank and Oxford University Press: Washington DC, 2001 ‘Financial regulation in developing countries’, Journal of Development Studies 37/1 by M. Brownbridge and C. Kirkpatrick, 2000 borrowers from the credit markets. the same time, to promote sounder banking Financial liberalisation has changed the nature and help protect bank deposits, reforms were of the risks facing the banking system. introduced to strengthen the prudential Reforms have reduced the risk of regulation (rules and regulations Liberalised financial bank distress caused by designed to restrict banks from markets require strong, governments directing banks taking excessive risks with impartial supervision, (government-owned banks depositors’ funds) and independent of political in particular) to lend to supervision of banks by interference, to protect unviable and uncreditworthy improving banking laws and depositors’ funds. borrowers. New sources of risk expanding supervisory capacities. have emerged, however: greater It has proved difficult for competition is squeezing the profits of weaker commercial banks to build up sound banks; the entry of new banks that lack the commercially viable loan portfolios, for several expertise to manage risks in liberalised markets; reasons: greater opportunities for fraud and abuse of ● Domestic private sectors are weak: few depositors’ funds by banks and NBFIs; and risks creditworthy borrowers exist. arising from foreign exchange denominated ● Banks face acute problems of information transactions such as lending by banks in foreign (concerning the viability and exchange and the contracting of foreign creditworthiness of borrowers) and contract exchange liabilities by banks. enforcement problems which increase the Kenya, Nigeria, Uganda and Zambia and risk of loan default. others have suffered from the failure of ● High inflation and exchange rate volatility privately owned banks and NBFIs – often due to has exacerbated the risks of lending in fraud and abuse by managers and owners, some countries. especially insider lending. These bank failures Large government deficits in some countries, have proved costly for taxpayers, who have which have to be funded through sales of often had to fund the reimbursement of treasury bills to domestic financial markets to deposits. Many of the failures exposed serious avoid inflationary growth of the money weaknesses in prudential systems: prudential supply, have crowded out private sector www.id21.org A foreign affair How far does Africa need foreign banks? F ● Swaziland. A small domestic market means that locally-owned banks cannot recover high set-up costs as foreign banks can from profitable operations elsewhere. Financial liberalisation increases the degree of access by foreign banks. Foreign banks in Tanzania had only 5 percent access pre1980 when policies were restrictive. This figure has now risen to 76 percent. So too the trend in Ethiopia (at 2 percent because of its barriers to entry under a Marxist regime) is now expected to change. Although bank loan growth patterns are similar for both domestic and foreign banks, increased foreign participation reduces the variability of loan supply. Contrary to expectation, foreign and domestic banks both shoulder a considerable amount of non-performing loans, possibly due to differences in accounting practices. Foreign banks are more profitable but not necessarily better capitalised than their local counterparts. ree foreign bank entry is essential to financial liberalisation in Africa. It is also integral to the World Trade ● Organisation (WTO) protocols on the General Agreement on Trade in Services (GATS) embraced by most African governments. What are the pros and ● cons of free foreign bank entry? What are the implications for local domestic banks? Foreign banks are central to the evolution of African banking. In colonial times, formal ● banks were foreign. Post-independence in the 1960s saw the creation of a two-tier banking system, with a central bank responsible for monetary policy, and several Mixed blessings? The pros and cons of commercial banks handling deposits and foreign bank entry loans. The lending objectives of foreign Foreign banks directly improve the quality, banks, however, severely marginalised pricing and availability of financial indigenous entrepreneurs. Foreign banks services. They engender Some governments engender competition with competition with domestic intervened by domestic banks and improve banks and improve financial nationalising foreign financial system architecture, for system architecture, for banks – most are example, accounting, auditing, example, accounting, now insolvent and transparency, and risk auditing, transparency, and either privatised or sold management. risk management. Foreign banks to foreign owners. also increase competitiveness and Recent research by the efficiency leading to better quality customer Birmingham Business School and the services. Institute for Development Policy and However, foreign banks can destabilise Management examined how open 26 domestic bank credit by providing additional African economies are to foreign channels for capital flight. Foreign-owned participation in their domestic banking banks also tend to withdraw quickly from the markets. Key findings include: domestic market in the face of financial crisis, ● Foreign banks can be totally involved in as was the case in South East Asia. In smaller economies such as Lesotho and regulations were not properly enforced and distressed banks were allowed to continue operating, often with financial support from central banks and governments, for too long after they had become insolvent, merely increasing the eventual cost of collapse. What should governments do? To encourage the growth of bank lending to the private sector, governments should: ● Maintain macroeconomic stability and avoid financing large fiscal deficits from the domestic banking system. ● Accumulate savings in the domestic banking system to create more room for private sector borrowing: in Uganda in the 1990s, fiscal reforms enabled the government to accumulate bank savings, which in turn facilitated a strong recovery in private sector bank credit. ● Improve the institutional environment for bank lending by strengthening the commercial legal system, so that banks can enforce contracts and foreclose on defaulters without long delays. ● NBFIs – leasing companies, merchant banks, mortgage institutions, microfinance institutions for example - good at filling specific niches in the financial markets, need support and encouragement. Most commercial banks are not suited to lending to the small scale enterprises likely to prove crucial to future growth. Liberalised financial markets require strong, impartial supervision, independent of political interference, to protect depositors’ funds. While many countries have brought their banking laws into line with what is regarded as best practice, better enforcement of prudential regulations is essential. Regulators must force insolvent banks to be re-capitalised by their owners or by new owners, or close them down promptly. Since supervisory resources are scarce, regulatory agencies must focus their limited resources on those banks and NBFIs which pose the greatest prudential risk Martin Brownbridge Institute for Development Policy and Management (IDPM), University of Manchester, Crawford House Oxford Road, Manchester M13 9GH, UK MartinBrownbridge@hotmail.com See also ‘Financial regulation in developing countries’ Journal of Development Studies 37/1 by Martin Brownbridge and Colin Kirkpatrick, 2000 ‘Banking in Africa: The impact of financial sector reform since independence’, James Curry: London by Martin Brownbridge and Charles Harvey, 1998 addition, foreign banks use their financial power to cherry pick the most lucrative transactions, thus relegating domestic banks to more risky markets. How should African governments respond? ● Where there is too much foreign bank involvement, local private banks should be encouraged to merge and expand to become more viable. ● Policy makers should not be complacent regarding the liquidity and capitalisation of foreign banks, even if the banks fall under the jurisdiction of the parent country. Both domestic and foreign banks should be subjected to the same regulatory regime, and the level of monitoring should be equally strict. ● By designing policies that enhance foreign bank participation for example setting up new banks or privatising state-owned banks. ● Sequencing is crucial. It is important to strengthen and enhance the international competitiveness of the domestic banking system before opening up fully to foreign entry Victor Murinde Birmingham Business School, University of Birmingham, Edgbaston, Birmingham B15 2TT, UK T +44 (0)121 414 6704 V.Murinde@bham.ac.uk Moses Tefula Institute for Development Policy and Management, University of Manchester, Oxford Road, Manchester M13 9GH, UK T +44 (0)161 275 2827 Moses.Tefula@man.ac.uk See also ‘Foreign bank participation in the domestic banking market of African economies’, Finance and Development Research Programme Working Paper #37: IDPM, University of Manchester, 2002 Crisis in Jamaica Has the cost been excessive? I n recent decades, financial crises have threatened the financial and monetary systems of many developing countries. But have the crisis management measures alleviated or intensified the accompanying economic, social and political upheaval? Research from the University of Manchester’s Institute for Development Policy and Management looks at Jamaica’s recovery from financial crisis in the mid-1990s. The paper argues that financial crises can be resolved without excessively impairing the real economy, but only if the problem is properly diagnosed and if the treatment is appropriate, as determined by local conditions. It rejects the IMF’s standard shock treatment as a panacea for local financial crises. Instead it uses Jamaica’s experience in responding to its crisis without the IMF’s involvement to show that crisis management programmes are more likely to succeed if they draw on the national stakeholders’ expertise and knowledge. The Jamaican financial crisis was severe. A downturn in the real estate and stock markets precipitated illiquidity problems in the March 2002 Bumpy road to Basel countries. Banks will be required to hold more capital against loans to developing countries than is justified, reducing the supply of loans Banking regulation: precision v accuracy and increasing their costs. Increased sophistication and precision does not anks play an important role in the economy and need to be regulated. Safe, sound necessarily imply increased accuracy: the banks and a stable financial system are essential. Without regulation, the banking distortion of bank lending with respect to loans system would be unable to perform its basic functions well, such as financing to developing countries is an important economic development and poverty reduction. Nor would people have the confidence example. Would the same objectives be to use banks. achieved with a less complex and costly system? The regulation of banks for capital ■ Do the regulatory requirements correspond to the amount of Regulation is a response to adequacy purposes (ensuring that banks hold capital a bank really needs, given the risks involved? market failure. Regulation, sufficient capital to cover their risks) has ■ Do they create incentives for effective and efficient risk however, may undermine other important implications for the safety and analysis, management and control mechanisms? mechanisms in the regulatory soundness of banks, stability, efficiency and ■ Does the regime create incentives for an efficient allocation regime: excessive reliance on consumer protection. Regulation may be of capital within the bank across different business areas and detailed and prescriptive rules precise, through detailed and prescriptive asset classes? may weaken incentive structures rules, but is it always accurate? While capital ■ Does it create perverse incentives for regulatory arbitrage – and market discipline. It may also adequacy rules may specify how much capital business structures that lower capital requirements without weaken corporate governance each bank should hold, such rules may not any corresponding reduction in the bank’s risk profile? within banks and blunt the truly reflect the risks involved and ■ Are the capital requirements competitively neutral as incentives of the market, other unintentionally force banks to hold either too between countries and competing banks? banks, depositors and so on, to much or not enough capital. Too little capital ■ Is the amount of capital appropriate for overall portfolio monitor and control the increases the danger of bank failure whilst risks? behaviour of banks. The value of too much capital imposes unnecessary costs ■ Do the requirements impair competition in banking markets? Basel 2 depends upon its accuracy: on banks and their customers and may reduce ■ Do they have detrimental effects on the macro-economy? ● Is better accuracy possible at the efficiency of the banking system. ■ Is the regime unnecessarily complicated and prescriptive? an acceptable cost to banks and A major new initiative from the Basel ■ Does it create or reinforce incentives for stakeholders? regulatory and supervisory Committee on Banking Supervision is the agencies? Basel 2 Accord – the proposed new capital ● Are the benefits of a complex set of capital suggested in the box above. adequacy framework. Set to replace the Basel adequacy arrangements enough to offset the What is impact of the Basel Accord on Accord of 1988, accepted by nearly all higher compliance and monitoring costs that developing countries likely to be? Will it countries as the basis for the regulation of they will inevitably entail discourage banks from lending to their banks, the Basel 2 Accord stipulates how developing countries if excessive risk weight much capital banks should hold in relation to David T. Llewellyn is applied to loans to the south, as critics their risks. But shouldn’t systemic stability and Economics Department, Loughborough University, maintain? the safety and soundness of banks be Leicestershire, UK Basel 2 is more detailed and complex considered in a wider framework than just T +44 (0)1509 222 700 D.T.Llewellyn@lboro.ac.uk than its predecessor, for example applying capital adequacy rules? A ‘regulatory regime’ risk weight to different classes of assets and should also include official supervision, market See also ‘Some regulatory lessons from recent bank crises’, De loans. If risk weights don’t reflect true risk, discipline, incentive structures and corporate Nederlandsche Bank Staff Report: Amsterdam, by D. T. banks’ balance sheets and lending policies governance arrangements for banks, and Llewellyn, 2001 will become seriously distorted. If risk intervention arrangements should they get ‘Bumps on the Road to Basel: An Anthology on Basel 2’ weights are too high, lending will decrease into difficulty. Ten tests to gauge the Centre for the Study of Financial Innovation: London, 2001 with serious consequences for developing suitability of any capital adequacy regime are B overexposed life insurance industry. Affiliated arrangements to protect depositors. The commercial banks were infected, and despite ensuing credit crunch, and contraction in Central Bank assistance, panic spread economic activity and social unrest, stand in throughout the sector. The government was stark contrast to the relative calm maintained initially inclined to follow the standard remedy of in the Jamaican financial sector and wider closing distressed institutions. However, after society. pausing to evaluate the extent of the The paper recognises the high cost of problem, fast track legislation and the Jamaican intervention, and The Jamaican case study other measures were introduced the worrying resultant debtshows that the cure for severe to resuscitate the sector. overhang, but argues that financial crises will always The Jamaican response to this is less significant be painful, but the adjustment the crisis was unusual, as it when compared to what costs can be reduced if an disregarded contemporary would have occurred if the appropriate policy response multilateral wisdom and fully standard IMF prescription is adopted. protected all deposits. This was had been adhered to. The done to maintain the public’s confidence in Jamaican case study shows that the cure the sector and prevent international capital for severe financial crises will always be flight. Instead of closing institutions, the painful, but the adjustment costs can be government created the Financial Sector reduced if an appropriate policy response is Adjustment Company (FINSAC) to assist troubled adopted. The adoption of universal panaceas financial institutions with an injection of capital. has tended to worsen rather than alleviate In exchange, FINSAC acquired a combination of crises. Responses must be appropriate to each equity, board seats and other assets, which financial sector’s structure and history and to facilitated the much-needed restructuring and the broader social and economic environment. subsequent divestment of the sector. ● During periods of financial panic, A comparison of the effect of this response governments should adopt an approach with that of the IMF-led response to the South aimed at restoring public confidence. Public East Asian crisis is instructive. The Asian resources may have to be used for bank meltdown resulted from financial panic, restructuring and protection of deposits, but triggered by the closure of institutions without should be complemented by strong incentives against future moral hazard. ● Post-crisis financial restructuring is vital and best carried out by strong, independent public agencies with political and legal clout to implement difficult decisions. ● Strengthened prudential regulation and supervision of the financial sector is crucial, but in periods of crisis, banks should be given appropriate leniency to meet these regulatory standards. ● Post-crisis policies should focus on the reduction of social hardships resulting from the linkages between the financial sector and the real economy David Tennant Department of Economics, University of the West Indies, Jamaica Davidf_Tennant@hotmail.com Colin Kirkpatrick Institute for Development Policy and Management, University of Manchester, Oxford Road, Manchester M13 9GH, UK T +44 (0) 161 275 2800 colin.kirkpatrick@man.ac.uk See also ‘Responding to Financial Crisis: Better off without the IMF? The case of Jamaica’ Finance and Development Research Programme WP #38: IDPM University of Manchester, by C. Kirkpatrick and D. Tennant, 2002 insights 40 Prudence pays? Regulating the financial sector A that two banks with the same capital adequacy ratio and using similar risk management procedures, may have completely different risk profiles if bank owners and managers’ interests diverge. Direct control and impact on output: such as ceilings on risky assets and on total asset growth and lending rates. While direct controls may prevent countries from experiencing crises, they are usually at the expense of financial sector performance – important for stimulating general economic activity. Restraints on output can also lose effectiveness as a result of financial innovation and if the incentives driving bankers’ actions are ignored. Controls on process or supervision: Prudential restraint such as overseeing and influencing banks’ risks policy framework, internal reporting standards, or market and credit risk management procedures would result in the least crisis-prone financial sector, but are complex and expensive to implement in countries where rent seeking activities such as corruption, bribery, and lobbying are commonplace. Increasing bankers’ liability limits: a powerful incentive to bank owners to stay prudent if liability is extended to typical LDC circumstances personal wealth, although penalties for c. Small d. Poor risk-taking may become too high. banking credibility of While raising capital ratios and liability sector government limits might be suggested to countries agencies for with insufficient supervisory skills both regulatory policy tools could induce either banking enforcement disintermediation. To guarantee profitability, limiting entry could be a ✶✶✶ ✶✶✶✶ solution, although rent-seeking activities may emerge. LDCs need a regulatory framework ✶✶✶✶✶ ✶ that rewards prudent risk-taking and punishes misconduct: possible policy options are summarised in the table strong banking system is the backbone of a robust financial sector. Research by the United Nations University’s World Institute for Development Economics Research identified four main obstacles to efficient banking regulation in LDCs: a serious information (data on many aspects of the economy is unavailable), contracting and monitoring problems b a paucity of well-paid, qualified officials and Incentive-compatible policy instruments under infrastructure for a. Information, b. Paucity of adequate supervision monitoring, well-paid, c high operation costs and contracting, qualified a limited choice of problems officials and financial assets for infrastructure diversification purposes for adequate curtails profitability supervision d poor credibility of Capital adequacy ✶✶✶ ✶✶✶✶✶ government agencies. What policies would work Contingent best to strengthen the liability limit ✶✶✶✶✶ ✶✶✶✶✶ banking sector and restrain Entry barriers irresponsible bank with openness behaviour? ✶✶ ✶✶✶✶✶ ✶✶✶✶ ✶✶✶ Restraints on input: capital to foreign banks adequacy (having enough Fit and proper capital is a minimum testing of bankers ✶ ✶ ✶✶✶ ✶ banking regulation), liability composition (types of assets Self-policing arrangements ✶ ✶✶✶ ✶✶✶✶ ✶✶✶ banks are allowed to hold) and tests for bank managers Restrictions on are generally considered the bankable activities ✶✶✶ ✶✶✶ ✶ ✶ least effective measures but The suitability of policy instruments are ranked from least suitable (*) to most suitable (*****) with the lowest verification under the four impediments (a–d) to building strong financial sector in small countries. costs. Critics say, however, Capital flows? Balance of payments management T he free movement of capital across national boundaries can ensure a more efficient allocation of savings, channelling resources to countries where they can be used to increase growth and welfare. Further arguments in favour of the free movement of capital relate to allocational efficiency and macroeconomic policy discipline, according to research by the University of Oxford, but may have to be set against the public good of financial stability: ● Access to foreign capital markets may enable investors to achieve a higher degree of portfolio diversification, allowing them to obtain higher risk-adjusted returns. ● Full convertibility for capital account transactions may complement the multilateral trading system, broadening the channels through which emerging market countries can obtain trade and investment finance. ● By subjecting governments to greater market discipline and penalising unsound monetary and fiscal policies, liberalisation may improve macroeconomic performance. Both theory and experience indicate the desirability of scheduling capital account liberalisation after appropriate domestic financial liberalisation. Significant foreign investment in domestic financial markets and foreign borrowing by domestic banks and corporations call for minimum levels of market efficiency and institutional and regulatory capacity to safeguard stability. The liquidity and volume effects of large foreign capital inflows on the domestic equity, bond and foreign exchange markets, can be highly destabilising. Following convention wisdom, major industrial countries and OECD members adopted the gradual and sequenced approach toward capital account liberalisation in the 1960s and early 1970s. Yet in recent decades, some emerging market economies adopted wrongly sequenced liberalisation programmes and undertook ‘big bang’ approaches instead, often under pressure from G7 governments. A shift in external market sentiment can cause a sudden (possibly excessive) reversal in the availability of external finance, destabilising the economy. Experience indicates that before liberalising capital account, fiscal balance and discipline, measures to attain a private sector savings-investment balance, and prudential regulation of bank and non-bank financial intermediaries should be in place. However, such measures have not proved sufficient to prevent the overheating of domestic financial markets, following capital inflows, and their subsequent market collapse. Until recently, international financial institutions were pressing for the immediate liberalisation of the capital account. But recent experience suggests that premature opening without macroeconomic pre-conditions, capital market depth, and sound financial regulation and supervision may be destabilising. This problem arises not only from distortions or imbalances in the host economy but also from the lack of breadth and depth in emerging capital markets. Unrestricted capital inflows lead to excessive appreciation of the domestic currency, current account deterioration, and increased instability S Mansoob Murshed Institute of Social Studies (ISS), PO Box 29776, 2502 LT The Hague, Netherlands Murshed@iss.nl See also Prudential regulation of banks in less developed countries, Finance and Development Research Programme Working Paper #19: IDPM, University of Manchester by S.M. Murshed and D. Subagjo, 2000 of the economy in general. What are the policy options? ● Active intervention in money markets to sterilise capital inflows is one possible response. Large-scale sterilisation policies could lead, however, to higher domestic short-term interest rates, which in turn would further stimulate short-term capital inflows. ● A free-floated exchange rate system would maintain free capital mobility. However, large exchange rate fluctuations in emerging economies may have significant economic impacts. ● If emerging market economies decide to stay with managed exchange rate regimes that target a competitive real exchange rate, they could establish mechanisms of managing short-term capital movements. ● The IMF still advocates the overall liberalisation of capital account transactions but also recognises the necessity of measures to influence the volume and composition of capital flows. Market-based instruments, such as taxes on short-term foreign borrowing, can thus be used to lengthen the maturity structure of external liabilities Valpy FitzGerald Finance and Trade Policy Research Centre, University of Oxford, 21 St. Giles, Oxford, UK edmund.fitzgerald@queen-elizabethhouse.oxford.ac.uk See also ‘Going with the flows? Capital account liberalisation and poverty’, Oxford: OXFAM and FTPRC by A. Cobham, 2001 ‘Rebuilding the international financial architecture’; Seoul Report Emerging Markets, Eminent Persons Group (2001) March 2002 Blurring the boundaries? Microfinance vs formal banking ID21 Institute of Development Studies, University of Sussex, Brighton BN1 9RE, UK T: +44 (0)1273 678787 F: +44 (0)1273 877335 Insights@ids.ac.uk www.id21.org Senior Editor: Louise Daniel Academic Advisor: Richard Batley Design: Robert Wheeler Electronic version: Alistair Scott and Caroline Lowes Printed in UK by Colorscope Ltd. ISSN 1460-4205 Insights is supported by DFID, as part of the ID21 programme. Views expressed in these pages do not necessarily reflect the official position of DFID, IDS or any other contributing institution. Copyright remains with the original authors. Unless rights are reserved in specific cases, however, any article may be copied or quoted without restriction, provided both source (Insights) and authorship are properly acknowledged. RE EY S icrofinance practitioners want to see special regulations allowing microfinance institutions to provide a range of financial services without attracting formal banking sector regulations – especially minimum capital requirements. If adopted, this approach will stretch the limited financial resources and technical capacity of many central banks in developing countries. It will blur the traditional boundaries of financial sector regulation. What options would best help regulators faced with a burgeoning microfinance sector? while others provide demand Research in Zambia by the University accounts facilities and a wide range of Manchester’s Institute for of other banking type services. Only Development Policy and Management, the latter need regulating. argues against the need for the central ● No capital requirements should be bank to impose an excessive level of stipulated for microfinance prudential regulations. The institutions at the lower end of the microfinance industry in Zambia is still regulation ladder for an interim relatively new and should be nurtured period of five years. There is within the parameter of an currently no justifiable basis upon accommodating legislative and which such capital requirements can regulatory structure. So too, regulatory be made. theory is in its infancy and lacks ● Prudential limits on the scale of sufficient guidelines for regulators microfinance operations, if required, faced with a growing microfinance should be based on the institutions sector. At this stage, a detailed deposits-to-loans ratio. The ratio regulatory structure may stifle rather measures the extent to which a than promote the growth of the sector. microfinance institution is able to Ideally for Zambia, a flexible mobilise deposits from its members graduated regulatory structure would and, where applicable, from the encourage microfinance institutions to general public. A higher ratio is increase their capital base voluntarily, associated with a greater element of allowing them to engage in the risk. permitted activities in the next The regulatory responsibility of the regulatory level. central bank should be restricted to Recommendations for designing and those institutions with potential developing effective regulatory systemic financial sector risk. Greater classifications for microfinance emphasis should be placed on institutions include: strengthening the self-regulatory ● Simple registration procedures are capacity of the Association of needed for all microfinance Microfinance Institutions. Selfinstitutions that take public deposits. regulation combined with targeted A self-regulating association should central bank involvement is more be responsible for non-prudential favourable at this early stage of the monitoring of these institutions. industry’s development ● Classifications should be based on an institution’s potential systemic risk to the financial sector and not size Samuel Munzele Maimbo of membership or area of operation. World Bank, 1818 High Street NW, Regulators cannot verify membership Washington, DC 20433, USA and geographical size in an T +1 (202) 472 3115 F +1 (202) 522 2433 smaimbo@worldbank.org economically efficient manner, especially in an industry where there See also is high group turnover and mobility. ‘The regulation and supervision of ● Regulators must carefully delineate microfinance institutions in Zambia’ by Samuel between seemingly homogenous Munzele Maimbo in ‘Financial System groups such as co-operatives. Some Regulation and Supervision in Zambia’ edited K. Mwenda, forthcoming, 2002 cooperatives do not accept deposits A SO good starting point to investigate issues around financial liberalisation, privatisation, banking restructuring, capital account regulation and microfinance is the World Bank’s Financial Sector network at www1.worldbank.org/finance and the search facility at www.worldbank.org/search.htm. A wealth of relevant reports are found via the search engines of the regional development banks: Inter-American Development Bank www.iadb.org; Asian Development Bank www.adb.org and African Development Bank www.afdb.org. Reports on bank privatisation processes in eastern Europe are provided by the European Bank for Reconstruction and Development www.ebrd.com. The work of the Basel Committee on Banking Supervision is on the site of its host, the Bank for International Settlements, at www.bis.org/bcbs/index.htm. Further news of Basel and other regulatory policy initiatives is provided by the Institute of International Finance (a global association of financial institutions) are at www.iif.com/ifr/index.quagga. Regulation is among the themes of the collection of proliberalisation articles on the Knowledge Navigator database of the multinational-supported World Economic Forum www.weforum.org. There are links to Africa’s online central banks and economic reports from around the continent at www.newafrica.com/economy/centralbanks.asp. Links to Asia’s central banks are at www.businessline.com/cebanks/asia/asia.htm. The Microfinance Gateway of the Consultative Group to Assist the Poorest nt1.ids.ac.uk/cgap/index.htm is a huge source of information on all aspects of managing and supervising microfinance institutions. The Asian Development Bank reviews the role of central banks in microfinance regulation at www.adb.org/Microfinance/default.asp. The DFIDfunded Finance and Development Research Programme website is at: www.devinit.org/findev/index. Among sites questioning, or campaigning against, the neo-liberal consensus are the Bretton Woods Project www.brettonwoodsproject. org/topic/financial, the Bangkok-based Focus on the Global South www.focusweb.org and the Malaysian-based Third World Network www.twnside.org.sg. Both the Public Services International Research Unit (PSIRU) www.psiru.org and its partner, Public Services International www.world-psi.org critically examine privatisation and deregulation initiatives. Public Eye on Davos www.publiceyeondavos.ch monitors the World Economic Forum. The finance section of OneWorld is at www.oneworld.net/themes/ topic/topic_122_1.shtml. E M ● SITES FO R Tim Morris Refugee Studies Centre, University of Oxford Fmr@qeh.ox.ac.uk Coming in issue 41 The perfect pension? Getting pensions right in an ageing world