NO. 19 BULLETIN MICROFINANCE REGULATIONS IN VIETNAM INTRODUCTION Developing sustainable microfinance has becoming a significant objective for economic development and been considered the extremely effective tool in the progress of eliminating hunger and reducing poverty when United Nations chose 2005 as “International Year of Micro-Credit”. In Vietnam, throughout about three decades, Microfinance sector has been asserting the importance in supporting the poor, low-income people to access financial, banking services in a convenient and consistent way. Therefore, developing sustainable microfinance is the important objective of Microfinance sector in the process of integration and development. With the goal towards sustainable microfinance sector, Government approved the Scheme of Developing organizational system of Microfinance to 2020 with the aim of “Establishing and developing organizational system of Microfinance safely, sustainably towards supporting the poor, low-income people, microenterprises to contribute to implement the undertakings of the Party and Government about ensuring social security and sustainable poverty reduction”. This is also a significant turning point in the evolution of developing microfinance activities in Vietnam as well as affirming the State's acknowledgment about the role and position of microfinance in the national financial system. It can be asserted that regulatory framework plays a very crucial role in the development of microfinance institutions in Vietnam. In facts, Microfinance Institutes are facing to lots of difficulties, challenges in the institutionalized process in order to developing activities in a sustainable way. The process of formalization of microfinance institutes is still slow since many different reasons, one of which is the issue relating to legal regulations for microfinance operation. That is also the concern of Microfinance institutes, Microfinance practitioners in the process of building strategic orientation in developing their own institutes. With the financial support from ADA – Luxembourg Organization, Cordaid – Netherlands Organization, and Citi Foundation - Citi Bank, and coming from the desire of many membership organizations of VMFWG, the content of this Bulletin 19 focused on the theme of "Microfinance Regulations in Vietnam". Editorial Board would like to sincerely thank the organizations and individuals who have contributed in building and accomplishing process of this Bulletin, to meet the demand of readers. We hope that the content of the Bulletin will help MFIs Vietnam attain more valuable experience to conditionally determine the direction for sustainable development in the future. EDITORIAL BOARD 2 - VIETNAM MICROFINANCE WORKING GROUP CONTENTS Microfinance in Cambodia: Regulatory and Supervisory Framework and 04 Development Philippine Microfinance 07 Regulations is necessary, but must 10 serve the sector Microfinance Regulations from the view of the State Bank of Vietnam 13 Establishment Licences and Microfinance Operations - Case study from the first institution to be licensed 15 Microfinance institutions formalization 18 procedure - why is it still so slow? Microcredit interest rates Benchmark of MFIs Vietnam in 2012 30 Cross-market Benchmarking and Analysis Vietnam Microfinance - Compared to East Asia and the Pacific 33 peers. News 36 Building a Sustainable Fundraising: the 41 Role of VMFWG 2013 VMFWG Member Registration 43 The Universal Standards for Social Performance Management 47 2013 Vietnam Citi - Microentrepreneurship Awards (CMA 2013) 50 20 Is the interest rate ceiling suitable for MFIs in Vietnam at present? 24 Difficulties in meeting the demand of the liquidity ratio 28 DONORS EDITORIAL BOARD 1. Nguyen Bich Vuong Microfinance and Development Centre (M&D) 2. Nguyen Thi Tuyet Mai Vietnam Microfinance Working Group (VMFWG) 3. Nguyen Thi Anh Phuong Vietnam Microfinance Working Group (VMFWG) 4. Phan Thi Lan Anh Vietnam Microfinance Working Group (VMFWG) 5. Le Thu Huong Vietnam Microfinance Working Group (VMFWG) NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 3 MICROFINANCE IN CAMBODIA: REGULATORY AND SUPERVISORY FRAMEWORK AND DEVELOPMENT KIM VADA 1 I. Background of Cambodia Microfinance Having featured since the early 1990s in projects of non-governmental organizations (NGOs) aimed at greater financial access for the rural population, with its main activities involving social rehabilitation, health care, and other humanitarian assistance for poor people, microfinance has been recognized as an important sector contributing to economic development and poverty reduction in Cambodia. Against the backdrop of peace and stability, in particular after 1998, microfinance has continued to grow rapidly. This requires an appropriate regulatory and supervisory framework. The number of microfinance institutions has increased from 15 in 2005 to 37 today. National Bank of Cambodia (NBC) has become the supervisory and regulatory authority of the sector based on two pieces of legislation to support the development and soundness of the sector. First, the Law on the Organization and Conduct of the NBC (LNBC) of 1996 allows the NBC to license, de-license, regulate, and supervise banks and financial institutions and other agencies such as auditors and liquidators including microfinance institutions. The NBC is empowered to issue regulations and other directives deemed necessary to execute its powers and responsibilities, and the law allows the NBC to exercise its supervisory and regulatory roles in order to maintain a sound and safe financial system. Second, the Law on Banking and Financial Institutions (LBFI) of 1999 provides a legal framework for microfinance to offer a broad range of financial services including rural credit, with appropriate mechanisms for licensing, regulation, and supervision. This legal and regulatory framework allows the NBC to develop and maintain sound and efficient microfinance. 1 The writer currently holds a position as a Director General of Banking Supervision of the National Bank of Cambodia (NBC) Disclaimer: This paper is being written solely to stimulate discussion and references only. The views expressed in the paper are those of the author and are not necessarily reflective of view of the National Bank of Cambodia. July 2013 4 - VIETNAM MICROFINANCE WORKING GROUP Description 2005 2006 2007 2008 2009 2010 2011 2012 June 2013 Licensed MFIs 15 16 17 18 20 25 30 34 37 Of which MDIs - - - - 1 6 7 7 7 Registered NGOs 23 24 25 27 26 27 28 33 33 Source: National Bank of Cambodia This table shows a doubling in the number of microfinance institutions to 37 in June 2013, with those allowed to take public deposits also increasing from 1 in 2009 to 7 in June 2013. In addition, there are also currently 33 registered NGOs who are operating rural credit in the country. II. Supervisory Roles of NBC The role of the NBC in microfinance development is envisaged as a direct and ongoing involvement with the microfinance operators. This role cannot be performed successfully without a favorable environment provided by the government through various forms of stable political environment, policy supports, social physical infrastructure development, and other support functions under the umbrella of government agencies and other international organizations. As the supervisory authority, NBC has conducted both off-site and on-site supervision. Off-site supervision consists essentially of the review and analysis of financial and activity reports submitted periodically by microfinance institutions. The main objectives of the off-site supervision are to ensure compliance with regulatory requirements, to monitor financial conditions and performance, and to detect irregular transactions. On-site supervision allows NBC to go on location and investigate beyond the data and information contained in off-site reports. By going on site, inspectors can perform a direct evaluation of an institution’s management and operational practices. On-site inspections are complementary to off-site supervision. The main objectives of the on-site supervision are to assess management quality, to confirm financial viability, to check loan portfolio quality, and to detect fraud and illegal activities. III. Regulatory Framework NBC has established a regulatory framework that reflects the level of risks undertaken by various categories of financial institutions in order to encourage imprudent risk-taking and “impose prudential standards to ensure that financial institutions conduct their activities in an appropriate manner”. This regulatory framework consists of a set of regulations and prudential norms dealing with minimum capital, minimum liquidity, leverage, loan portfolio quality, and other such requirements that represent the basic standards that sound financial institutions must satisfy to ensure their sustainability. Non-Registered NGOs: Under the regulatory authority of Ministry of Interior (MOI) and Ministry of Cooperation and Foreign Affairs (MoFA) Non-registered MFIs are mostly local and international NGOs. They are under the supervision of Ministry of Interior and Ministry of Foreign Affairs and International Cooperation in case they local and international NGOs, respectively. No criteria required by the NBC for these types of institutions. Microfinance Institutions: Under the regulatory authority of NBC Criteria for Registration (Regulation on Registration and Licensing of Microfinance Institutions) Registration with the NBC is compulsory for all NGOs, associations and other entities engaged in microfinance if they meet one of the following conditions: - For those engaged in credit, their loan portfolio outstanding is equal to or greater than KHR 100 million; or - For those engaged in savings mobiliza- NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 5 tion, the savings mobilized from the general public amount to KHR 1 million or more OR the number of their depositors is 100 or more. Criteria for Licensing of MFIs (Regulation on Registration and Licensing of Microfinance Institutions) IV. Lessons Learnt of Microfinance Development in Cambodia The rapid development of sound, safe, and efficient microfinance in Cambodia has been largely explained by the following measures. Licensing is compulsory for all MFIs if they meet one of the following conditions: 1- Define the clear definition of “Microfinance” and determine its mission and vision. - For those engaged in credit, their loan portfolio outstanding is equal to or greater than KHR 1,000 million OR they have 1,000 borrowers or more; or 2- Create sound macroeconomic policy that provides price stability, which means inflation should be at an appropriate level. - For those engaged in savings mobilization, the savings mobilized from the general public amount to KHR 100 million or more OR the number of their depositors is 1,000 or more. 3- Minimize market distortions relating to the interest rate on microfinance assets and loans and encourage healthy competition. The interest rate dropped dramatically from 36% p.a to around 18%. Criteria for Licensing of MDIs (Regulation on Microfinance Deposit Taking Institutions) 4- The authorities have encouraged the sector by using other means such as building infrastructure, roads, and bridges to the very remote areas so that microfinance can deliver their services to people in those areas and also reduce their operating costs, i.e., transportation cost for their credit officers. MDIs stand for Microfinance Deposit Taking Institutions. This type of institution, in addition to its core lending activities, is allowed to collect deposits from the public. Any institutions not having this license are not allowed to take deposits from the public. An MFI requesting a license to collect deposits from the public shall have the following qualifications: - Hold a MFI’s license from the NBC for at least three years; - Have a good financial condition and sound management as judged by the internal rating of the NBC, at a safe level, for at least two years before submitting the application; - Have a minimum paid-up capital equal to KHR 10,000 million; - Have an effective Management Information System (MIS); - Implement NBC’s uniform chart of accounts; and - Have sustainable profitability of at least two consecutive years in primary operations. 6 - VIETNAM MICROFINANCE WORKING GROUP 5- Behind the backdrop of appropriate supervisory and regulatory framework, a small sound and safe microfinance institutions would become a big sound and safe microfinance institutions. 6- Creating a government wholesale fund mechanism to support retail microfinance institutions, which can be the best source of funds for those microfinance institutions that are solely operated on funds rather than deposits from the public. 7- Keep updating the regulatory and supervisory framework in line with the development of the market. PHILIPPINE MICROFINANCE THERESE MARIE RICO THE MICROFINANCE COUNCIL OF THE PHILIPPINES There are three different types of institutions providing microfinance services in the country. These are the thrift and rural banks, the cooperatives with savings and credit services, and the non-government organizations with microfinance services. Banks engaged in microfinance operations remain under the supervision of the Bangko Sentralng Pilipinas (BSP) and cooperatives fall under the regulatory ambit of the Cooperative Development Authority (CDA), while microfinance NGOs, as non-deposit taking institutions, are not subject to any prudential regulation. Microfinance NGOs, nonetheless, are required to register with and disclose to the Securities and Exchange Commission (SEC) that they are engaged in microfinance and related services. Recent developments in the sector include the following. venting the uninformed use of credit to the detriment of the national economy. The law covers any creditor, which is defined as any person or institution engaged in the business of extending credit that requires, as an incident to the extension of credit, the payment of a finance charge. The circular also established a pricing formula that must be followed by all credit-granting institutions. The circular, which took effect in August 2012, also included amendments on information to be disclosed, especially for small business/retail/consumer credit. These are the total amount to be financed, finance charges expressed in terms of pesos and centavos, net proceeds of the loan, and the percentage that the finance charge bears to the total amount to be financed. Pricing transparency is monitored and enforced by the BSP, but this is limited to com- • In December 2011, BSP issued Circular No. 744 that allows banks to offer the option of “Microfinance Plus” loans of up to PHP 300,000 (US$7,000). Traditionally, the central bank defined microfinance loans as those below PHP 150,000 (US$3,500). • New rules issued by the BSP and effective July 1, 2012, outlaw the use of flat interest rate calculation methods for regulated institutions. Unregulated NGO-MFIs and cooperatives are encouraged to follow suit. Pricing Transparency A central bank circular, BSP Circular 730, encourages MFIs to enhance loan pricing transparency and improve creditor disclosure practices by updating the Truth in Lending Act. The declared policy behind the regulation is to protect people from lack of awareness of the true cost of credit by assuring full disclosure of such cost, with a view to pre- NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 7 mercial and rural banks only as BSP does not regulate nor supervise other MFIs like cooperatives and NGOs. Thus, there is no examination of compliance with the rule for non-banks. Over-indebtedness The sector has actively responded to the challenge of multiple borrowing that could likely translate into over-indebtedness, rising PAR, and high client turnover. MFIs that are keen on exchanging lists with other institutions to avoid credit pollution are met with uncooperative MFIs owing to the latter’s negative experience of client poaching. There are moves at present to combine a number of approaches including intensifying financial education, improving product suitability, outreach mapping, and studies to understand multiple borrowing in order to discourage multiple indebtedness, which can lead to high PAR of MFIs and over-indebtedness of clients. In 2012, the Asian Institute of Management (AIM), Oikocredit, Mindanao Microfinance Council (MMC), and the Microfinance Council of the Philippines (MCPI) released a series of notes on multiple borrowing in the Philippines. One of the notes is a report that aimed to estimate the incidence and correlation of multiple borrowing by using consolidated branch client data obtained from several MFI partner organizations operating in the “Commonwealth” neighbourhood 2 of Quezon City. The main results suggest that, on average, 14 percent of active MFI clients borrow from more than one MFI. Because loan sizes are generally the same, multiple borrowers account for a similar proportion of all outstanding MFI loans, though there are important distinctions across various types of loans and substantial variations in the prevalence of multiple borrowing across MFI. There are generally no systematic differences in the demographic characteristics between single borrowers and multiple borrowers, and there is no evidence to date to suggest that multiple borrowing is associated with repayment difficulties and delinquency 1. Credit Bureaus The Credit Information Systems Act (CISA), passed in 2008 by the Congress, requires the establishment of a central credit registry in the country. The implementation of the CISA is expected to increase access to credit by micro, small, and medium enterprises as well as address problems of multiple borrowings that could lead to delinquencies. On a larger scale, the sharing and dissemination of credit information will lead to a sound, healthy, and vibrant credit market. To date, the implementing rules and regulations of the CISA have already been approved and some members of the Board have already been appointed. The implementation and operations of the Credit Registry are, however, hampered by the lack of budgetary appropriations from the national government for the initial capitalization requirement of the Bureau. Early this year, the seven biggest microfinance institutions in the country led the formation of the credit bureau that aims to make microfinance providers more comfortable with extending loans to micro-entrepreneurs through the “Microfinance Data Sharing System (MiDAS)” 2 that would put credit information on micro-borrowers in a common database that the lenders would have common access to. Proponents of the system said that, with the credit bureau, micro-entrepreneurs of good credit standing or those that have not been heavily indebted would have better chances of securing loans from the participating creditors. MiDAS hopes to address the problem of difficulty in access to loans by perceivably credit-risky micro-borrowers. Data Security Law Philippine banks are governed by the country’s law on Secrecy of Bank deposits, whereby all deposits of whatever nature with banks or banking institutions, including investments in bonds issued by the Government of the Philippines, are considered absolutely confidential. These deposits may not be examined, inquired, or looked into by any person, government official, bureau, or office except upon written permission of the depositor, in cases of impeachment, upon order of 1 The authors of the report note that results of the study should be treated as preliminary and interpreted with caution. Because the analysis is subject to errors of inclusion and exclusion, and because the data are a cross-sectional snapshot that does not capture adequately changes over time, the correlations should be interpreted as mere statistical association. No causal inferences are made. In addition, because this is an area study, the results should not be interpreted as nationally representative. 2 http://business.inquirer.net/39021/credit-bureau-for-microfinance-formed 8 - VIETNAM MICROFINANCE WORKING GROUP a competent court in cases of bribery or dereliction of duty of public officials, or in cases where the money deposited or invested is the subject matter of the litigation 3 . Another law, The Data Privacy Act of 2012 (Republic Act No. 10173), supports the former but places more emphasis on the role of information and communications technology providers in ensuring that personal information in the information and communications systems of the government and the private sector are secured and protected. Mobile Banking With the advancement in technology and the popularity of mobile phones, mobile banking is recognized to have a huge potential to provide access to the unbanked, particularly in remote locations, and to significantly reduce both cost and external risks. Findings from the Philippines show that one half of the active mobile money users are unbanked. Of these, 26 percent are poor, living on less than US$5 per day (the poverty line in the Philippines) and that 1 in 10 unbanked users saves an average of US$31 (one quarter of their family savings) in a mobile wallet. The SIMM aims to: • Encourage individuals to open new savings accounts via mobile banking; • Encourage institutions to establish additional cash-in/cash-out merchant partners by focusing on rural areas; • Encourage institutions to increase payroll implementation and adoption to small, medium, and large businesses and one Philippine government agency or local government unit; • Increase the volume of mobile money transactions; and • Share knowledge on mobile banking through research papers, conferences, and learning venues. Recent regulations and circulars issued by the BSP have also enabled a regulatory environment that promotes greater financial inclusion, or the delivery of financial services to low income groups at affordable costs. Among these important policies is the easing of bank branching requirements and the expansion of the role of micro-banking offices.6 Prior to the Microenterprise Access to Banking Services (MABS)4 Project, the industry already saw mobile phone banking as a technological solution to extend low cost banking services to existing clients and unbanked individuals, especially in rural areas.5 Another mobile banking-related project is the Scaling Innovations in Mobile Money or SIMM - a two-year undertaking that aims to train more people through financial education and literacy on the uses of mobile money and mobile money services for improved household financial management. 3 Republic Act No.1405, as amended, Law on Secrecy of Bank Deposits 4 The USAID-funded Microenterprise Access to Banking Services (MABS) program is an initiative designed to accelerate national economic transformation by encouraging the Philippine rural banking industry to significantly expand access to microfinance services. 5 Philippine Industry Report, 2010 6 http://www.manilatimes.net/index.php/business/top-business-news/33417-simm-project-provides-clear-receptionto-mobile-banking NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 9 REGULATIONS IS NECESSARY, BUT MUST SERVE THE SECTOR JOERG TEUMER REPRESENTATIVE OF GERMAN SAVINGS BANKS FOUNDATION FOR INTERNATIONAL COOPERATION TYM, for which I am working as a consultant since many years, is a good example for the impact of regulation and supervision. Decree No. 28 was issued in 2005. By the end of that year, long before Decree No. 165 came out and amended Decree No. 28, the Vietnam Women’s Union made the courageous decision that TYM should upgrade to become a registered “Small-scale financial Institution”. In August 2010, after 2 years of waiting and repeatedly having to change the application dossier, TYM was awarded the Licence. It took another year to complete all registration documents and become the first official MFI of Vietnam. Meanwhile the revised Law on Credit Institutions (Banking Law) was adopted, including "Microfinance" - how it was now called – as a part of the official banking system of the country. A great step forward, that is what many 10 - VIETNAM MICROFINANCE WORKING GROUP thought. But in practice it meant that all implementation rules for Decree No. 28 and No. 165 (which were not even complete yet) became invalid. New rules are now being drafted. Until they are finished, nobody really knows which rules to follow. In case of doubt, the much stricter rules for commercial banks are applied. Amidst this legal uncertainty, the State Bank of Vietnam carried out a full scale inspection if TYM's Head Office and its 17 Branches, where neither we nor the SBV knew exactly how to handle many issues. Given this far from perfect situation, I fully sympathize with those microfinance projects, who are not in a hurry to submit or to update and complete their Licence application. At TYM during the last 3 years there was not just one day where we thought it better to give back our Li- cence to SBV and to return to our comfortable status as a special project or incomegenerating enterprise (don vi su nghiep co thu). After all TYM belongs to the mighty Vietnam Women's Union, who could protect us and, in case of need, could get special permits by the Prime Minister. Still we firmly believe that working with the Licence and under the supervision of SBV is the only forward not only for TYM, but in the end also for many other microfinance projects. If nobody was licensed, how could SBV and the MFIs themselves find out, if the rules and regulations are approriate, and what and how should be changed? I will now give my personal thoughts on some of the "burning" issues in regulation in Vietnam: 1. Who shall be regulated? In my view all microfinance projects which collect savings from the pubic and all MFIs above a certain size. And the rules should be the same for all - Government owned bank, cooperatives or MFIs. 2. Why do we need regulation? The main reason is to protect clients, especially poor and low income people, from losing their hard earned savings, but also to prevent bad practices in lending. The main tools for achieving this are transparent and regular reporting and certain minimum standards for governance and the key persons in a MFI. Now, all MF projects I know in Vietnam, have a high social orientation, the reputation of their owners is beyond doubt. But as the MFIs and their clients grow, as services become more diverse, and more money is at stake, there must be standards, which are supervised. 3. What should regulation do and what not? It should create incentives, not obstacles for the sector to grow. If regulations are too strict, no one will register. One example: Opening new branches and outlets should be made as easy as possible. Microfinance reaches out to large numbers of people who are not served by banks. While the impact on people can be huge, the amounts at stake are negligible - all microfinance of Vietnam (including VBSP and PCF) accounts for just 2% of all banking assets. For the same reason, MFIs in Vietnam, like in many other countries, should be totally free from taxes, as long as they have non-profit status, i.e. re-invest their profits to improve and enlarge their services for the people. The potential tax income for the state is minimal, but the current tax policy discourages so many MFIs from getting licensed. Another issue is ownership of MFIs. Why must it be limited to 5 shareholders? Maybe a MFI wants to make its clients or staff co-owners, like in many other countries. Why can’t one shareholder own the majority openly, and not in disguise like in may jointstock banks? Why can’ t the Women’s Union own several MFIs? Regulation should also encourage the provision of more, better and innovative services. Many poor and low income people have the need for fast and secure money transfers. Others need insurance. Small entrepreneurs need to buy equipment at favourable conditions. So instead of restricting MFIs, they should be allowed to open accounts for their clients, provide mobile banking, or to set up subsidiaries for microinsurance and microleasing. One point, which in my view, should not be regulated, is the provision of information on all borrowers to a centralized database. A Credit Bureau makes sense in a sophisticated market with high risks and default rates. In Vietnam, there is multiple borrowing, but no problem of overindebtness. MFIs have various ways to verify the existing loans of their clients and whether they can afford to repay another loan, as is proven by the high repayment rates and various impact assessments. A credit bureau with its need to acquire or change software and assigning staff for reporting would just be an additional burden, especially for smaller MFIs. 4. How to improve supervision? The experience of TYM shows that the level of understanding of microfinance by the staff and inspectors of SBV is still very limited, especially at the local level. It is even more so for the local administrations, who must approve the opening of new outlets in their area. Most of them consider MFIs just another bank and think they must apply the same standards, for example using armoured cars for transport NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 11 of cash or having a sophisticated reporting software. Improving the capacity of these people takes time and money. If there were 10-20 MFIs instead of just 2, SBV would perhaps need to hire more staff. Supervision is also time consuming and costly for the MFIs - they must explain a lot, prepare reports, copy documents. SBV should consider lowering the scope and frequency of reports and on-site supervision missions. Another idea is listed in Point 6. 5. What to do with smaller microfinance projects? MFIs below a certain size and offering only loans and compulsory savings should not be obliged to register. Still, they should follow a certain set of standards and be subject to a minimum of supervision. There was the idea of the Microfinance Working Group taking on the task of collecting information and at least randomly checking the various projects. However this would require building the relevant capacity of the VMFWG and to secure ongoing funding for this work. Also it could lead to a conflct of interest, if members are controlled by an organisation which is formed by themselves. Another, currently very popular option is to set up Social Funds according to Decree 30. However, this Decree 12 - VIETNAM MICROFINANCE WORKING GROUP was not really meant for microfinance, and there is little to none supervision of standards. 6. Could a Wholesale Fund be a solution for two problems? All MFIs in Vietnam, licensed or not, are in need of funding. Only a few have the right and capacity to raise savings from the public and loans from local and international financial institutions. Smaller and unlicensed MFIs could borrow from a professionally run Wholesale Fund, supervised by SBV. Such a Fund would need to conduct a due diligence analysis of its borrowers (the MFIs) and later monitor, how the MFIs have used the money and if they will be able to repay the loan. In other words, the Wholesale Fund will "supervise" the MFIs. There are already 2 such funds in Vietnam. One is the Microlending Fund (MLF) of the World Bank, managed by BIDV. It is only open for licensed MFIs, its conditions (e.g. floating interest rates) and reporting requirements are not really suitable for MFIs. The other is the Credit Support Fund of the Women's Union, which already lends to several (licensed and unlicensed) microfinance projects. It does so on the basis of the borrower's (MFI's) analysis, at rates close to the market. The interest income of the Fund is used to finance the staff and operations, i.e. it covers the "cost of supervision". Any surplus is used to enlarge the Fund. Perhaps this Fund could serve as the basis or model for a larger Wholesale Fund. Funding could initially come from ADB's Microfinance Sector Loan, later other sources could be added. MICROFINANCE REGULATIONS FROM THE VIEW OF THE STATE BANK OF VIETNAM HOANG QUOC MANH: DEPUTY DIRECTOR OF LICENSING DEPARTMENT BANKING INSPECTION AND SUPERVISION AGENCY STATE BANK OF VIETNAM This interview is based on the demand of sharing information of regulations and policies related to Microfinance activities in Vietnam as well as orientating the development of Microfinance Institutions in formalization and professionalization in Vietnam. The Vietnam Microfinance Working Group (VVMFWG) had a close interview with Mr. Hoang Quoc Manh – Deputy Director of Licensing Department – Banking Inspection and Supervision Agency - State Bank of Vietnam about some microfinance regulations in Vietnam. Question: Will the State Bank of Vietnam replace or modify Decrees No.28/2005/NĐCP and No.165/2007/NĐ-CP regulated the structure and activities of small scale Microfinance institutions in Vietnam? What are the functions of foreign institutions in capital contribution? Does the State Bank allow microfinance institutions to have legal status as 100 percent foreign owned companies? Answer: Implementing the Law on Credit Institutions 2010, the SBV will have guidance on the process of establishing and licensing MFIs in the near future. Basically, this Circular is based on Decrees No. 28 and No.165. In accordance with the provisions of the laws as well as the development orientation of the microfinance sector, microfinance institutions will probably be required to establish solely in the form of limited liability companies. Moreover, according to the development scheme of microfinance to 2020, the State Bank will continue researching the most effective structure for microfinance shareholdings and the involvement of many sectors, including perhaps in- NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 13 ternational companies. However, in terms of the social goals of microfinance, there should be participation of social organizations. Thus, there is no possibility of having a 100 percent foreign owned microfinance institution, only foreign participation to a certain level. Question: Could an international organization or a commercial bank establish a microfinance institution as its subsidiary company to implement microfinance? Why/Why not? Answer: Under the current laws, this is impossible. In addition, pursuant to the microfinance establishment draft, there must be a social-political organization. Thus, a commercial bank can contribute capital to a limited liability company with more than two members. Question: It is a fact that formal MFIs are facing more difficulties than informal MFIs in implementing current laws and rules such as taxes, interest rates, and liquidity. Therefore, what policies and policy improvements does the State Bank of Vietnam have to encourage the transformation of informal MFIs into formal ones? Answer: Transforming into a formal microfinance institution is a relatively big change in quality – it requires comprehensive preparation of knowledge, quality of operations, and other conditions. Thus, in order to support the formalization of microfinance institutions, the Asian Development Bank funded a programme to support MFIs’ transformation. All of the market mechanisms have been operating under a certain legal framework and under the supervision of the State authorities. However, due to lack of proper understanding, a difficult tax regime, and liquidity regulations (because MFIs mobilize deposits and make loans), it is understandable that MFIs face many difficulties in their operations. In recognition of this, the government and the State Bank of Vietnam support the dissemi- 14 - VIETNAM MICROFINANCE WORKING GROUP nation of legal awareness, which are regulated microfinance activities, and training activities, as well as supporting to connect low-interest loans, create favorable conditions for the development of microfinance. Question: MFIs are licensed to set up and aim to reach clients who are poor and near-poor households. In order to help a growing number of poor people access loans for productive development, MFIs need more capital. However, those organizations are currently under a shortage of capital and face difficulties in borrowing. Thus, what are the State Bank’s mechanisms to solve these problems and help microfinance institutions have sufficient capital for operation? Answer: In the case of an informal MFI, the legal status is incomplete, and it cannot independently borrow money. If this organization wants to expand its operations, it must be formalized and operate within the framework of the law. Then, borrowing will be more favorable. Thus, MFIs have to convert themselves in order to access capital. If MFIs want to access loans, they must have mechanisms to use capital efficiently, with well qualified human resources and modern technologies. In summary, in conjunction with MFIs, the State Bank will support and facilitate the proper legal framework pursuant to the law. The State Bank encourages formalization of MFIs, which brings them many benefits. Interviewer Nguyen Thi Anh Phuong Project Officer Vietnam Microfinance Working Group ESTABLISHMENT LICENCES AND MICROFINANCE OPERATIONS - CASE STUDY FROM THE FIRST INSTITUTION TO BE LICENSED TRAN THI NGOC HA TYM In August 2010, after two years of working to meet licencing requirements and working as a small scale financial institution in accordance with the government’s Resolution No. 28/165, the sole member limited liability institution called Tinh Thuong (previously Tinh Thuong Fund – Vietnam Women’s Union and abbreviated as TYM) has become the first licensed small scale organization working in Vietnam. As the first organization to apply for a licence, TYM not only had advantages, but it also encountered many difficulties. The organization faced opportunities and challenges that no microfinance institution or program had ever experienced before. 1. Advantages, difficulties, opportunities, and challenges Advantages: Firstly, TYM was supported promptly and received detailed guidance from the State Bank of Vietnam. Being the first time preparing such documentation, TYM was overhelmed by requests to provide a lot of paperwork, files, and data for being licensed. However, thanks to Department 6 of the State Bank of Vietnam, TYM could complete the application step by step. A second aspect is the professionalization of TYM operations. Pursuant to the regulations of the State Bank, TYM has gradually improved its policies and made its operations safer and more methodical, such as the process for assigning the staff performing the cashier function at branches and transaction offices. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 15 Thirdly, the licence has brought benefits to TYM, particularly in raising capital. On one hand, TYM can borrow capital from international organizations and is guaranteed the repayment of foreign currencies after registering loans to the State Bank. On the other hand, TYM has the right to mobilize voluntary savings from the public and members without limitation. Owing to these advantages, along with designing flexible products, TYM has raised the rate on savings balances per portfolio to approximately 55%, an increase of nearly 30% compared with prior to the authorization. Difficulties Besides these advantages, TYM was also faced with many difficulties. It took TYM nearly two years to complete the licensing documents required by the State Bank. In order to meet the information and data requirements, both the State Bank and TYM had to study, research, and monitor how to fit the regulation and the reality together perfectly. During the licensing procedure, TYM encountered other matters. These were the series of specified texts, namely the regulations on the financial regime, the regime of corporate income tax, etc., were not issued in a timely manner by the State Bank and the Ministry of Finance for small scale financial institutions. Recently, guidelines were released for implementation of the Law on Credit Institutions 2010, even though this came into effect in more than three years ago. Moreover, several regulations have been developed specifically for small scale finance (in accordance with the Law on Credit Institutions 2010 known as microfinance), and they are not consistent with the typical operations of microfinance. For example, Circular No. 07/2009/TT-NHNN dated 17/4/2009 stipulates the prudential limits on the operation of financial institutions and regulates the percentage of liquidity at 20%. The numerator of this ratio includes cash, bank deposits in the State (but excludes required reserve deposits) and deposits in credit institutions, and government bonds (bonds are guaranteed by the government). The denominator includes compulsory savings and voluntary savings. This provision is no different from the regulation for commercial banks. Yet, microfinance uses compulsory savings to secure the borrowed capital and to actively plan on paying the withdrawals of these savings. In the current context of current microfinance, when funds raised from domestic and 16 - VIETNAM MICROFINANCE WORKING GROUP foreign credit institutions are still limited and compulsory savings account for a large proportion of the total money-saving mobilization, these regulations reduce the possibility of increasing the lending capital of microfinance institutions and their opportunities to gain access to capital for microfinance by individuals and low income households. Other examples of irregular regulations include Circular No. 09/TT-NHNN dated 03/25/2013, which stipulates the short-term interest rates for loans in Vietnam dong for credit institutions and foreign bank branches provided customers in some sectors, while the short-term interest rate of microfinance must not exceed 12% per year. Or regulations on facilities (warehouses, tanks, cash, transport cars, etc.) of the transaction offices and branches of microfinance, which have to be the same as commercial banks, whereas the amount of cash transacted and stored at microfinance branches is much lower. In addition, TYM encountered some difficulties during its practical operational process. Firstly, in 2011, the halt in licensing transaction offices of microfinance led to the situation where a series of old TYM branches, which were unlicensed to convert operations into transaction offices, had to merge their operations with the licensed branches. This increased the cost of operating and reduced the ability ofTYM to expand to new districts. After 2011, the State Bank had no other notices on the continuation or suspension of licensing transaction offices of microfinance, which has caused many difficulties for TYM in the development plans of the organization in recent years. Opportunities Firstly, a chance for TYM to innovate and professionalize its operations under the monitoring and guildance of the State Bank. Secondly, TYM has an opportunity to diversify the sources of mobilized capital – not only the small compulsory savings and voluntary savings from members, but also the large savings deposits from members, the public and loans from domestic and foreign credit institutions. Thirdly, TYM can expand collaborative relationships with other organizations, where the licence is regarded as TYM’s passport. Presently, TYM has had collaborative business relationships with nearly 20 organizations over the world. Last but not least, TYM has the permission to establish a financial unit of TYM. Taking advantage of this opportunity, TYM is taking its very first step to promote its business development services (BDS) to support the members as a precursor to the establishment of TYM BDS centers in the near future. Challenges In the case of TYM, the first challenge is to provide training for the management staff and employees to switch from the old type of operations to the professional banking finance operations. This requires a lot of effort from both organizations and each individual, as well as time and money for the training. Another challenge is to build the image of TYM in the mind of the public, including upgrading facilities and enhancing communication campaigns. These requirements are also problems for TYM leaders, when they have to address another difficult problem: “Should we invest in the business image or continue to expand?” 2. Lessons learned: From our own experiences, these lessons will help other microfinance institutions in the decision-making, preparation, and commitment in the licensing process and conversion. - Before making the licensing decision, it is of great importance for organizations to be aware of what they have got. The changes will take place to determine whether or not to be licensed or the right time and the steps for preparation, licensing implementation, and how to convert. - During the licensing process, instituations ought to have close contact with Department 6 and the State Bank to obtain guidance and timely support. - After being licensed, institutions must continue to switch gradually and safely by piloting the principal changes before deploying them on a large scale. 3. Recommendations: For smooth licensing, transition, and benefits to the microfinance industry and the beneficiaries of the industry, TYM proposes a number of recommendations: - Microfinance institutions /programs: contribute a voice to the power of institutions /microfinance programs in policy advocacy; - The Vietnam Microfinance Working Group: enhance the sharing of licensing experiences between organizations, playing an intermediary role between organizations and stakeholders, closely follow the operational situations of organizations in order to advocate for appropriate policy; and - The government and related authorities: promote the implementation of development strategies for the microfinance industry to the year of 2020, closely monitoring microfinance activities and facilitating the development of microfinance through appropriate policy management. For the professionalization and formalization of microfinance activities, licensing microfinance institutions is essential. Although each organization needs to carefully consider its current situation, preparing roadmaps for licensing appropriate to the condition and the ability of the institution. The most important thing is to transition successfully. In order to do so, the licensed organization will need much care and support from the Vietnam Microfinance Working Group and the authorities through practical activities and appropriate policy promoting the development of the microfinance industry. TYM, as the first organization licensed in this field, is always willing to share experiences and propose possible solutions based on practical activities at TYM. - Sharing experiences with organizations that have been licensed and the Vietnam Microfinance Working Group to study practical experiences, as well as sustain advocacy to get the appropriate policies and bring benefits to the official microfinance operations. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 17 MICROFINANCE INSTITUTIONS FORMALIZATION PROCEDURE - WHY IS IT STILL SO SLOW? NGO THI THANH VAN INDEPENDENT CONSULTANT FOR MICROFINANCE Although the Government established the policy on formalization of MFIs nine years ago, so far formal MFIs are relatively few. Only two out of more than 300 large and small organizations across the country are licensed by the State Bank of Vietnam. Was the policy established too early, has it not been suitable with the development trend of the industry or are there other reasons? Government Decree No. 28 was issued after a long process of mobilization of microfinance practitioners with the support of international non-government organizations in 2005 – known as the "International Year of Micro-Credit." At that time, microfinance proved its important role in helping poor and low-income people access financial services conveniently and reasonably. The Government and donors also recognized microfinance as an effective tool in the struggle 18 - VIETNAM MICROFINANCE WORKING GROUP to reduce poverty and hunger as well as to help people in rural, mountainous areas to develop their economic situation sustainably. Moreover, worldwide microfinance is developing quickly and drawing attention from many investors, thus microfinance institutions are required to keep up and comply with international standards in order to attract more investors. There is no doubt that the formalization policy for MFIs was established at the right time and reasonably in accordance with the development trend of the microfinance industry in Vietnam and around the world. Why is the formalization process happening so slowly in Vietnam and why are MFIs not really keen on the transition? In Vietnam, microfinance operations are often carried out and managed by the Women's Union (VWU), thus formalizing is a transition which includes: i) Transforming from a microfinance program managed by the VWU and implemented by a simple management system mostly self-designed and not complying with any standards; ii) The next stage is to recruit specialized staff who have specific qualifications to perform and apply the professional management system to comply with the global standards (e.g. WOOCU, CGAP etc.); iii) Then the VWU – the owner of the microfinance program – submits applications for establishing a Social Fund which becomes an independent organization, with its own seal, charter of operations and separate organizational system; iv) The last step is to become a formal financial institution operating under the authority and supervision of the State Bank of Vietnam. Currently, most MFIs are in the process of moving from the first stage to the second stage. Although organizations find out their limitations in the management and operations of MFIs, they still have not found the motivation to change, even when receiving technical and financial support from donors. There are many different reasons. Firstly, the VWU have not foreseen the future of MFIs under the VWU as a whole. How will they manage their institutions as they grow and expand? The relationship between "gain" and "loss" here is not clear and has not been researched, particularly at provincial and district levels. The VWU is concerned about finding the answers for this, which is the core of the "transition motivation". Secondly, the implementation of policies at an intermediate level (provincial and district) also known as "environment policy implementation" is still weak. Meanwhile, this level plays a critical role in the transition of change and as the decision-making level for switching or not switching. vantage and the role of the VWU. Following the glorious times (between 2005 and 2009), microfinance has gradually subsided and abdicated for the more pressing concerns of climate change and natural disaster risk mitigation. Similarly, donors are directing there funding elsewhere, as the microfinance industry is not a primary concern. At the same time, the impact of the global economic crisis has also reduced the likelihood of funding/support from many large donors. Therefore, prioritizing investment is inevitable. There are not many studies proving the impact and influence of microfinance on climate change, disaster risk reduction, or other development sectors. In order to quicken the process of formalization of MFIs, the following issues should be considered; besides the technical and financial support for the conversion process: - Strengthening the implementation of policies for intermediate levels to create a favorable environment for the implementation of policies at the macro level. - Strengthening the advocacy on policy and implementation guidelines to ensure that all policies are well understood and implemented smoothly from a macro level - intermediate - micro. - Clearly distinguish the role of the VWU in the implementation of policies in the intermediate and micro levels, and study the "gain" and "loss" of switching to create transitional motivation for the VWU. - Carry out research on the role of microfinance in climate change and natural disaster risk mitigation, as well as the integration of microfinance into other development areas to help microfinance develop its role fully, and contribute more actively to the general development of Vietnam. Thirdly, the role of the VWU in the implementation of policies is not clear. In terms of the State, the VWU is under the local government units and the implementation of policies at an intermediate level. In term of the microfinance industry, the VWU is the owner of the MFIs and the one implementing the policies at the micro level. This fact has inadvertently created a conflict between the ad- NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 19 MICROCREDIT INTEREST RATES ERIC DUFLOS AND TAM LE THANH On 16 May 2013, several governments, international and private actors involved in microfinance in Vietnam debated the issue of microfinance interest rates at a workshop organized by the Vietnam Microfinance Working Group, TYM and the IFC. The emerging microfinance industry is indeed facing a challenging interest rate cap of 10 percent on short term credit 1 and a minimum shortterm deposit rate of 7.5 percent 2. This article first highlights why microfinance 3 is important for the poor. It then explains why MFIs need to charge sustainable interest rates, and why these rates are higher than bank rates. It then explains negative consequences of interest rate caps, highlights specific facts about the Vietnam situation, and concludes on possible next steps. Microfinance includes the provision of a diversity of financial services such as credit, savings, transfers and insurance to low income households and micro-enterprises, but we focus here on microcredit interest rates. 1 Circular No. 16/2013/TT-NHNN dated June 27, 2013 of the State Bank of Vietnam promulgating the maximum interest rate for VND short-term loans of the credit institutions and foreign bank’s branches for the customers to satisfy funds demand serving some economic areas and sectors. In Article 1 “The maximum short-term loaning interest rate in VND is 9% per annum; people's credit funds and microfinance institutions may impose the maximum interest rate of 10% per annum on short-term loans in VND” 2 Circular No. 15/2013/TT-NHNN dated June 27, 2013 of the State Bank of Vietnam promulgating the maximum interest rate of VND deposit of organization and individuals at credit institutions and foreign bank’s branches. 3 Microfinance is defined here as the provision of a broad range of financial services such as credit, savings, transfers and insurance to the un-banked population. 20 - VIETNAM MICROFINANCE WORKING GROUP Why is microfinance important for poor people? A large majority of working adults in Asia have no access to formal financial services. Among the poorest 20 percent of the population in East Asia and the Pacific, only 33 percent have formal access to finance (Source Findex, World Bank). In Vietnam 79 percent of adults still do not have access to formal financial services according to Findex. Most unbanked people need to save and borrow from multiple sources to manage their financial lives. Many poor people end up borrowing from money lenders at interest rates often higher than 100 percent per annum. To solve this unfair situation, for the past 30 years, thousands of microfinance institutions (MFIs) have emerged globally. There are many kinds of MFIs such as NGOs, specialized banks, cooperatives, finance companies etc. They provide credit, savings, and sometimes other financial services that the poor highly value. With microfinance services, poor people can save for difficult days or for educating their children and borrow for their micro-enterprise or in case of emergency. Why do MFIs need to charge sustainable interest rates? Currently MFIs serve dozens of millions of formally unbanked people in Asia. Most of these MFIs are private or semi-private organizations. Since they are not charities, they need to recover their costs. This means that they must charge market interest rates to their clients to operate and expand. As illustrated below, the main component of microcredit interest rate is the operation costs (staff costs, transport etc). MFIs also need to make a small profit, put money aside for bad debt (loan losses) and borrow some money that they can on-lend to poor people (financing expenses). Microcredit rates are higher than banks because making many small loans to many people generates higher operation expenses than making one big loan to a large company. In addition the MFIs often offer a doorstep service which is more costly for the institution but which reduces the opportunity and transaction costs for the clients. Lastly, MFIs serve people who have limited collateral and who often live in more remote areas. These reasons explain why the average loan interest are close to 30 percent per annum globally (using interest yield as a proxy). A recent CGAP publication (Microcredit and their Determinants 4) shows that interest rates have declined in the last eight years (see box below). The causes vary from country to country, and the decrease may sometimes be related with increased efficiency and competition. But we believe that it is unlikely that these rates will go down to what commercial banks charge because it will always be more expensive to serve a large number of small accounts. DRIVERS OF INTEREST YIELDS, AS % OF YIELD, 2004 - 2011 2004 Interest Yield 2011 Interest Yield Profit Loan Lossec Financial Expense Operating Expense 4 http://www.cgap.org/publications/microcredit-interest-rates-and-their-determinants see also the blog post on East Asia http://www.cgap.org/blog/understanding-microcredit-interest-rates-east-asia NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 21 What are the effects of interest rate caps? In theory, interest rate caps are appealing because they sound fair and protective for the poor. In practice, these caps have had negative effects on the poor. Caps indeed prevent MFIs from covering their costs, which means that they are forced to take one or a combination of the following actions: • They target larger clients (because costs are lower when serving richer clients) • They may close operations in more difficult to reach areas (e.g. rural areas, remote areas) or stop expanding in these areas. • They stop expanding because they lose money on operations • They charge fees on top of the official interest rate to be able to recover their losses. • They deprive MFIs from loans from local and international social investors who can constitute an important re-financing source for MFIs and who usually shy away from places that have severe interest rate caps. 5 As a result clients previously served by MFIs can no longer access MFI services and they go back to money lenders who charge exorbitant rates. What are the interest rate policies for MFIs in Vietnam For formalized MFIs, State Bank of Vietnam (SBV) has imposed an interest rate ceiling, whereas semi-formal MFIs have to comply with the Civil Code. The Civil Codes has requested since 2005 that semi-formal MFIs should not have rates exceeding 150 percent of basic interest rates set by SBV (Clause 1 of Article 476, Civil Code 2005). So legally, with an SBV rate at 9 percent since 2012, semi-formal MFIs should not lend at higher rates than 13.5 percent per annum. While the Credit Institution Law allowed formal MFIs to negotiate their interest rates, the SBV has imposed a ceiling since December 2012, which has been reduced several times since December. Currently, the ceiling interest rates on short term microloans in 5 priority areas 5 for MFIs is 10 percent.. This rate is the lowest ceiling the authors are aware of in the region. 5 priority areas are: a) To service the development of agriculture and rural areas as prescribed in the Decree No. 41/2010/ND-CP dated April 12, 2010 of the Government on credit policies for agricultural and rural development; b) To implement the plans, projects of production and trading of exports as prescribed in the Commercial Law; c) To service the production and trading of medium and small enterprises as prescribed in the Decree No. 56/2009/ND-CP of June 30, 2009, on assistance to the development of small- and medium-sized enterprises; d) To develop the ancillary industries as prescribed in the Decision No. 12/2011/QD-TTg dated February 24, 2011 of the Prime Minister on policies on development of a number of supporting industries; e) To serve the production and trading of the high-tech enterprises as prescribed in the Law on High Technologies, and relevant laws. (Circular No. 16/2013/TT-NHNN dated June 27, 2013 of the State Bank of Vietnam promulgating the maximum interest rate for VND short-term loans of the credit institutions and foreign bank’s branches for the customers to satisfy funds demand serving some economic areas and sectors) 22 - VIETNAM MICROFINANCE WORKING GROUP What are the alternatives for MFIs? MFIs do not have many alternatives to overcome this ceiling. They have five alternatives, but each of them is either not fully conform with the law or simply not realistic given the nature of microfinance: (i) MFIs can switch to medium and longterm loans if they want to have negotiated rates. However microfinance is usually short term and MFIs do not have much available funds for medium and long-term loans. (ii) They can lend outside of the 5 priority areas. However, most of MFIs work with clients who are part of these 5 priority areas. (iii) MFIs in Vietnam may be tempted to charge extra fees. However, legally, MFIs can only apply two kinds of fees: prepaid-payment and fees for syndicated loans. 6 (iv) MFIs can charge negotiable interest rates if customers are not satisfied with the loan conditions in accordance with the regulations of SBV and their financial conditions are not considered transparent and healthy. 7 However, an essential condition for lending is that clients “have the financial capacity to pay on time”. 8 How can MFIs lend to clients who do not have good capacity and conditions for borrowing? 9 annum. With a ceiling of 10 percent on short term loans, Vietnamese MFIs are unlikely to become sustainable and to contribute to the expansion of sustainable microfinance promoted by the National Strategy (Following the Decision No. 2195/2011/QD-Tgg dated December 6, 2011 of the Prime Minister on Approving the Proposal of designing and development of microfinance system in Vietnam up to 2020). What can the VMFWG do to improve microfinance interest rates? On the one hand the VMFWG should continue advocating for market based interest rates for MFIs so that its members can operate on a sustainable basis and expand their services especially to the poor. The VMFWG could also encourage MFIs to improve their efficiency to continue reducing their operational costs. The VMFWG should also foster more responsible microfinance by ensuring that clients are treated fairly. This means that MFIs need to ensure transparency of their interest rates in a comprehensible and comparative way, as well as ensure that their clients have some means to complain in case of abusive practices. The IFC, through its Microfinance Program, supports a sustainable and responsible sector in line with the Microfinance Strategy launched by the Government of Vietnam which includes support for the VMFWG to promote more sustainable and responsible finance. (v) MFIs could use a flat rate methodology. However, for formal MFIs in Vietnam, it may not be consistent with the legal way of calculating the rates, and it is not consistent with international good practices. While the interest rate caps are said to be imposed for macro-economic reasons, they will have negative consequences for the emerging Microfinance sector. Reporting in Vietnam is not highly reliable, but CGAP estimates that the average interest rate of Vietnamese MFIs is below 25 percent per 6 Circular No. 05/2011/TT-NHNN dated March 10, 2011 of the State Bank of Vietnam regulating the charge of Credit Institutions’ Loans to clients. 7 Article 2 of Circular No. 16/2013/TT-NHNN dated June 27, 2013 of the State Bank of Vietnam 8 Article 7 of Decision No. 1627/2001/QD-NHNN dated December 31, 2001 of the State Bank of Vietnam on the lending regulations of Credit Institutions. 9 Article 10 of the Decision No. 652/2001/QD-NHNN dated May 17, 2001 of the State Bank of Vietnam “Issuing the Regulation on methods of calculating and accounting the collected and paid interests of the State Bank and Credit Institutions. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 23 IS THE INTEREST RATE CEILING SUITABLE FOR MFIS IN VIETNAM AT PRESENT? PH.D LE THANH TAM BANKING - FINANCE INSTITUTION - NATIONAL ECONOMICS UNIVERSITY Recently, Vietnamese policymakers have turned their attention to the microfinance institutions’ (MFIs) and People Credit Funds’ (PCFs) operational characteristics by allowing them to charge a 1% higher ceiling interest rate than other credit institutions. According to some international practices and experiences, this adjustment has not been sufficient for the sustainability of these institutions. This fact is due to four main reasons. First of all, if microfinance customers were served by commercial banks, they would have to bear higher transaction costs and opportunity costs. In fact, most microfinance customers live in mountainous and remote areas and face problems in accessing traditional banking services. Assuming that a microfinance client borrows money from a conventional bank, he/she will have to reach the bank’s transaction office or branch to complete the deal. Not only does he/she bear the transaction costs (such as travel, meals, documents, records, papers, etc.), but he/she also bears an increasing opportunity cost due to travel and processing time. If the loan in this example is large, these costs will not be significant (3-5%); however, if it is a small loan (below 30 million VND), the costs will account for an average of 34% (international practices-ADB/2013). Total cost of customer’s loan = interest expense + transaction costs + opportunity cost Although microfinance institutions charge a higher interest rate, it is clear below that customers bear a lower overall cost. Table 1: Costs of customer loans from banks and from MFIs Customer loans 30 million VND/12 months 20 million VND/ 12 months 10 million VND / 12 months Interest Rate Interest Payable (%) (million VND) (million VND) (million VND) (million VND) (%) Commercial Banks 15 4.5 3 0.48 7.98 27 MFIs 23 6.9 0.05 0.12 7.07 24 Commercial Banks 15 3 3 0.48 6.48 32 MFIs 23 4.6 0.05 0.12 4.77 24 Commercial Banks 15 1.5 3 0.48 4.98 50 MFIs 23 2.3 0.05 0.12 2.47 25 Organization Transaction Opportunity Total cost cost Cost Effective Interest Rate Notes: The transaction costs include travel costs (petrol, food, paper photocopies, purchase information, registration of security transactions, etc.). To obtain a loan, customers need to travel 3-4 times. The opportunity cost is the amount of money a customer would receive after one working day (120,000 VND). The interest rates above are assumed. In reality, although interest rate of commercial bank is 15% while MFI’s interest rate is 23%, the effective interest rate of commercial banks is higher. The smaller the loan is, the higher the cost 24 - VIETNAM MICROFINANCE WORKING GROUP rate is (for a 10 million VND loan, there is a 50% effective interest rate). Microfinance clients are benefit from decrease in transaction costs and opportunity costs. Thus, if interest rate of MFIs is higher than current interest rate ceiling, it is still very beneficial for customers, especially customers in rural and remote areas. Secondly, customers’ transaction costs and opportunity costs are transferred to the operational costs of microfinance institutions. Customers no longer have to present at the transaction office because microfinance institutions bring them services (door-to-door banking). As a consequence, costs and time required have been reduced for customers, although the amount of tasks that one credit staff has to fulfill increases significantly. Therefore, the salary costs take up a high proportion of MFIs’ operational costs. 70 63.64 61.81 58.95 60 50 40 30 26.25 20 12.48 10 0 TYM Thanh Hóa M7MFI Agribank QTDNDTW Figure 1: Percentage of salary costs and other costs related to salary between some MFIs and credit institutions (%) Source: Authors' calculations on data from annual financial reports of MFIs (2011-2012) Overall, the salary costs and other cost related to salary typically account for 60% of the total operational costs of MFIs. Meanwhile, it was 12.48% for Agribank and 26.25% for the People Credit Fund. In fact, the microfinance staffs’ salaries are relatively low in comparison with commercial banks. The main reason of high percentage of salary cost is that MFIs use a lot of employees and transfer customers’ costs to their operational costs. Clients can implement transactions in day with small loans but large number of transactions. Therefore, number of customers and average loan balance per credit officer of MFIs are much lower than other credit institutions. Gross Loan Outstanding per credit office (million/person Clients per credit offiver 350 300 250 200 150 100 50 0 286 270 206 1000 945.9 236 861.5 800 771.2 580 161 600 477.8 157 154 400 296.6 284.4 200 0 Average New MFLs (0-4 years) Young Mature Super Small Small MFLs Medium Large MFLs MFLs MFLs MFLs (USD MFLs (USD (GLP > USD (4-8 years) (>8 years) (GLP<USD 400.000 1m < GPL < 8 m) 400.000) < GLP < USD 8 m) USD 1m) Figure 2: Labor Productivity and exposure of MFIs in Vietnam Source: Authors' calculations on data of the VMFWG members in the period of 2011-2012 NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 25 that are difficult to access, customers will have no choice but to borrow from other sources. It is also clear that the 1% higher interest rate would not be sufficient for MFIs to cover the operational costs that are transferred from their customers. Moreover, they will encounter problems in maintaining operational sustainability due to the gap of 3.5% between the input and output interest rate. Thirdly, the interest rate ceiling can harm the sustainability of MFIs and have negative impacts on microfinance clients. According to It is obvious that the labor productivity of MFIs is lower than commercial banks due to the market segmentation and approach. In Vietnam, a single MFI credit staff has to deal with an average of 206 customers and 580 million VND in outstanding loans. This is slightly higher for large and mature MFIs, (270 and 861.5 million VND for mature MFIs, 286 and 945.9 million VND for large MFIs). In addition, newly established and small MFIs have much lower labor productivity. However, this does not reflect inefficiency in MFIs’ operations. There is no doubt that if MFIs cannot approach customers and provide them services the calculations of TYM and M7-MFI, the average input costs are 13-14% per year. Thus, the 11% interest rate ceiling would lead to operational losses. If this interest rate remains stable for 2.5 years, the two organizations will go bankrupt. Also, it will cause the following results. (I) The physical and mental benefits of microfinance clients will be reduced or even disappear in the long term. In terms of characteristics, MFIs are social enterprises, with the aim of balancing sustainability and social benefits. Thus, microfinance clients can get access to highly social financial services. The characteristics of the market, risk management, products, and personnel differentiate MFIs from other credit institutions. Table 2: Characteristics of MFIs compared to other credit institutions and the benefits for customers Categories Conventional credit institutions Microfinance institutions Benefits for customers Targets Profit only Sustainability and social targets - Affordable costs - High socialization Customers Medium and high income customers from urban areas Low income customers from rural areas - Better access to official financial services Risk reduction Guarantee by assets Unsecured - Group support - Higher internal competitiveness Products Large loans - Small loans, gradual payment, mostly for women - Several additional products improve the ability of women - Human resources Highly qualified and well trained Basic qualifications Good social skills - Friendly staff - deeply comprehends customers Procedure More complex Easier - Door-to-door services, always available - Close and friendly services Approach Transaction office/branches At the customers’ - Reduction of transaction costs - Easy loan collection Meet the demands and abilities Payable Additional services Gender empowerment Source: Compiled by authors from ADB (2013), VMFWG (2013) 26 - VIETNAM MICROFINANCE WORKING GROUP The benefits that clients receive from microfinance services are extremely huge, both physically and mentally, especially in social and gender empowerment. Therefore, the interest rate ceiling contributes to increase the physical value in the short term for customers (due to lower interest paid), even though MFIs are unable to provide long-term services continuously. Therefore, the future physical and mental benefits of customers would be seriously affected. (II) Customers will have to borrow from informal sources to meet their financial needs if they do not have access to MFIs. Borrowing a loan of under 30 million VND from formal credit institutions is very difficult because of high total transaction costs and complex procedures. Meanwhile, the average loan amount of an MFI is 5.7 million VND (VMFWG, 2013). Thus, the customer will have to borrow from informal sources (private lenders, pawnshops, friends, relatives ...) to meet the financial needs if they do not have access to MFIs. In fact, although the interest rates of private lenders in Vietnam and the world are relatively high (averaging 60-100% per year), they still exist and develop, even in crowded urban areas where credit institutions are developing. Informal sectors have many advantages such as accessibility without paperwork, no collateral requirements, availability when needed, and timely and quick disbursement (ADB, 2013). These are also the characteristics that Vietnam MFIs already have. When comparing the cost of loans between MFIs and informal sectors, transaction costs and opportunity costs are similar. But we can see a huge difference in the costs of borrowing. For example, MFIs’ lending rate is 23-30% per year and customers are able to save 30-77% per year if they borrow from MFIs. The smaller the loans are, the larger difference in borrowing costs. If low income customers borrow from the informal sector, they will have to address debt burdens. Fourthly, International experiences in microfinance interest rate: Lending rates of MFIs on average range from 20-30%, depending on the country or region. 45 39 40 37 35 35 34 30 30 30 26 27 25 30 30 30 28 27 26 25 26 23 23 25 22 21 20 15 10 5 0 World Africa 2004 2006 East Asia Central Asia Latin America Middle East South Asia 2011 Figure 3: Average lending rates of MFIs in the world (% per year) Source: (Duflos, 2013) Due to the characteristics of clients and MFIs, lending rates charged for microfinance clients around the world have been quite high in recent years, averaging 30% in 2004 and dropping to 27% in 2011. The South Asian countries had the lowest interest rates (averaging 28% in 2004 and 21% in 2011), while the rates in Africa were the peak (39% in 2004 and 25% in 2011). Data showed that the lending rates for microfinance were generally lower than the informal sector by 10-25% per month (Duflos, 2013). Therefore, the current interest rate ceiling for formal MFIs in Vietnam is too low compared to international practices and not enough for the organization to stay alive, showing a huge difference with the informal sectors, as discussed above. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 27 DIFFICULTIES IN MEETING THE DEMAND OF THE LIQUIDITY RATIO NGUYEN DUC BINH M7 MFI 1. Formula of the liquidity ratio The liquidity ratio of microfinance institutions (MFIs) is regulated by Article 8 of Decree No. 07/2009/TT-NHNN dated 17/ 04/2009. Pursuant to this Resolution, MFIs have to keep the liquidity ratio at a stable minimum level of 20%. This ratio is calculated as follows: Liquidity ration = Cash + Liquid asets Total deposits Cash + liquid assets: Cash, deposits at the State Bank (excluding the required reserve), deposits at other credit institutions, Government bonds, bonds guaranteed by the Government. Total deposits: compulsory deposits and voluntary deposits. 2. Practices and problems faced During the implementation process, MFIs came across problems in maintaining the liquidity ratio at 20%, which had a negative impact on operational efficiency. To follow the Resolution strictly, MFIs have to keep a large amount of cash as required reserve or at a Bank, while the demand for loans by customers increases. Thus, the demand cannot be fully met on account of the limited capital of MFIs. 28 - VIETNAM MICROFINANCE WORKING GROUP In theory, the liquidity of a MFI at a specific time reflects the payment ability of this institution to matured loans. The formulation illustrates the amount of cash, bank’s deposits and liquidity bonds that a MFI holds to arrange payment of interest on compulsory and voluntary deposits. Compulsory and voluntary deposits differ (maturity deposits and call deposits). Compulsory deposits (regulated savings) are defined and regulated by Resolutions No. 28/2005/NĐ-CP, which are savings or deposits of households, who are clients of the MFI. In reality, customers are required to deposit regularly by MFIs in order to create the habit of saving. It is also extremely important to provide capital and liquidity for MFIs. Having awareness of this importance, MFIs have provided strict rules to regulate withdrawals. Clients, who hold compulsory deposits at the institutions, can withdraw only if they cease to be customers of the institutions or may partly withdraw in the event of an emergency. Due to these regulations, compulsory deposits are stable and there is a steady increase in these account balances. On the other hand, the regulated minimum liquidity ratio of 20% is relatively high for MFIs, while the ratio for credit institutions is only 15%. Moreover, the cash flow of MFIs has a rapid rotation. Most of the loans are short-term and payment is made more than once every month. In fact, clients of M7 are required to make repayments and compulsory deposits twice a month. This can guarantee MFIs high liquidity. 3. Recommendations. In order to implement the regulations of the State Bank as well as ensure the sustainability of MFIs and help the poor to access loans which provide sufficient capital, we recommend that the State Bank to reconsider the liquidity ratio. Firstly, by removing compulsory deposits in the denominator of the formula and secondly, reducing the liquidity ratio threshold from 20% to 10%. Studies show that using cash to ensure the payment of compulsory deposits is not reasonable. According to the practice of M7, the mobilization of capital is mostly from borrowing and mobilizing deposits. Compulsory deposits account for over 20% of total deposits. Statistics indicate that to maintain the liquidity ratio of 20% M7 has to deposit 9 billion VND at commercial banks. Without compulsory deposits, M7 has to deposit 7 billion VND and the rest can be lent to 300 members for developing business. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 29 BENCHMARK OF MFIS VIETNAM IN 2012 A ge I n s t it u t io n a l c h a r a c t e r is t ic s Number of institutions 9 11 S c a le b y Gr o s s L o a n P o r f o lio Ge o g r a phic a l S c a le Trend Mature (Across (> 8) Group) 14 District Province National 24 8 2 Trend (Across Group) Small (2m) Medium (2-8m) 24 6 Trend Large (>8m) (Across Group) 4 238,511 944,211 1,679,822 668,801 1,374,326 2,889,778,926 490,376 2,531,348 183,408,866 Total Asset 305,899 1,193,867 2,070,737 718,451 2,023,839 3,281,441,913 508,376 2,895,244 376,867,953 Age 1 5 13 6 6 16 5 8 14 Staff 12 33 43 21 47 5,008 20 63 1,185 84% 94% 90% 92% 85% 64% 92% 87% 64% 4 15 28 11 32 1,375 10 33 367 Number of active borrowers 1,463 4,362 9,196 3,287 8,309 3,575,437 2,839 13,002 148,425 Percentage of Female borrowers 98% 96% 100% 99% 99% 51% 99% 100% 75% Average Loan Balance 174 157 246 160 203 3,445 166 186 533 Average Loan balance/ GNI per capita 13% 12% 18% 12% 15% 256% 12% 14% 40% Number of depositors 1,463 5,478 10,430 5,004 10,408 2,126,724 4,708 15,318 151,571 21 34 41 34 23 46 29 35 114 Average Saving balance/ GNI per capita 1.5% 2.5% 3.1% 2.5% 1.7% 3.4% 2.2% 2.6% 8.5% Borrowers per loan officer 351 282 352 300 352 1,601 282 462 567 69,973 62,947 93,959 68,358 71,226 1,534,949 57,033 75,647 443,527 Loan officer O ut r e a c h Young (5 - 8) Gross Loan Portfolio % Female Staff Average Saving balance F in a n c ia l a n d O p e r a t io n a l P e r f o r m a n c e New (0 - 4) Portfolio per loan officer Cost per borrower 29 24 15 22 26 231 24 16 29 Operating Expense Ratio 14% 15% 9% 14% 13% 5% 14% 12% 8% Total Liabilities/ equity 1.80 1.52 2.02 1.78 1.01 4.50 1.52 1.16 3.38 Loan Portfolio/ Total Asset 89% 94% 95% 94% 94% 69% 95% 89% 87% Yield on GLP 22% 24% 22% 23% 22% 18% 23% 22% 25% Funding expense ratio 1% 3% 4% 2% 1% 13% 2% 1% 6% SOSS 141% 134% 166% 146% 157% 94% 141% 159% 129% ROA 7% 4% 9% 7% 6% 0% 7% 7% 4% Note: 1. All figures are in USD and are calculated medians. 2. Exchange rate on 31st December, 2012: USD 1=20,833 VND 3. The definitions of Small, Medium and Large MFIs are based on the Microfinance Information Exchange classifications for Asia (Parcific) 4. GNI/capita is USD 1345.85 (Source: MIX market, 2013) 5. We apply 3 ways to classify Vietnamese MFIs, based on age, geographical coverage and GLP. Generally speaking, the more mature an MFI is, the bigger it is in term of asset, gross loan portfolio, staff and its number of borrowers. The same positive correlations are also manifested in groups of geographical coverage and asset size. However, some indicators sending mixing message. Observable disrupted trend is largely dependent on various factors, not only on listed difference (age, geographical coverage, and asset size), but on both external economics condition in different area, and internal model and purpose of each MFIs. 30 - VIETNAM MICROFINANCE WORKING GROUP Age New (0-4 years) Young (5-8 years) Mature (>8 years) Golden Hand Program (BTV); Economic Development Fund for Poor Households (VietED); Soc Trang Fund for Poor Women; Thanh Hoa Fund for Poor Women; Women Development Fund in Lao Cai; Women Development Fund in Quang Binh; An Phu Development Fund; Small Credit Fund For Housing Refurbishment in Da Nang; Standard Training Unit (STU) Anh Chi Em (ACE); Microfinance Program- Women's Union, Ben Tre Province (BTWU); Credit Project- Women Union Soc Son Distric (PNN Soc Son); Dong Trieu Women Development Fund (M7 Dong Trieu); Mai Son Women Development Fund (M7 Mai Son); Uong Bi Women Development Fund (M7 Uong Bi); Center for Women and Community Development (CWCD); Microfinance Fund for Community Development (MFCDI); The Center of Small Enterprises Development Assistance (SEDA); Ha Tinh Women Development Fund (Wu Ha Tinh); Microfinance Unit- World Vision Vietnam (WV Vietnam) Credit & Savings project-Women Union, Phu Yen District, Son La; Ninh Phuoc Women Development Fund (M7 Ninh Phuoc); Dien Bien Phu City Women Development Fund (M7 DBP City); Dien Bien District Women Development Fund (M7DB District); Capital Aid Fund for Poor Employees Ba Ria- Vung Tau (CAFPE); Pro-Poor Center Can Loc, Ha Tinh (PPC); Credit & Savings Project- Livelihood Program- ChildFund Vietnam; Tien Giang Capital Aid Fund for Women's Economic Development Fund (MOM); Women Economic Development Fund- Ho Chi Minh City; The Dariu Foundation (DARIU); Capital Aid Fund for Employment of the Poor (CEP); Tinh Thuong One Member Limited Liability Microfinance Institution (TYM); Vietnam Bank for Social Policies (VBSP); Central Pepple's Credit Fund (CCF) Geography District Province National Golden Hand Program (BTV); Economic Development Fund for Poor Households (VietED); Soc Trang Fund for Poor Women; Women Development Fund, Quang Binh; An Phu Development Fund; Small Credit Fund For Housing Refurbishment, Da Nang; Standard Training Unit (STU); Thanh Hoa Fund for Poor Women; Anh Chi Em (ACE); Microfinance Program- Women's Union, Ben Tre Province (BTWU); Credit Project- Women Union Soc Son Distric (PNN Soc Son); Dong Trieu Women Development Fund (M7 Dong Trieu); Mai Son Women Development Fund (M7 Mai Son); Uong Bi Women Development Fund (M7 Uong Bi); Center for Women and Community Development (CWCD); Ha Tinh Women Development Fund (Wu Ha Tinh); Credit & Savings project-Women Union, Phu Yen District, Son La; Ninh Phuoc Women Development Fund (M7 Ninh Phuoc); Dien Bien Phu City Women Development Fund (M7 DBP City); Dien Bien District Women Development Fund (M7DB District); Capital Aid Fund for Poor Employees Ba Ria- Vung Tau (CAFPE); Pro-Poor Center Can Loc, Ha Tinh (PPC); Tien Giang Capital Aid Fund for Women's Economic Development Fund (MOM); Women Economic Development Fund- Ho Chi Minh City Women Development Fund, Lao Cai; Microfinance Fund for Community Development (MFCDI); The Center of Small Enterprises Development Assistance (SEDA); Microfinance Unit- World Vision Vietnam (WV Vietnam); Credit & Savings Project- Livelihood Program- ChildFund Vietnam; The Dariu Foundation (DARIU); Capital Aid Fund for Employment of the Poor (CEP); Tinh Thuong One Member Limited Liability Microfinance Institution (TYM); Vietnam Bank for Social Policies (VBSP); Central Pepple's Credit Fund (CCF) NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 31 Size (based on Gross Loan Portfolio) Small (<2m USD) Medium (2m-8m USD) Large (>8m USD) Golden Hand Program (BTV); Economic Development Fund for Poor Households (VietED ); Soc Trang Fund for Poor Women; Women Development Fund, Quang Binh; An Phu Development Fund; Small Credit Fund For Housing Refurbishment, Da Nang; Standard Training Unit (STU); Women Development Fund, Lao Cai; Anh Chi Em (ACE); Microfinance ProgramWomen's Union, Ben Tre Province (BTWU); Credit Project- Women Union Soc Son Distric (PNN Soc Son); Dong Trieu Women Development Fund (M7 Dong Trieu); Mai Son Women Development Fund (M7 Mai Son); Uong Bi Women Development Fund (M7 Uong Bi); Center for Women and Community Development (CWCD); Microfinance Fund for Community Development (MFCDI); The Center of Small Enterprises Development Assistance (SEDA); Credit & Savings project-Women Union, Phu Yen District, Son La; Ninh Phuoc Women Development Fund (M7 Ninh Phuoc); Dien Bien Phu City Women Development Fund (M7 DBP City); Dien Bien District Women Development Fund (M7DB District); Capital Aid Fund for Poor Employees Ba Ria- Vung Tau (CAFPE); Pro-Poor Center Can Loc, Ha Tinh (PPC); Credit & Savings Project- Livelihood Program- ChildFund Vietnam Thanh Hoa Fund for Poor Women; Ha Tinh Women Development Fund (Wu Ha Tinh); Microfinance Unit- World Vision Vietnam (WV Vietnam); Tien Giang Capital Aid Fund for Women's Economic Development Fund (MOM); Women Economic Development Fund- Ho Chi Minh City; The Dariu Foundation (DARIU) Capital Aid Fund for Employment of the Poor (CEP); Tinh Thuong One Member Limited Liability Microfinance Institution (TYM); Vietnam Bank for Social Policies (VBSP); Central Pepple's Credit Fund (CCF) 32 - VIETNAM MICROFINANCE WORKING GROUP CROSS-MARKET BENCHMARKING AND ANALYSIS VIETNAM MICROFINANCE COMPARED TO EAST ASIA AND THE PACIFIC PEERS. LE LINH CHI VMFWG VOLUNTEER Vietnam belongs to East Asia and the Pacific (EAP) region, which includes approximately seven countries (Cambodia, China, East Timor, Indonesia, Laos, Philippines, and Vietnam). This analysis will not delve into detailed analysis of EAP microfinance, which stakeholders can find on MIX report archive, but to sketch out an overall view of development of Vietnam Microfinance sector among other peer countries on several main indicators. 1. Institutional Characteristics 800 60,000,000 700 50,000,000 600 40,000,000 500 400 30,000,000 300 Personnel (median) Total Assets, GLP, Deposit blanace (Median In USD) Total Assets, Gross Loan Portfolio, and Deposit Balance Of Coutries in EAP 20,000,000 200 10,000,000 100 0 Vietnam China, People’s Republic of Assets (median) Laos East Timor Gross Loan Portfolio (median) Indonesia Philippines Deposits (median) Cambodia Region 0 Personnel(median) NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 33 Regarding of median value of Total Assets, Gross Loan Portfolio and Deposit, Vietnamese MFIs stays at the bottom of the region ranking. Only 4 of 34 MFIs of Vietnam are classified as “large credit institution” with total asset more than USD 8 millions, the rests are ranging from approximately USD 80,000 to more than USD 3 millions. Relatively insignificant Loan Portfolio and Deposit value of Vietnam MFIs are derived from two main factors: smaller number of active clients (including both borrowers and depositors clientele) and smaller average loan/deposit balance per client. With comparatively smaller loan sizes and deposit balance relative to national income per capita, Vietnam MFIs in general are more focused on poor household than peer institution in the region. Operational scale of Vietnam MFIs is also smaller in the region judging by the number of staff, which is especially heavily composed by female (89% vs. 48% of the region median institution) due to the fact that a large portion of Vietnam MFIs are directly controlled by Women Unions. 2. Funding Structure Funding Structure 100% 90% 80% 70% 60% 50% 40% 30% 30% 10% 0% Philippines Indonesia East Timor Total Ewuity Vietnam Total Deposit China, People’s Republic of Cambodia Laos Region Total Borrowings and other liability MFIs have generally funded by three main categories: Deposit (grows through outreach to clients), borrowings and other liability (grows through outreach to investors), and equity (though contact with investors and retained earnings). As observed on the chart, Vietnam MFIs financing structure is composed by moderate equity, slight deposit and heavy borrowings and other liability, compared to their regional peers. This visualization demonstrates that outreach to client through deposit channel of Vietnam MFIs is still limited compared to that of the region; On the other hand, Vietnam MFIs received heavier borrowings, including both sponsored and subsidized loan, and other market-interest-rate loan, from foreign banks or various local or foreign development projects and programs. 3. Productivity and Efficiency Country Operating expense/ loan portfolio (median) Cost per borrower (median) Borrowers per loan officer (median) Vietnam 12.10% 19 340 China 8.80% 85 148 Indonesia 89.03% 89 254 Laos 21.92% 93 112 East Timor 23.91% 94 157 Philippines 22.01% 107 300 Cambodia 14.18% 127 146 34 - VIETNAM MICROFINANCE WORKING GROUP In previous year, Vietnam MFIs was reported to be outstandingly efficient and productive compared to other regional peers. This fact was explained by direct support by mean of staff (voluntary or part-time officer to monitor loan) and subsidize from controlling Women Union. This year data still claims Vietnam MFIs’ loan officers are the most productive compared to other EAP colleagues with median number of borrowers per loan officer (10% more than the second countries), and maximum value of the indicator amounts to 1300. On the other hand, contradicting to previous explanation that cost-efficiency of Vietnam MFIs was thanked to Women Union’s support of staffs, this year average salary of Vietnam MFIs has median of USD 185 per month, equal to 160% GNI per, showing no proof for previous explanation. Instead, relatively smaller scale and scope of operation of Vietnam MFIs should play a part in explaining high productivity. High productivity of Vietnam MFIs’ loan officer results in remarkable low cost per borrowers (just a fraction of that of other regional peers), and overall operation cost of MFIs. 4. Profitability and Sustainability Profitability and Sustainabitity of Vietnam MFLs, and of others in the region 2010 - 2012 8.00% 700,00% 7.00% 600,00% OSS range 5.00% 400,00% 4.00% 300,00% 3.00% 200,00% 2.00% 100,00% Retunrn on Asset (Median) 6.00% 500,00% 1.00% 0,00% 0.00% 2010 2011 2012 2010 2011 2012 Indonesia China 2010 2011 2012 Range of OSS Philippines 2010 2011 2012 2010 2011 2012 East Timor Cambodia OSS Median 2010 2011 2012 Laos 2010 2011 2012 Vietnam Return on Asset (Median) Even though generally MFIs in Vietnam have lower yield on gross loan portfolio (nominal) than their regional peer institutions, thank to cost structure (high productivity) and favorable funding structure (a large proportion of sponsored and subsidized loan), Micro Finance sector of Vietnam stands out as one of the most profitable and sustainable in the region. Certain level of diversification of OSS among Vietnam MFIs is presented, but the heuristic trend observable on the chart is a stable improvement of Vietnam MFIs’ capacity to stay profitable and self-sustaining. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 35 NEWS LOCAL NEWS 1. Bao Viet Hanoi and M7-MFI officially cooperate to provide loan insurance products In order to implement the mission and the vision of the organization, M7-MFI has been steady steps to become the institution providing microfinance services efficiently and bringing to customers the best products as well as ensuring the financial sustainability of the organization. On 06/28/2013, M7-MFI and Bao Viet Hanoi has officially signed a cooperation agreement to provide loan insurance products. As the cooperation with Bao Viet Hanoi - a member of Bao Viet Insurance Corporations which is one of the leaders providing insurance products, finance services for institutions and individuals in Vietnam, M7 -MFI has become an official partner of Bao Viet Hanoi besides some potential customers such as: Hong Kong Shanghai Bank (HSBC), Vietnam Technological and Commercial Bank (Techcombank) and many other well-known organizations. This asserts reputation and position of M7-MFI in the financial sector and the customer services in order to become the top microfinance institution in Vietnam. 2. The Government allows CFRC to continue piloting the project M7MPA To overcome the difficulties of the legal framework, in 3/2013 CFRC sent an official letter to the State Bank of Vietnam, Ministry of Finance and the Government Office for 36 - VIETNAM MICROFINANCE WORKING GROUP permission to continue implementing birth mutual protection association (mutual protection association - MPA) cooperated with organizations and micro-finance programs for low-income people. Vietnam Study Encouragement Association, governing the CFRC, also sent to the Government the project of birth mutual protection of CFRC. After presenting to competent authorities, CFRC has received very positive supports. In detail, Deputy Governor of the State Bank Dang Thanh Binh has allowed MFIs M7MFI fully implemented "collection of payments for their clients" for the MPA in his documented reply to CFRC and Ministry of Finance, Deputy Minister Tran Van Ha mentioned in an official letter to the Government that the project "The protection of mutual security" should be encouraged by the CFRC. Therefore, the Government allowed CFRC to continue carrying out project with the guidance of the Ministry of Finance as well as assigned the Ministry of Finance to be responsible for issuing a microfinance insurance policy basing on piloting results of the project, to have a formal microfinance policy for Vietnam in 2015. The remaining problem depends on the awareness and commitment to pursue social missions of microfinance institutions whether they follow CFRC or another path. 3. Vietnam Cooperatives Bank acquired the Business License On June 4, 2013, the Governor of the State Bank of Vietnam signed the license number 166/GP-NHNN to establish the Vietnam Cooperative Bank as the request of the Central People’s Credit Fund. This license has come into effect as the signed date. According to the license, the Vietnam Cooperative Bank is headquartered at 15T Nguyen Thi Dinh Street, Trung Hoa Ward, Cau Giay District; has chartered capital of 3,000 billion VND, including supported capital from the State’s budget, contributed capital from People’s Credit Funds and other legal entities. The validity of the license is 99 years. The Vietnam Cooperative Bank operates with the geographical of nationwide, and it is allowed to establish network units domestically and internationally when receiving acceptance from the State Bank of Vietnam. The Vietnam Cooperative Bank must follow all regulations and laws of Vietnam. GLOBAL NEWS 1. Partnerships against Poverty: Government, Business, Finance and Civil Society The conference brings an opportunity to the participants to delve into the most advanced and successful examples of publicprivate partnerships (PPP) in the microfinance sector. Stakeholders work altogether to enlarge the scale of these programs, involved parties include: government regulatory agencies, microfinance practitioners, product design experts, providers of support services, and heads of multinational banking institutions. With many activities, it will meet the stakeholders’ demand of a deep dialogue around challenges and opportunities, and working together on our mission to completely eliminate poverty in the near future. For more information http://partnershipsagainstpoverty.org/ 2. 2013 SEEP Annual Conference http://www.vision6.com.au/ch/14090/2ddv6 qg/1846324/2b5cd7m0c-1.html The 2013 SEEP Annual Conference “Partnerships and Cross Sector Approaches” will be held as a fundament to promote learning and potential opportunities for collaboration. Economic development practitioners, regardless of regions and organizations, are seeking ways to break through interventional boundaries and the traditional mindsets of roles. Sustainable changes can be achieved by accepting approaches that focus on optimizing outcomes across sectors and throughout the entire system. For more information http://www.seepnetwork.org/annual-conference-pages-20008.php ence, networks and exchange techniques for keeping going on implementation efficient and sustainable financial services in the region. For more information: h t t p : / / w w w . m i c r o fi n a n c e pasifika.org/pmw2013.html 4. 2013 Citi-FT Financial Education Conference The 2013 Citi-FT Financial Education Conference, which is organized by Citi Foundation, the Pearson Foundation and the Financial Times, marks its 10th anniversary as the leading annual global forum on financial literacy and capability. This year Conference will: • Introduce technology and product innovations enhancing the financial capability for low-income groups, including youth, migrant workers, women, farmers, workers and the elderly; • Find out methods for assessing the effects of financial education programmes; • Examine potential model, particularly focus on more sustainable, cost-effective approaches. For more information: https://www.etouches.com/ehome/fined20 13/home/?& 5. The Luxembourg Microfinance and DevelopmentFund The Luxembourg Microfinance and Development Fund (LMDF) is an open-ended collective investment scheme (SICAV) supporting financial institutions, which aim to reduce poverty, in developing countries in Africa, 3. 2013 Pacific Microfinance Week http://www.vision6.com.au/ch/14090/2ddv6 qg/1846329/2b5cdp5wh-1.html 2013 Pacific Microfinance Week is the initiative of Pacific Microfinance Network which includes a chain of events in a week as workshops, field trips and official conferences. The most comprehensive fundament will be provided to all parties involving microfinance sector in the Pacific in order to share experi- NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 37 Asia and Latin America. LMDF concerntrates on medium-sized institutions which hold the 2nd and the 3rd place in the sector. To receive funds from LMDF, microfinance institutions shall fullfill the following requirements: - Having being active for at least 3 years; - Having AT LEAST 1,000 micro-entrepreneurs as clients; - Having investment portfolio : 0.5 million Euros ; - Generating profit or close to making profit. - Portfolio at risk (PAR 30 days) does not exceed 10% of gross loan portfolio. - All accounts are audited. - Having good social and financial position (not required but as an advantage) LMDF pays much attention to the following aspects : - Institutional structure: history, management, human resources; - Operational profile: types of products, methods, portfolio management; - Social profile: social mission and vision, targets and the appropriateness of products provided, geographical scope. - Financial performance: coverage costs, resources structure, level of dependence on sponsors. - Context: economy, society, politics and market. - Value added society and economy expected as a result of LMDF financing. Contact: Alexandre Brajoud Investment Officer for Asia and Africa Alexandre.ada@microfinace.lu +352 45 68 68 34 6. Executive Master in Development Policies and Practices (DPP) 2013 The DPP lasts for 2 full-time months and 4 part-time months at place of work and is offered to development practitioners in Central and Southeast Asia, Africa and Latin Amer- 38 - VIETNAM MICROFINANCE WORKING GROUP ica. It is also open to Swiss and other ‘Northern’ countries candidates working in international cooperation, whether they are based in the field or at the headquarters of their organisation. Module 1: July – August 2014 in Hanoi (5 fulltime weeks) Studying on public policies and development factors, analytical tools and methodology, strategic management of development actions Module 2: September – December 2014 (4 part-time months at place of work) Job-related professional thesis Module 3: January – February 2015 in Geneva (3 full-time weeks) Strengthening and reflecting on communication, negotiation, mediation, teamwork and intercultural skills; Delivering professionally these findings and interaction within thematic groups, with professors and experts; Analyzing the policies and practices of Geveva-based organizations and public administration. Scholarships are available for candidates coming from the Mekong Region (Vietnam, Cambodia, Laos and Myanmar) and Switzeland. For more information, please see at link : : http://dpp.graduateinstitute.ch/home.html POLICY NEWS 1. Consultation on “The proposed regulatory framework for microinsurance in Vietnam” On September 19th, 2013, Asian Development Bank (ADB) coordinated with State Bank of Vietnam to organized the consultation on “Propose the legal framework for micro-insurance in Vietnam” in Hanoi. The delegates listened to presentations related to ADB Microfinance Development, including: Micro-insurance Development Support, Good Practice of Micro-insurance in several countries, ADB’s recommendations on legal framework for micro-insurance in Vietnam and the open discussion for micro-insurance and legal framework. 2. New Draft Circular on the rules of prudential limits and rates in microfinance activities On 17/4/2009, the Governor of the State Bank of Vietnam issued Circular No. 07/2009/TT-NHNN (Circular No. 07) rules about prudential ratio in the operation of small-scale financial institutions. However, some provisions of the Circular No. 07 were no longer consistent with the practical operation of microfinance institutions. In July 2013, the State Bank surveyed some MFIs on the Draft regulations of prudential limits and ratios for the operation of microfinance institutions to facilitate the development of microfinance activities in Vietnam, especially for licensed micro-finance institutions. 3. Workshop "Establishing sustainable interest rates and risk management in microfinance institutions." In the morning of May 16th, Hanoi, the International Finance Corporation (IFC) collaborated with Tinh Thuong one member limited liability microfinance institution (TYM - the Vietnam Women's Union) and the Vietnam Microfinance Working Group (VMFWG), organized a workshop on "Establishing an sustainable interest rate and risk management in microfinance institutions after sending the official correspondence to the State Bank of Vietnam, Banking Supervisory agency and Monetary policies Department and proposing the applicable interest rate for the objective of their sustainability in Vietnam. The principal goal is to raise the awareness of the policy makers and organizations operating in the microfinance sector about the importance of interest rates and pricing policy for the sustainability of MFIs, as well as risk management in microfinance institutions in order to prepare for the transition and business development of organization. develop favorable policies and regulations for the development of the microfinance sector in Vietnam, as well as facilitate MFIs to build suitable price , enhance risk asset management and practice microfinance responsibly. 4. Official Dispatch of The State Bank of Vietnam about lending interest rate and the calculating method of interest for Microfinance Institutions VMFWG is pleased to share with you the content of the SBV’s original response about interest rate for Microfinance operation in Vietnam (Detail in Official Dispatch of The State Bank of Vietnam responding for Official Letter No. 0402/CV-MFWG sent to the SBV in February 4, 2013, attached),in brief as follows: - Lending interest rate For loans as the particularities of Microfinance Institutions that do not meet enough requirements/conditions about financial transparency and visibility under the provisions of Circular No. 10/2013/TT-NHNN, Microfinance Institutions implement lending interest rate mechanism basing on agreement in accordance with Section 3, Article 4, Circular No. 10/2013/TT-NHNN and Circular No. 12/2010/TT-NHNN in April 14, 2010 of The Governor of The State Bank of Vietnam. - The calculating method of interest rate on loans Microfinance Institutions implement interest in accordance with the regulations of the State Bank of Vietnam and Credit Institutions about calculating and revenue accounting , interest payment method issued in accompanying with Decision No. 652/2001/QĐNHNN in May 17, 2001 of The Governor of The State Bank of Vietnam. The workshop was held successfully with the participation of 75 delegates including representatives from relevant ministries, national and international experts, researchers, policymakers and representatives of microfinance institutions of Vietnam. It is highly appreciated because of the content and methods of discussion whichemphasized the significance of sustainable interest rates and risk management in microfinance activities, then contributes to help the State agencies NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 39 NEW PUBLICATIONS OF VMFWG sample of three MFIs operating in Long An, Tien Giang, and Soc Trang provinces in the Mekong Delta in Vietnam. 1. Microfinance Institutions in Vietnam: The publication is accomplished by VMFWG and the cooperation of the research group including: Dr. Nguyen Huu Thien, Mr. Duong Phuoc Hoang Lan and MSc, Nguyen Thi Tuyet Mai with financial support of Citi Foundation – Citi Bank, ADA Organization and Cordaid Organization. In 2012, VMFWG published the first “Microfinance Institutions in Vietnam” and received many positive feedbacks from investors as well as Government agencies. In order to keep moving on promoting the transparency of Micro-finance sector in Vietnam, VMFWG has been continuously co-operating with The Mix Market Organization, along with financial support from ADA Organization and Cordaid Organization to collect data information of 34 institutions and programs being active in Vietnam in December 31, 2013 and complete the second “Microfinance Institutions in Vietnam”. The publication of these profiles is an important achievement of the VMFWG and aligns with our goals to enhance information sharing and create opportunities for collaboration and cooperation between microfinance institutions in Vietnam. The document provides an overview of the number of operating MFIs and their location, the size and area of operations, outstanding loans, productivity, quality, sustainability and the vision and mission of MFIs in Vietnam. At the same time, it allows MFIs to compare and assess the operational status of their organization compared to other organizations in Vietnam and Asia. 2. The Research Report on “Climate Change impacts on microfinance: Case study The Mekong delta in Vietnam” : To raise the awareness of different microfinance stakeholders on the impacts of climate change to MFIs and livelihoods of their clients, the Vietnam Microfinance Working Group has commissioned this rapid qualitative study in the Mekong Delta to provide insights into the issue. The study looked at a 40 - VIETNAM MICROFINANCE WORKING GROUP 3. Complete and publish research report on "The sustainable level of MFIs in Vietnam: Current situation and some recommendations": Studying systematically the basic problems of microfinance institutions’ sustainability, the international experiences, and the real sustainable status of Vietnam microfinance institutions and recommendations. This research is completed by consultant group including Prof. PhD Nguyen Kim Anh, PhD Le Thanh Tam, MA. Quach Tuong Vy, MA. Nguyen Hong Hanh, BA. Nguyen Hai Duong, and MA. Nguyen Thi Tuyet Mai, with financial support of Citi Foundation-Citibank, ADA organization and Cordaid organization. BUILDING A SUSTAINABLE FUNDRAISING: THE ROLE OF VMFWG STEFANO BATTAGGIA ADA VOLUNTEER AT VMFWG Fundraising is the process of soliciting and gathering contributions as money or in kind (products or services), by requesting donations from individuals, businesses, charitable foundations, or governmental agencies. Some examples of grants include student scholarships, merit awards, humanitarian or medical concerns, disaster relief, human rights, research, and other social issues. VMFWG is actively pursuing the goal of maximizing the inflow of resources in the Vietnamese microfinance market by monitoring the calls for proposals of agencies from all over the world. We believe that a close cooperation with our members can help in winning the commitment of international agencies. We therefore call for a united effort in monitoring the ongoing and future projects in Vietnam, employing all members' connections. Below is a list of international agencies and NGOs who actively support projects in Vietnam. Please note: in some sites there is no specific page on grants, as they are distributed according to different action fields, so please search the entire site writing 'grant Vietnam' or the like in the search box. Country Austria Non-goverGoverment ment OrganiOrganization zation (NGO) ADA http://www.entwicklung.at/funding/en/ Jugend Eine Welt Austria WEB http://www.jugendeinewelt.at/ Australia AUSAID http://www.ausaid.gov.au/business/Pages/default.aspx Belgium BTC http://www.btcctb.org/en/tenders?country=89&type=All DGDC http://diplomatie.belgium.be/en/policy/development_cooperation/grants/ Brazil ABC http://www.abc.gov.br/projetos/pesquisa?intIdTipCooperacao=1&intIdPais=330 Canada CIDA www.cida.gc.ca Canada HOPE International http://www.hope-international.com/index.php Canada Street Kids International http://www.streetkids.org/ Canada World Accord http://www.worldaccord.org/ Chile AGCI www.agci.cl/ Denmark DANIDA http://um.dk/en/danida-en/ European Union Europaid Finland FINIDA http://formin.finland.fi/public/default.aspx?nodeid=15316&contentlan=2&culture=en-US France AFD http://www.afd.fr/lang/en/home/pays/asie/geo-asie/afd-vietnam/strategie-vietnam Germany GIZ http://www.giz.de/ Ireland Irish Aid http://www.irishaid.gov.ie/grants.html Israel MASHAV mashav.mfa.gov.il Italy Cooperazione Italiana http://www.cooperazioneallosviluppo.esteri.it/pdgcs/inglese/intro.html http://ec.europa.eu/europeaid/work/funding/index_en.htm NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 41 Country Goverment Organization Non-goverment Organization (NGO) WEB Japan JICA http://www.jica.go.jp/vietnam/english/ Korea S. KOICA http://www.koica.go.kr/english/board/new/index.html Liechtenstein LED http://www.led.li/en/home.html Luxembourg LUXDEV luxdev.lu/en Netherlands Dutch Aid www.dutchaid.net Centre for Safety and Dev. Netherlands http://www.centreforsafety.org/ Netherlands Cordaid http://www.cordaid.org/en/ Netherlands SNV World http://www.snvworld.org/ New Zealand NZAid http://www.aid.govt.nz/funding-and-contracts Norway NORAD http://www.norad.no/en/front-page Poland Polish Aid www.¬polishaid.¬gov.¬pl Portugal IPAD ns1.¬ipad.¬mne.¬gov.¬pt Saudi Arabia SFD http://www.sfd.gov.sa/ Slovakia Slovak Aid http://www.slovakaid.sk/ Spain AECID http://www.aecid.es/en/ Sweden SIDA http://www.sida.se/english/ Switzerland SDC http://www.sdc.admin.ch/ Switzerland Agha Khan Development Network http://www.akdn.org/akf_grantees.asp Switzerland International Red Cross www.icrc.org Switzerland Medecins sans Frontieres www.msf.org Taiwan ICDF http://www.icdf.org.tw UK DFID https://www.gov.uk/vietnam-business-challenge-fund UK Christian Aid www.christianaid.org.uk UK Helpage International http://www.helpage.org/ UK Oxfam http://www.oxfam.org/ USA USA USA USAID http://www.usaid.gov/work-usaid/get-grant-or-contract Adventist Dev. and Relief Agency Business Council for Peace http://www.adra.org/site/PageServer http://www.bpeace.org/ USA CARE http://www.care.org/ USA Five Talents http://www.fivetalents.org/ USA Giving Children Hope http://gchope.org/ USA Mennonite Central Committee http://www.mcc.org/ USA Save the Children www.savethechildren.org Trickle Up www.trickleup.org Vietnam International Development Ent. http://ide-vietnam.org/default.asp Vietnam World Vision International http://www.worldvision.org.vn/worldvision/index.php 42 - VIETNAM MICROFINANCE WORKING GROUP 2013 VMFWG MEMBER REGISTRATION In order to encourage policy dialogue between the relevant organizations to facilitate the development of a favorable environment for microfinance operations, and to promote sustainable microfinance by disseminating information, sharing experiences and achieving consensus on the important issues of Microfinance activities in Vietnam, VMFWG Board Members announces 2013 membership fee as below: I. Objectives • Enhanced the commitment of VMFWG members • Increase operational sustainability of VMFWG • Build trust and make commitment of VMFWG to donors. II. Criteria 1. Full member (FM) • Member code: FM2013_”No.” • Eligibility criteria: - The credit institutions are primarily performed some banking activities in order to meet the needs of individuals, low income households and Enterprise (according to the Law on deposit insurance) - Whose core activity is microfinance defined to include the provision of financial services (credit, savings, insurance, and money transfers) in a sustainable manner tailored to the needs of poor households; - Whose vision and mission statements include a commitment to server an ever increasing number of poor (grow and outreach) in a sustainable and efficient manner; - Willing to sign the VAMFI Code of Ethics, and contribute membership fees and time to join efforts; NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 43 - Willing to be independently audited and report data to VAMFI database. - Contribute ideas and suggestions for VMFWG meeting topics • Benefits: - Participate in monthly microfinance newsletter development and bulletin by providing data and articles - Have chance to connect, introduce to the donors, investors; - Join in research and survey implemented by VMFWG - Receive 01 Bulletin per year; annual report, Outreach map and Industry Profile; access to technical literature on website and library; - Notice by official correspondences about any changes in the organization (name, structure, title, etc...) - Eligible to vote at GA and nominate candidates for Council - Invited to all meetings, events and activities of VAMFI (training for a discounted fee); - Receive feedback on performance and benchmarking reports, access to MIX, eligible for Performance Award and VAMFI Certification when established - Pay the membership fees in time • Fee per year: 6,000,000 VND (six million dongs) 2. Observer member (OM) • Member code: OM2013_”No.” • Eligibility criteria: - Institutions/organizations/programs registered in Vietnam that provide microfinance services - Whose core activity, vision, or mission statement differ from microfinance as defined by VAMFI - Willing to be independently audited and report data to VAMFI database. - BDS/CB provider Directory - Support to access funds for capital and TA/CB - Annual research report, Social performance, Social audit. • Responsible: 44 - VIETNAM MICROFINANCE WORKING GROUP - Supportive of microfinance as defined by VAMFI and wishing to contribute to the development of sustainable microfinance in Vietnam • Benefits: - Have chance to connect, introduce to the donors, investors; - Receive 01 Bulletin per year; annual report, Outreach map and Industry Profile; access to technical literature on website and library; - Invited to GA, but no vote - Invited meetings, events and activities (training for fees) - Training Center-Support organization • Benefits: - Have chance to connect, introduce to the donors, investors; - Receive 01 Bulletin per year; annual report, Outreach map and Industry Profile; access to technical literature on website and library; - Invited to GA, but no vote - Invited meetings, events and activities (training for fees) - Access to publications, e.g BDS provider Directory, Training needs a s s e s s m e n t etc…at discount rates - Support to complete reporting to database and feedback on performance - Support to adopt Code of Ethics • Responsible - Contribute ideas and suggestions for VMFWG meeting topics - Participate in monthly microfinance newsletter development and bulletin by providing data and articles - Join in research and survey implemented by VMFWG - Notice by official correspondences about any changes in the organization (name, structure, title, etc...) - • Responsible - Contribute ideas and suggestions for VMFWG meeting topics - Participate in monthly microfinance newsletter development and bulletin by providing data and articles Pay the membership fees in time • Fee per year: 4,000,000 VND (Four million dongs) - Join in research and survey implemented by VMFWG • Member code: AM2013_”No.” - Notice by official correspondences about any changes in the organization (name, structure, title, etc...) • Eligibility criteria: - Pay the membership fees in time 3. Associate members (AM) - Capacity building providers, INGOs, donor programs, apex funds, insurance companies, software companies, private, public and state agencies, institutions and individuals that do not offer microfinance directly to clients; • Fee per year: 12,000,000 VND for Institution (Twelve million dongs) 1,500,000 VND for Individual (One million and five hundred thousand dongs) NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 45 III. Principles of VMFWG members fee management • VMFWG will open a separate account to manage the membership fee; • VMFWG members will transfer the membership fee to the account; • VMFWG membership fee account details will be published quarterly to fee paying members via email; • The use and allocation of membership fees will be published in the audited VMFWG annual financial report. VMFWG is looking forward to the participation of organizations and individuals interested in microfinance activities, through the membership registration by filling information on the registration form and send to VMFWG via e-mail, postal mail or fax. VMFWG will study the information of your organization/individual and inform the results to you within 14 days. For more information please visit our website: www.microfinance.vn 46 - VIETNAM MICROFINANCE WORKING GROUP THE UNIVERSAL STANDARDS FOR SOCIAL PERFORMANCE MANAGEMENT is a comprehensive manual of best practices created by and for people in microfinance as a resource to help financial institutions achieve their social goals. The Universal Standards can unite the industry behind a common approach to social performance management and enhance its reputation for responsibly serving people's financial needs “ There are almost as many tools and processes as there are stakeholders. The Universal Standards are the first and only achieved project that draws on the many processes in the field to create a unified structure and language for social performance management Jürgen Hammer, Grameen Crédit Agricole ” DEFINE AND MONITOR SOCIAL GOALS ENSURE BOARD, MANAGEMENT, AND EMPLOYEE COMMITMENTTO SOCIAL GOALS BALANCE FINANCIAL AND SOCIAL PERFORMANCE UNIVERSAL STANDARDS FOR SOCIAL PERFORMANCE MANAGEMENT TREAT EMPLOYEES RESPONSIBLY TREAT CLIENTS RESPONSIBLY DESIGN PRODUCTS, SERVICES, DELIVERY MODELS AND CHANNELS THAT MEET CLIENTS’ NEEDS AND PREFERENCES NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 47 1. Define and Monitor Social Goals 2. Ensure Board, Management, and Employee Commitment to Social Goals 3. Treat Clients Responsibly STANDARDS: STANDARDS: STANDARDS: A. The institution has a strategy to achieve its social goals. A. Members of the board of directors are committed to the institution’s social mission. A. The institution determines that clients have the capacity to repay without becoming overindebted and will participate in efforts to improve market level credit risk management. B. The institution collects, reports and ensures the accuracy of client-level data that are specific to the institution’s social goals. B. Members of the board of directors hold the institution accountable to its social mission and social goals. C. Senior management sets, and oversees implementation of, the institution’s strategy for achieving its social goals. D. Employees are recruited, evaluated and recognized based on both social and financial performance criteria. B. The institution communicates clear, sufficient and timely information in a manner and language clients can understand so that clients can make informed decisions. C. The institution andits agents treat their clients fairly andrespectfully and without discrimination. The institution has safeguards to detect and correct corruption as wellas aggressive orabusive treatment by their employees and agents, particularly during the loan sales and debt collection processes. D. The institution respects the privacy of individual client data in accordance with the laws and regulations of individual jurisdictions and only uses client data for the purposes specified at the time the information is collected or as permitted by law, unless otherwise agreedwith the client. E. The institution has timely andresponsive mechanisms for complaints and problem resolution for their clients and uses these mechanisms both to resolve problems and to improveproducts and services. 48 - VIETNAM MICROFINANCE WORKING GROUP 4. Design Products, Services, Delivery Models and Channels That Meet Clients’ Needs and Preferences 5. Treat Employees Responsibly 6. Balance Financial and Social Performance STANDARDS: STANDARDS: STANDARDS: A. The institution understands the needs and preferences of different types of clients. A. The institution follows a written Human Resources policy that protects employees and creates a supportive working environment. A. Growth rates are sustainable and appropriate for market conditions, allowing for high service quality. B. The institution designs products, services, and delivery channels in such a way that they do not cause clients harm. C. The institution’s products, services, delivery models and channels are designed to benefit clients, in line with the institution’s social goals. B. The institution communicates to all employees the terms of their employment and provides training for essential job functions. C. The institution monitors employee satisfaction and turnover. B. The insitution’s financing structure is appropriate to a double bottom line institution in its mix of sources, terms and desired returns. C. Pursuit of profits does not undermine the long-term sustainability of the institution or client well-being. D. The institution offers compensation to senior managers that is appropriate to a double bottom line institution. NOVEMBER /2013 - MICROFINANCE REGULATIONS IN VIETNAM - 49 2013 VIETNAM CITI MICROENTREPRENEURSHIP AWARDAS (CMA 2013) 2013 Vietnam Citi - Vietnam Microentrepreneurship Awards 2013 (CMA 2013) is an annual global activity, funded by Citi Foundation/ Citi Bank Vietnam to recognize and honor the microentrepreneurs with initiatives in using loans effectively, the outstanding credit officers and the typical microfinance institutions that have significantly contributed to the implementation of the Construction and Development of sustainable microfinance system Project in Vietnam until the year 2020, contribute to the reduction of poverty in the country. The CMA program has been held annually since 2007 by Vietnam Microfinance Working Group Vietnam (VMFWG) in coordination with Citi Foundation/ CitiBank Vietnam, Vietnam Small and Medium Enterprises Association (VINASME), and with the support of State Bank of Vietnam and Banking Academy. The CMA has recognized the contributions of 310 typical microentrepreneurs, 109 excellent credit staffs, and more than 40 typical microfinance institutions in Vietnam. Structure and value of the CMA 2013 Awards is as below: (The value of award includes taxes and charges in accordance with the State legislation) No. Award Quantity Value (VND) 1 The Excellent Micro-entrepreneur 1 15,000,000 2 Typical Micro-entrepreneur 29 10,000,000 3 Outstanding Credit Office 5 6,000,000 4 The most Excellent Microfinance Institution 1 100,000,000 5 The Second Excellent Microfinance Institution 1 50,000,000 6 Typical Microfinance Institution 9 10,000,000 7 The Small Microfinance Project Providing creative products and services 1 5,000,000 The list of winners is posted into the VMFWG’s website in November 11th 2013. The CMA 2013 is scheduled to be held on12/12/2013 in Hanoi. For more information, please contact us by: Website: www.microfinance.vn Tel: (84-4) 6269 1825 Email: bantochuccma2013@gmail.com 50 - VIETNAM MICROFINANCE WORKING GROUP The Vietnam Microfinance Working Group was established in 2004, with 87 members, as a forum for microfinance practitioners to share experiences, debate relevant issues and speak to policy makers with a unified voice. The VMFWG and its members share a vision to create “A large and dynamic microfinance industry of professional, sustainable and efficient institutions that offer unsubsidized, high-quality, and demand-responsive financial services to a growing portion of the poor and low-income population of Vietnam”. Vietnam Microfinance Working Group 4th floor, No,70, Alley 34, Hoang Cau Street Dong Da District, Hanoi City, Vietnam T: +84 4 6269 1825 F:+84 4 6282 2462 E:info@microfinance.vn Website: www.microfinance.vn