With around 20 million borrower accounts estimated for March 2012, India still has one of the largest microfinance industries in the world – even though the number is much lower than 32 million in October 2010 when the microfinance crisis began. However, in March 2012 it also had the dubious distinction of having perhaps the worst portfolio quality in the world (at the national level). Since October 2010 commercial bank lending to MFIs, which made up over 70% of their funding, has been consistently drying up mainly because of perceived political risk.
Over the past 18 months since the crisis began, stakeholders in the microfinance industry – policymakers, commercial banks, academic institutions, investors and MFIs – have debated and introspected, conducted studies, assessments and yatras, reaching out to clients and analyzing the issues and problems of the industry.
In December 2011, M-CRIL released a report on the industry, the findings of which were amongst the topics discussed on 4 April 2012 at a Seminar on Risk in Indian Microfinance at the College of Agricultural Banking, in Pune, India. The college is a training and research unit of the Reserve Bank of India (RBI), the country’s central bank. The seminar took stock of the condition of MFIs in India since the AP intervention and the actual and potential future impact on the industry of the regulatory measures announced by the RBI over the past few months. A number of issues emerged.
In March 2010, banks provided 71.3% of the average Indian MFI’s funds and this is estimated to have risen to over 75% by October of that year. While over 75% of MFI funds were invested in portfolio when the crisis broke in October, the decline in bank funding since then has meant that MFIs have had to shift their fund use increasingly into portfolio resulting in the deployment of 88% of funds in portfolio as early as March 2011. In spite of this shift, overall portfolios have been declining and, by March 2012 were down to half the October 2010 level as shown by M-CRIL’s index (see graph 1).
At the risk seminar earlier this month, the main message was that MFIs are an integral part of the financial inclusion architecture and have a role to play in providing financial services to low income families. Yet, due to the high growth of 2008-10 and the events surrounding the SKS IPO and the subsequent action of the AP government, MFIs are perceived as being risky propositions for banks and investors. Amongst the risks discussed were:
Leadership risk: One major perception of participants was that the problems of the industry stem largely from a failure of leadership with the wide range of financial sector risks having become subservient to individual egos and the pursuit of short term monetary gain. There was concern that the lessons of the crisis have not been adequately learned and that some of the leading MFIs had not yet done enough to strengthen internal controls and inculcate a commitment to client protection in all aspects of their operations.
Reputational risk: The public perception that MFIs have experienced mission drift and do not have adequate social motivation has affected commercial bank lending to them. All MFIs are painted with a single brush without consideration of the diverse performance and motivations of organizations in the industry.
Regulatory risk: The regulatory framework announced by the RBI so far has significant costs of compliance. This includes the cost of (i) assessing borrower incomes to ensure that clients fall within the limits set by the RBI, (ii) verifying indebtedness levels through credit bureau checks, (iii) checking loan use to ensure that the money is actually invested in productive assets, and (iv) verifying compliance with codes of conduct through independent assessments.
How does the MFI bear such costs with shrinking margins, and what are the features of compliance that are working and those which are impractical? For example, the regulation says that no family that has an outstanding loan of Rs 50,000 (US$1,000) should be provided with additional loans. How does the MFI monitor and capture this information when many loans are through informal sources including borrowings from friends and relatives of which there is no record? The point was made that this regulatory approach entailed such a degree of micro-management that it could lead to the exclusion of measures such as varying prudential capital requirements based on degrees of geographical saturation in relation to levels of financial inclusion.
An inverse relationship can be established between levels of inclusion in a region and the amount of capital required to under-pin lending in that region. A more nuanced approach to various aspects of regulation would result in a more practical application of client protection than is possible at present.
Risk of developing a “herd mentality” or monoculture: The MFI industry has suffered from a culture that promoted the development of a single “plain vanilla” product and working in what became key hotspots leading to saturation of outreach and excessive lending to individual families. There is a need to develop a wider (if still limited) range of credit products along with the measures to introduce greater transparency, indicated above.
Dear Sanjay Sinha and Shweta Banerjee
A good anatomy on micro credit services has been done. In this regard I would like to share my views on the anatomized body of facts in the micro finance theatre.
First, although the anatomy on risk in commercial banks’ lending to MFIs delves in details, it deals with micro credit only. where as India’s MF industry represents more wider MF services besides micro credit and of late this industry is moving from micro credit to microfinance with integrated services having more potential for poverty cure with many actors besides commercial banks and MFIs. To me therefore, it appears only a partial probe for MF industry as whole as referred to, due to the fact that micro credit represents one component of micro finance services and further even the anatomy on risk on micro credit has been done only on supply side.
Secondly, even in the anatomy on risk, related to micro credit, covers only institutional aspects in supply system. It is no doubt necessary for credit rating agency . However for a prudent risk analysis more particularly for micro credit, it is inadequate since the rudimentary factors for the risk element could be discreetly located more in the demand side anatomy particularly while the micro credit is actually functioning or handled or managed by the poor borrowers in the process of productive utilization at field or household level. Further as a chain effect, these demand side risk factors also add fuel to fire further aggravating the intensity of supply side risks factors.
Third, related to anatomy on the demand side of micro credit, two basic factors , to be reckoned with risk in the anatomy process, are ‘capability differentials’ of the target clients in pyramid and ‘physical potential of the given area’ for credit absorption for avoiding over heating and saturation. In most of the institutional analysis , these demand side risk factors were blindly assumed and indiscriminate lending and multiple borrowing without any credit planning and discipline resulted in chaotic scenario in this industry and pathetic situation for the poor borrowers’ house hold as witnessed in Indian MF crisis .
Fourth, demand side anatomy , as emphasized above, assumes an important role for MFIs in general and NBFC-MFIs in particular in the context of adherence to RBI’s mandatory portfolio keeping 75% of loan for income generation activities recognized under priority sector norms (followed by commercial banks)
In fine, for avoiding risk of developing ‘herd mentality or mono culture with single plain vanilla product, it has been rightly pointed out for the need to go for wide range of credit product with transparency etc., Here again, it is an imperative need to have wide range of micro finance products flavored with multiple tastes ( diversified and integrated – credit plus services ) matching to the needs of the poor clients in the pyramid and not necessarily confining to micro credit only. But again development of such wide range of product cannot be done in vacuum but it demands prudential local area credit planning and assessment of area potentials for productive absorption . Here ‘capability building’ for both the MFIs and the target group borrowers for the said task assume importance..
Rating agency does very useful services in finance industry . However, in this given context with MF industry moving from micro credit to benign micro finance services for the poor, rating agency also may take cognizance of all MF integrated services and consider due weights /ratings accordingly so that the lending institutions may be alert and take initiatives for serving with integrated services( more particularly insurance among others) to the poor for enhancing their welfare on the one hand and risk reduction in PAR/RWA for lending institution on the other hand.
Thank you for sharing my views