Regulating Agents: Who is liable for the agent?

Microfinance and Technology
Building Operational Solutions for Microfinance and SME Projects
May 24, 2010
CGAP Technology Program
14 projects in 10 countries, 13 policy diagnostics
• Research, policy, advisory and grant funding
• Learning and knowledge sharing
• Co-funded by the Bill & Melinda Gates Foundation, CGAP and
the UK Department for International Development
• Find us online at http://www.cgap.org/technology
What we do
• Demonstrate innovation and scale in branchless banking projects resulting from CGAP’s technical
assistance and/or grant funding.
• Improve broad industry knowledge and practice in the areas of customers, agents, business models and
regulatory frameworks.
• Harness existing government payments and remittance flows to provide banking services to large numbers
of unbanked people.
• Help policymakers develop regulations that support effective use of mobile technologies for financial
inclusion.
What are the factors that limit access?
Long distances & low pop density
High bank costs relative to income
Low education & illiteracy
Poor product/ channel design
Branchless banking may
overcome these constraints
Branchless Banking: What do we mean?
“… delivery of financial services outside conventional bank branches using
information and communications technologies and nonbank retail agents.”
Bank
Credit/Debit
Client
Account
MNO
Debit /Credit
Agent
Account
Agent
Cash in/out
Receipt/
Cash
Client
The logic of branchless banking
Use existing retail
infrastructure
Use existing deployed
technology
Huge potential
•
•
•
1.7 billion unbanked customers with mobile phones by 2012
Case of India: 400 million SIMs, 15 million new mobile users added
every month, 70% of population has access to mobile telephone
networks
Only 55 million bank accounts out of 1.15 billion population
Out of scope
No known deployments
1 known deployment
2 known deployments
3 known deployments
More than 3 known deployments
CGAP-GSMA Mobile Money Market Sizing Study
The power of using existing infrastructure
~3.5bn
~28m
Worldwide points of presence
250k
Western
Union
500k
Bank
branches
~1m
665k
Post
offices
ATMs
POS
Mobile
Phones
Options for reducing cost of banking infrastructure
$250,000
Traditional
branch
$50,000
Branch
in store
$10,000
ATM
$2,000
Agent with
POS terminal
$400
Agent with
mobile
$0
No agent
(cashless)
The case of Brazil: bank-based model
Overview
The case of Brazil: bank-based model
• Agents replaced branches as #1 service point of the banking
sector
The case of Kenya: a nonbank-based model
Overview
Regulating agents: Who is permitted to act as an agent?
Regulating Agents: Approval needed to work as an agent
Regulating Agents: Who is liable for the agent?
Regulating Agents: Liability
MFIs and Mobile Banking
Typology of MFIs in mobile banking
CONTEXT:
ROLE OF
MFI:
MFIs in countries with no existing
mobile banking infrastructure
Build
mobile
banking
system
Use
phones for
data
collection
and other
non-cash
purposes
MFIs in countries with existing
mobile banking infrastructure
Use m-banking
system for loan
disbursements/
repayments
and/or deposits
Act as agent on
behalf of bank
or MNO
Advancing financial access for the world’s poor
www.cgap.org
www.microfinancegateway.org