Support Our Work

Subscribe to our bi-monthly newsletter for the latest blog posts, report releases, fellowship and research opportunities and CFI news.

Fellow Exec Ed

Blog Post

The Economist Intelligence Unit’s <a href="https://centerforfinancialinclusion.org/global-microscope-2019/">Global Microscope</a> is a robust data set that offers a deep dive into the policies and regulations that are considered important for financial inclusion in 55 countries. The indicators are derived from an expert-based consultation process to identify the most likely policy and regulatory conditions under which financial access and usage is likely to thrive.

The Microscope’s approach is to bundle the indicators into an index so that performance across countries can be compared easily. It also allows the EIU to simplify a set of complex conditions in which no one indicator can sufficiently signal a country’s environment for financial inclusion. Using an index approach to aggregate the indicators has both positive and negative implications. On the positive side, it simplifies a complex set of variables into a score than can easily be understood; a low score is bad and a high score is good. An index also creates a certain level of competition among countries that are covered in the index. Like with other indices that use this approach, such as <a href="https://openknowledge.worldbank.org/bitstream/handle/10986/32436/9781464814402.pdf">Doing Business</a>, many countries put resources behind improving their score year in and year out. The ranking serves as motivation for action.
<blockquote>An index allows the EIU to simplify complex conditions in which no one indicator can signal the environment for financial inclusion.</blockquote>
On the other hand, there are several drawbacks with the use of indices for something as complex as the policy and regulatory environment in a country for financial inclusion. The first drawback is squaring the results with the evidence on the ground. According to the EIU’s Microscope, Colombia has the highest score, 82, in the enabling policy and infrastructure index, yet Colombia’s access figures from the <a href="https://globalfindex.worldbank.org/">2017 Global Findex</a> shows that the country’s financial access is only 46 percent for adults over 15. This is significantly lower than the global average of 69 percent and lower than the 63 percent average in developing countries. A country like Bangladesh is ranked very low in the Microscope (38), but has higher access figures than Colombia, reaching 50 percent in the latest Findex round.

So why is there such a disconnect between a country’s ranking on Microscope with its access and usage data from Findex? It shouldn’t surprise anyone that the reality on the ground can lag behind regulations. For example, while the US has equal-rights legislation on the books, experience among minorities in the US confirms frequent and continued discrimination in practice. So it isn’t a surprise that even though some countries have favorable policy and regulatory conditions for financial inclusion, there may be cultural issues or social norms that aren’t in line with the regulatory change and may require time and additional effort to change. Change may also require enforcement or supervisory capacity to ensure that there’s compliance with policies and regulations.

But perhaps more importantly, policies and regulations are only part of the financial system, and financial service providers and the users of the financial system have many other influences on their choices and behaviors. If we’re only looking at the policy and regulatory viewpoint, we’re not seeing the full picture of what drives outcomes on the ground.
<blockquote>If we’re only looking at the policy and regulatory viewpoint, we’re not seeing the full picture of what drives outcomes on the ground.</blockquote>
The second drawback is lack of clarity on which policies actually matter. The Microscope tracks five domains with a total of 69 indicators. Each of these indicators has an equal weight in the score. But is it true that each indicator is equally likely to drive inclusion? The Microscope doesn’t do enough to help countries prioritize from among the 69 indicators it tracks. For example, in the new indicators on women’s financial inclusion, variables such as “non-discriminatory access to IDs” and “differences in access to a mobile phone between men and women” are included as indicators. How important is one or the other towards women’s financial inclusion? When everything is important, nothing is. The index may be inadvertently contributing to either paralysis or misguided prioritization by policy makers.
<blockquote>The Microscope doesn’t do enough to help countries prioritize from among its 69 indicators.</blockquote>
Regulators and policy makers are looking for evidence on what works to drive financial inclusion. This is where there is potential for researches and EIU to take this important data set and do additional analysis to identify which of the indicators correlate with results on the ground. The <a href="http://documents.worldbank.org/curated/en/926401524803880673/pdf/125804-PUB-REPLACEMENT-PUBLIC.pdf">World Bank’s Women, Business and the Law 2018</a> publication did a deep dive on financial inclusion which did this type of analysis linked to women’s financial inclusion, for example

While correlations have their own set of limitations, they are nonetheless a step closer to helping us unpack which policies and regulations are priorities to drive inclusion. In the next round of the Global Microscope, we’d like to see less emphasis on rankings and much more effort devoted to helping policy makers understand which policies and regulations should be prioritized.

What’s in a Score? Reconciling Financial Access and Usage With the Microscope Rankings

With the expansion of digital financial services (DFS) for the underserved, policymakers and regulators must set the conditions to allow innovative financial products to flourish while providing the market guardrails that ensure customers, especially those accessing financial services for the first time, can access DFS with confidence and adequate protections.

According to the World Bank’s most recent Global Financial Inclusion and Consumer Protection Survey, more than 95 percent of the 124 respondent jurisdictions have some kind of <a href="https://openknowledge.worldbank.org/bitstream/handle/10986/28998/122058.pdf?sequence=5&amp;isAllowed=y">financial consumer protection legal framework</a>. Other studies, such as the <a href="https://centerforfinancialinclusion.org/global-microscope-2019/">Global Microscope</a> series and the World Bank's <a href="https://openknowledge.worldbank.org/bitstream/handle/10986/28996/122011-PUBLIC-GoodPractices-WebFinal.pdf?sequence=1&amp;isAllowed=y">Good Practices for Financial Consumer Protection</a>, have demonstrated that legal and regulatory responses to consumer protection risks have been strengthening over time. Such developments are important accomplishments and demonstrate the prioritization of consumer protection as an enabler of financial inclusion. However, our work doesn’t stop there.
<h2>The Opportunity</h2>
Not all financial consumer protections frameworks are effective in addressing key consumer protection risks for the financially excluded. In some cases, elements of such frameworks may even impede financial inclusion goals. Common challenges include legal and regulatory gaps, disproportionate (non-risk-based) interventions, inconsistent oversight, competing or overlapping regulatory mandates, and the inability or lack of enforcement. These challenges are exacerbated by a rapidly changing sector where digital technologies have introduced new providers, products, business models and delivery channels. Appropriate legal and regulatory responses can help to mitigate new and evolving risks while promoting responsible inclusive finance, stronger markets, and better served clients.
<h2>Our Contribution</h2>
To address the demand for practical resources to promote strong legal frameworks for responsible inclusive finance, CFI, DLA Piper’s global pro bono initiative, New Perimeter, and the legal team at Accion developed the <a href="https://centerforfinancialinclusion.org/handbook-on-consumer-protection-for-inclusive-finance/">Handbook on Consumer Protection for Inclusive Finance</a>. Organized around the <a href="https://www.smartcampaign.org/about/smart-microfinance-and-the-client-protection-principles">Client Protection Principles (CPPs)</a>, the Handbook expands on its predecessor, the <a href="http://smartcampaign.org/tools-a-resources/1049-model-law">Model Law and Commentary for Financial Consumer Protection (Model Legal Framework)</a> to address the unique characteristics of digital financial services. It’s informed by CFI's <a href="https://www.centerforfinancialinclusion.org/consumer-protection-in-a-digital-age">Consumer Protection Standards for Digital Credit</a>, which provide a shared set of practices for responsible digital lending through a provider lens, and updated Guidance for these standards. It also reflects consultation with experts and practitioners, experience from our work with regulators and financial service providers (including fintech companies), research on 19 regulatory environments, and guidance issued by international organizations and collaborative working groups.

The Handbook complements existing tools and guidance by distilling recommended legal and regulatory approaches for financial consumer protection into illustrative and user-friendly model language with explanatory commentary. Like the Model Legal Framework, the Handbook is intended for a broad range of stakeholders and is designed to be used in several ways: to develop or revise financial consumer protection legal frameworks, to serve as a diagnostic tool to assess existing frameworks, and to support dialogue and collaboration between government and industry.
<blockquote>The Handbook distills recommended legal and regulatory approaches for financial consumer protection into illustrative, user-friendly language and commentary.</blockquote>
<h2>What’s New?</h2>
The Handbook comprehensively updates the Model Legal Framework, including new and revised provisions and commentary related to DFS. It significantly expands recommendations regarding the privacy and security of consumer data, which traditional consumer protection frameworks may not address or where standalone data privacy regimes do not exist. In addition, the Handbook advocates for strong internal controls in the design process for products, services and delivery channels to support the concept of “consumer protection by design” in addition to monitoring consumer outcomes. It also tackles questions around algorithm-based lending, transparency safeguards for digital interfaces, third-party accountability, fraud, and coordination among supervisory authorities with converging regulatory mandates, among other topics.

No single resource can address every issue relevant to financial consumer protection, but the Handbook focuses on key areas of consumer risk based on consensus in the responsible inclusive finance ecosystem. As recommendations around strong consumer protection policy continue to evolve, so too will future editions of the Handbook, and we welcome your comments and feedback.

New Handbook Addresses Demand for Practical Legal Resources About Consumer Protection in a Digital World

News

The <a href="https://www.elespectador.com/economia/colombia-lidera-entorno-para-la-inclusion-financiera-regional-articulo-888988">article</a> (in Spanish) notes that Colombia -- along with Peru, Uruguay and Mexico -- lead the <a href="https://centerforfinancialinclusion.org/global-microscope-2019/">Global Microscope 2019</a> rankings this year. Supported by CFI and the Bill &amp; Melinda Gates Foundation, an updated Microscope is published every year by the <a href="https://www.eiu.com/n/">Economist Intelligence Unit</a>. It assesses the enabling regulatory environment for financial inclusion in 55 countries worldwide.

<a href="https://events.iadb.org/calendar/event/20252?lang=en">FOROMIC</a> is hosted by the Inter-American Development Bank (IDB).

In El Espectador: CFI, Mayada El-Zoghbi Mentioned in Microscope Coverage

Report

Regulators play a significant role in catalyzing or impeding a country’s progress toward financial inclusion. By evaluating five domains of the regulatory environments in 55 countries (i.e., government and policy support, stability and integrity, products and outlets, consumer protection and infrastructure), the Global Microscope identifies each country’s current policies and regulations and notes which are likely to create an enabling environment for financial inclusion.

The 2019 Global Microscope features 11 new gender-focused indicators that measure financial inclusion for both women and men. These new indicators can help policymakers identify areas that could potentially improve women’s ability to access and use the financial tools they need to thrive.

The Global Microscope is produced by The Economist Intelligence Unit with policy guidance and financial support from leading organizations in the field, including CFI.
<h2>Major Findings</h2>
<ul>
 	<li>The enabling environment for financial inclusion has improved in the 55 countries covered in the Global Microscope 2019. Colombia, Peru, and Uruguay maintained the top rankings again this year. Likewise, the countries covered in the study’s regional analysis of Latin America and the Caribbean maintained the most favorable regulatory environments. These findings are at odds with access and usage data that show that Latin America and the Caribbean have recently fallen behind other regions. This points to the limitations that policies play in driving outcomes. They can contribute, but policies alone are insufficient in driving desired outcomes.</li>
 	<li>Practical impediments – such as limited access to identification, the Internet, and/or mobile phones – restrict women’s ability to use digital financial services.</li>
 	<li>Argentina, Costa Rica, Honduras, Russia, and other countries continue to adopt financial inclusion strategies and incorporate digital approaches to foster inclusion. In the past, national-level programs have led to the most progress over the short and long term.</li>
 	<li>Consumer protection and privacy laws are evolving to respond to the unique challenges that fintech presents, but few countries have updated their consumer protection regulations to account for the risks posed by digital players.</li>
</ul>
<h2>Calls to Action</h2>
<strong>Policymakers must ensure that both women and men are enabled to utilize and empowered benefit from greater financial inclusion.</strong> As the landscape for financial inclusion continues to evolve, and as financial service providers adopt new technologies and approaches, governments will need to implement policies to ensure that potential users develop the necessary capabilities and possess key enablers to access and use these products (such as national ID and mobile phones). This includes developing and implementing policies specifically designed to address gender disparities in access to these enablers.

<b>Governments must ensure their national strategies do not worsen the gender gap.</b> As financial inclusion policy shifts its focus towards the promotion of digital financial services, regulators and policymakers must address this digital gender gap or risk contributing to even greater disparities in access to financial services between women and men. Although nearly four-fifths of countries in the Microscope have strategies or initiatives to promote digital literacy, only one-fifth incorporate a gender approach into these programs.

Global Microscope 2019: The Enabling Environment for Financial Inclusion

Find Hema Bansal at ADB’s Fintech Bootcamp as well as the 3rd Asia Finance Forum that follows.

Event

Hema Bansal is presenting at two events at the 3rd Asia Finance Forum:
<h2>Fintech Bootcamp
Monday, November 4, 2019 3:30-5:00pm</h2>
Financial inclusion is increasingly driven by fintech firms independently, or in partnership with banks. Although financial services delivery models differ across countries, digital financial services have shown promising financial inclusion outcomes. There is little evidence, however, that these services are being delivered responsibly, increasing the potential risks to clients.

The Center for Financial Inclusion’s (CFI) <a href="http://smartcampaign.org/about/smart-microfinance-and-the-client-protection-principles/digital-credit-standards">Smart Campaign digital credit standards</a> address risks to consumers, particularly those arising from new digital products or channels. At the Fintech Bootcamp, we will share these standards, which address a wide range of risks clients are exposed to when accessing digital credit, including but not limited to data privacy and security, over indebtedness, and lack of transparency. They are meant to guide both fintechs and traditional financial service providers undergoing digital transformation. We will also share CFI’s approach to building the financial capability of consumers in accessing digital financial services.

Hema's session will cover the following:
<ul>
 	<li>Responsible standards for digital credit design and delivery</li>
 	<li>Adaptability of responsible digital credit standards nationally and regionally</li>
 	<li>Financial capability approaches</li>
 	<li>Strategies for embedding responsible finance in digital financial services at the country level</li>
</ul>
<h2>Inclusive Finance: Combining Fintech Innovation, Public-Private Collaboration, and Responsive Regulation to Reach the Poorest
Wednesday, November 6, 2019 9:20-10:30am</h2>
Lack of financial and digital literacy is a major reason for lack of access to finance for women and in rural communities. Policies to enhance financial inclusion, especially through technology, should involve more active financial literacy and educational programs.

Learn about new products and services, players, and channels that address the essential need of financial literacy to reach the underserved and unbanked and drive the shift from financial access to financial usage.

Moderator: Lotte Schou-Zibell, Regional Director, Pacific Department, ADB

Panelists:
<ul>
 	<li>Hema Bansal, Senior Director, The Smart Campaign, Center for Financial Inclusion at Accion</li>
 	<li>Peter Morgan, Senior Consulting Economist and Vice Chair for Research, ADB Institute</li>
 	<li>Anil Gupta, Partner – Payments and Distribution, Microsave Consulting</li>
 	<li>Grace Tan, Head of Corporate Communications, Visa Inc.</li>
</ul>
&nbsp;

&nbsp;

3rd Asia Finance Forum

Board effectiveness executive education for social enterprise leaders

Board Leadership for Impact Program

We provide management and leadership training to executives shaping the financial inclusion industry.

HBS-Accion Program on Strategic Leadership in Inclusive Finance

Become a fellow to pursue the big, unanswered questions facing the financial inclusion community.

CFI Research Fellows Program

Fellowships and Executive Education

Industry Engagement

For equity investors committed to financial inclusion and seeking at least a double bottom line

Financial Inclusion Equity Council

For researchers, financial services providers and policymakers to advance the conversation and toolset on financial health

Financial Health Community

For CEOs of MFIs committed to accelerating repsonsible financial inclusion

Partnership for Responsible Financial Inclusion

For fintechs and digital financial service providers committed to consumer protection

Fintech Protects Community of Practice

Institutional partnerships make our work possible. 

Partner With Us

As a non-profit organization, your donations help us achieve our mission.

Donate

Building practical knowledge and human capacity, we work to deepen and sustain financial inclusion.

We support, convene and engage industry stakeholders to help make financial inclusion a lasting reality.

Mayada El-Zoghbi

Using an index to score complex policy and regulatory environments has its pluses and minuses. 

Jessica  Galimberti

Learn More

The Handbook on Consumer Protection for Inclusive Finance fills a void created by legal and regulatory shortcomings, inconsistent oversight, competing or overlapping regulatory mandates, and the inability or lack of enforcement. 

A leading Colombian news outlet features a photo of the CFI Managing Director speaking at FOROMIC, an annual conference on microfinance and entrepreneurship in the Latin American and Caribbean region. The Global Microscope 2019 was formally unveiled at the conference. 

The Global Microscope 2019 assesses the enabling regulatory environment for financial inclusion in 55 countries. The 2019 edition features 11 new gender-focused indicators that measure financial inclusion for both women and men.

Hema Bansal is presenting on responsible digital credit at the pre-forum Fintech Bootcamp, and speaking on a panel during the main Forum on turning access to usage through financial and digital literacy.

Get Involved

Partner With Us

Donate

Fellowships and Executive Education

Industry Engagement

Support Our Work

Quick Links

Partner With Us

Donate to the Center for Financial Inclusion at Accion

Quick Links

CFI Inclusions + Blog Digest Newsletter

Fellowships and Executive Education

Board Leadership for Impact Program

HBS-Accion Program on Strategic Leadership in Inclusive Finance

CFI Research Fellows Program

Industry Engagement

Financial Inclusion Equity Council

Financial Health Community

Partnership for Responsible Financial Inclusion

Fintech Protects Community of Practice

Stay informed. Subscribe to our newsletter.