Sub-Saharan African countries may be leading the world in mobile money and growth in access to accounts, but the state of financial consumer protection in Africa is in urgent need of attention.
In the EIU Global Microscope’s 2014 overall rating of the policy environment for financial inclusion, African countries scored very close to the global average (44 SSA vs. 46 Global out of a possible 100). However, these countries were substantially below the average on consumer protection indicators – market conduct (27 SSA vs. 43 Global) and grievance redress (35 SSA vs. 45 Global).
These numbers have human consequences. The Smart Campaign commissioned research in two African countries – Benin and Uganda – which revealed the frequently harsh environment in which microfinance is conducted. In Uganda, research on what happens to clients who default showed that, lacking regulatory oversight and the calming influence of credit reference bureaus, lenders in Uganda feel compelled to resort to practices such as rapid confiscation of a borrower’s assets. They are afraid that if they do not act quickly, the borrower may flee. In the research on client experiences from Benin, clients reported major gaps in trust and transparency. For example, many reported being surprised by fees that were not explained or expected, having no place to turn when problems arose, or being publicly shamed for late payments.
The research pointed to very low trust on both sides between providers and customers. In fact, in Smart Campaign conversations with African microfinance institutions about consumer protection, one of the most frequently asked questions is, “Who will protect us (the lenders) from them (the borrowers)?”
Perhaps this problematic environment partly explains why of the 43 institutions certified for good client protection practices by the Smart Campaign, only one, Bayport Botswana, is in Africa. Quite a number of African MFIs have expressed interest in Smart Certification, and several have gone through certification missions. However, most scored relatively poorly, with a daunting list of items to be upgraded in order to pass.
In analyzing the experience of certification among African financial institutions, several observations stand out.
Onsite certifiers often find significant gaps between adopted policies and their field implementation. Procedures, staff training and internal controls – the internal elements that move policies into action – are often lacking, reflecting the overall institutional weaknesses of small financial institutions in the region. In many cases, complaints and grievance redress processes are either missing or dormant. These are correctable issues, but they take work. Certified institutions tell the Smart Campaign that one of the benefits from undergoing the certification process is that the certification analysis provides a detailed diagnostic of gaps in their internal processes and the impetus to close them.
More challenging are the difficult issues that may bite into the business models of the MFIs. These cannot be so easily resolved. Among them are issues connected with preventing over-indebtedness and promoting transparency:
- Business models that approve risky loans, such as automatic renewals, top-ups or step increases without repayment capacity review.
- Staff incentives that do not weight portfolio quality, leading to aggressive sales and risky loans.
- Non-transparent prices through practices such as bundling of credit life insurance or compulsory savings requirements.
In dialogue with the Smart Campaign, institutions assert that they cannot change such practices without losing customers or reducing revenue. This may or may not be true, but it’s hard to blame organizations for reluctance to try out changes that they fear risk significant hits to the business model.
One bright spot is the interest among regulators to improve the consumer protection environment. At the recent Alliance for Financial Inclusion (AFI) meeting in Mozambique, the Consumer Empowerment and Market Conduct Working Group was very active, with strong representation from eastern and southern Africa. However, given the pace of legal and regulatory change, jurisdictional gaps, and deficits in supervisory capacity throughout the region, it will be some time before effective consumer protection regulation is in place. Meanwhile, as credit and other services are added to expanding mobile money rails, new consumer risks are emerging, and African regulators will have even more on their plates.
As a movement grounded in the industry, the Smart Campaign will continue to work with African financial institutions, associations and regulators to highlight the urgency of the need and to strengthen practices.
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