Draft
3.0
concept
note
3
b)
The comparison in the microfinance sector is the increasing use of securitization of microcreditloan portfolios. This suggests a potential misalignment in incentives for those who originate theloan to ensure creditworthiness. While there are mechanisms to mitigate these (ICICI Bank forexample, ensured that originators of securitized microfinance loans were also subject to a firstloss default guarantee (FLDG)), they are limited in scope.c)
Besides securitization, there also exist potential incentive misalignments in loan origination thatutilizes a principal-agent method on the ground, when brokers originate loans which are kept onanother institution’s balance sheet.
Lending has increased indebtedness and leverage for consumption purposes instead of investmentpurposes.
a)
The availability of cheap credit for subprime clients led to reckless refinancing as house pricesrose, for the purposes of consumption rather than investment.b)
In microfinance, the claims that loans are fed to enterprises or income-generating activities ratherthan consumption-smoothing or income-smoothing activities may be overstated. Thesusceptibility of such clients towards debt traps needs to be carefully examined.
Disparate regulation for banks, non-bank financial institutions, mortgage-agents etc
11
leads to lackof appropriate oversight.
a)
For example, the US financial regulatory system permits mortgage lenders to move risk to wherecapital charges are lowest and regulatory scrutiny is lightest
12
.b)
The opacity and disparity of regulation also exist in microcredit markets where banks, and non-bank financial lenders that originate similar loans are regulated differently in domestic markets.The global market for investors that invest in microfinance institutions are largely self-regulatedat the moment, though there is movement towards adopting a common set of principles (seePocantico Declaration.)
Consumer protection is limited
a)
Predatory subprime lenders in the US have misled borrowers and convinced them to take outloans that they did not understand or that carried inappropriate risks. Subprime borrowers arepredominantly minority, lower income, less well financially educated and less likely to search forthe best interest rates and terms for their mortgage loans
13
.b)
These characteristics, particularly regarding financial literacy is true in microcredit markets. Inaddition a commonly cited practice has been fee packing, where excessive processing fees areincluded in the balance of the new loan. In microcredit, while many countries have pushed tohave transparency regarding
effective
interest rates (i.e. including fees etc.), more can be done toensure that the consumer is fully informed about loans.
R
ECOMMENDATIONS
FOR
M
ICROCREDIT
MARKETS
11
Ibid.
12
Ibid.
13
Ibid.
Leave a Comment