MINUTES OF MICROLENDING INDUSTRY MEETING

DATE: MONDAY, 9TH MARCH 2020,

VENUE: NAMIBIA INSTITUTE OF PUBLIC ADMINISTRATION (NIPAM),

WINDHOEK

TIME: 09H00 A.M.

1. WELCOMING REMARKS

Mr. Marvin Daniels, Manager: Conduct and Compliance, welcomed everybody present
and announced that all attendees should ensure that they complete the attendance
register.

Mr. Daniels informed the attendees that he will be the master of proceedings for the
meeting. He guided the attendees through the meeting agenda. The minutes of the
previous meeting was adopted without amendments and thereafter he introduced
Ms. Hilka Alberto as the person responsible for the welcoming remarks.

Ms. Hilka Alberto, the General Manager of the Market Conduct Division, welcomed
everyone to the industry meeting. The welcoming remarks, which were made under the
theme “Promoting orderliness within the Microlending Industry”, are attached hereto as
Annexure B.

2. ATTENDANCE REGISTER

Kindly see the attendance list attached (Annexure A) for details of industry participants
who attended the meeting.

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NAMFISA STAFF PRESENT

Ms. Hilka Alberto General Manager: Market Conduct Division

Mr. Marvin Daniels
Mr. Vilho Nkandi
Ms. Alma Mavenjono
Ms. Lucrecia L. Lombardt
Mr. Samuel Zeraua
Ms. Marion Shumane
Ms. Ngajozikue Ndjoze
Ms. Suoma Kapadhi
Mr. Alfred Van Rooi
Mr. Josef Kadhila
Manager: Conduct and Compliance Department
Manager: AML and Inspections Department
Manager: Consumer Complaints and Education
Senior Financial Analyst: Conduct and Compliance
Senior Financial Analyst: Conduct and Compliance
Financial Analyst: Conduct and Compliance
Trainee Financial Analyst: Conduct and Compliance
Regulatory Analyst: Conduct and Compliance
AML: Compliance Officer
AML: Compliance Officer

3. ADOPTION OF PREVIOUS MINUTES OF 8 MARCH 2019 IN WINDHOEK

Mr. Ronald Weber (Finaid Financial Services (Pty) Ltd) proposed the adoption of the
minutes of the previous industry meeting. Mr. David Lewies (Focus Finance (Pty) Ltd)
seconded this proposal. The majority of the attendees indicated they had received the
minutes, however, only a small number of attendees indicated that they went through the
minutes. Mr. Daniels reiterated the importance for the attendees to consider and read the
minutes when they are forwarded to them. This should be done before the meeting for
ease of adoption of these minutes.

4. MATTERS ARISING FROM PREVIOUS MEETING OF 08 MARCH 2019

4.1. UPDATE ON LEGISLATION

4.1.1. Penalty Regulation

Mr. Daniels informed the meeting that a Circular was distributed to the industry pertaining
to the draft penalty regulations in 2017. The purpose of the Circular was to solicit
comments and input from the industry relating to the penalty regulation. He indicated that
another Circular was circulated in 2018 relating to the same penalty regulation, which

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again solicited comments and input from the industry.

Mr. Daniels explained that the penalties provided for in the regulation will be applied or
imposed if provisions in the Microlending Act are contravened. Penalties are structured
as per the following categories based on the value of annual loans disbursed:
 Category A: N$1 to N$10 million
 Category B: N$10 million to N$100 million
 Category C: N$100 million and more

He further mentioned that the importance of this categorization was that for each
contravention a maximum amount is prescribed as a penalty fine, which may be imposed
on any microlender in that particular category

Mr. Daniels also highlighted that NAMFISA reconsidered the penalty regulation in 2018
because of the comments and input from the industry. He highlighted two of the
comments that were received from the industry, and which influenced the decision to
reconsider the regulation. The first comment was a recommendation that the regulation
should refer to "the annual value of loans disbursed by a microlender in the immediately
preceding financial year". It therefore means that for a microlender to be in a particular
category, it requires the Regulator to look at the loans disbursed for the previous year.
The Regulator incorporated this in the penalty regulation.

Another comment from the industry related to the severity of the misconduct, as it stated
that "misconduct should be categorized to determine which of them are more severe
than others and in so doing prescribe appropriate maximum penalties". This would
warrant that the penalties be categorized according to a matrix in respect of the severity
and the potential impact a particular contravention may have on borrowers and the
industry at large.

Mr. Daniels applauded the industry for the type of comments received. He also informed
the meeting that the regulation was re-drafted and the new categories based on the
nature of the contravention are as follows:

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Section 23 Offences

Schedule 1- Daily Penalties of 10% of annual value of loan disbursements divided by

either 12 months or 365 days.

Schedule 2- Once off Penalties of 10% of annual value of loan disbursement (AVLD) or
10% of AVLD divided by 12 months or 10% of AVLD divided by 365 days multiplied by
the number of contraventions.

Section 24 Offences

Schedule 3 – Once off Penalties of 10% of AVLD or 10% of AVLD divided by 12 months
or 10% of AVLD divided by 365 days multiplied by the number of contraventions.

Mr. Daniels provided an example of a microlender with an AVLD of N$500,000.00 10% of

the aforementioned AVLD is N$50,000.00. If this microlender committed a contravention
that requires the percentage of the AVLD to be divided by 12 months, it would result in a
penalty of N$4,166.67. If the microlender committed a contravention that requires the
percentage of the AVLD to be divided by 365 days, it would result in a penalty of
N$136.98. If it is a daily penalty, the aforementioned amounts will have to be multiplied
by the number of days that the contravention persisted.

Mr. Daniels reminded the participants that they were requested to note their questions
and ask the questions at the end of each presentation.

4.1.2. Microlending Act Standards Issued

Mr. Daniels informed the meeting that two (2) standards were gazetted on the 12th
September 2019 and additional three (3) were gazetted on the 25th February 2020. He
urged the industry to ensure that they take cognizance of the issuing of standards and
regulations or amendments to any law that pertains to the microlending industry.

He informed the meeting that there were five (5) Standards gazetted which pertains to:
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 1. applications for registration as a microlender (and re-registration for microlenders
that were registered under section 11);
2. fit and proper criteria;
3. submission of returns;
4. form and content of the affordability assessment; and
5. The terms and conditions of the standard loan agreement.

The following are the questions asked by the participants.

Mr. David Lewies (Focus Finance (Pty) Ltd) said that he was unclear about the
calculations of the fines.

He indicated that he was worried about affordability as they made input in the form of
comments, which were not incorporated and that it would lead to over-indebtness for the
consumer.

Mr. Ronald Weber (Finaid Financial Services (Pty) Ltd) asked who made the decision
with regards to the affordability assessment, he wanted to know whether it was a
NAMFISA in-house decision.

Mr. Weber indicated that the draft standards that was sent out had drastically changed,
however, there was no change in the published standards.

Mr. Daniels clarified the issues by stating that the penalties are calculated on 10% of the
annual, monthly or daily loans disbursed by a particular microlender. He informed the
meeting that all the comments that were received on the standard were considered.
However, it does not mean that all the comments were incorporated.

Mr. Daniels said that when the comments and input on the affordability assessment were
reconsidered, different departments within NAMFISA were involved in the discussion. He
explained that the process involves various departments within NAMFISA going through
each comment, deliberating on it and making recommendations. The comments and

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proposed recommendations would go through the internal governance process before a
decision is made.

5. STANDING ITEMS

5.1. COMPLAINTS STATISTICS

Ms. Alma Mavenjono provided an overview of the complaints received for the period
01 January 2019 to 31 December 2019.

NUMBER OF COMPLAINTS
Ms. Alma Mavenjono provided an overview of the number of complaints received for all
regulated industries for the reported period:

Year Total complaints Total resolved In progress

received
2019 1 013 977 36
2018 1072 1072 0
2017 990 990 0

She reported that the turn-around time for resolving individual complaints is 40 days, and
the current target for a quarter is a resolution rate of 75%.

NUMBER OF COMPLAINTS PER INDUSTRY

Ms. Alma Mavenjono furthermore provided a breakdown of the complaints per industry:
Year Microlending Short-term Long-term Pension Others Referrals Total
insurance insurance funds
2019 309 (31%) 188 303 148 65 0 1013
2018 400 (38%) 151 326 178 7 10 1072
2017 345 (35%) 138 276 209 19 3 990

She highlighted that from 2018 to 2019, there was a decrease of 7% of the number of
complaints for the microlending industry. However, when compared to the other
industries, the complaints from the microlending industry remains high.

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She indicated that the decrease in complaints could be as a result of the consumer
education awareness campaigns, which encourage customers to first lodge complaints
with the service providers involved before engaging the Authority..

TYPES AND NUMBER OF COMPLAINTS LODGED AGAINST TERM LENDERS

Ms. Mavenjono explained that the complaints received against the term lenders
pertained to the following:

Type of complaint Number of Complaints

Amount handed over to debt collectors 1
Dispute: Correctness of payment received 2
Double payment of loan 1
Extension of the loan period 57
Illegal deductions 18
Listing on credit bureau 3
Non-cancellation of contract 18
Non-payment of refunds 28
Overcharged interest 41
Query: Arrears on the Loan 2
Refund of bank charges 1
Request to negotiate loan repayment 1
Services not acceptable 18
Total 191

TYPES AND NUMBER OF COMPLAINTS LODGED AGAINST PAY DAY LENDERS

Ms. Mavenjono explained the complaints received for the payday lenders pertained to
the following:

Type of complaint Number of Complaints

Amount handed over to debt collectors 7
Asset repossession 1
Extension of the loan period 1

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Illegal deduction 32
Listing on Credit Bureau 6
Loan amount not disbursed 1
Non-payment of refunds 4
Non-provision of the information 1
Overcharged interest 42
Poor information on loan granted 1
Query: Arrears on the loan 2
Request to negotiate loan repayment 7
Retention of ATM card 2
Retention of Identification Card 1
Service not acceptable 10
Total 118

PAYMENTS EFFECTED AS A RESULT OF COMPLAINTS LODGED AGAINST TERM

LENDERS

Ms. Mavenjono gave a breakdown of the redress payments as a result of complaints

lodged against term-lenders:

Type of complaint Refunds N$

Dispute: Correctness of payment received 521.96
Extension of the loan period 55,101.18
Illegal deduction 5643.06
Non-cancellation of contract 32,742.92
Non-payment of refunds 95,618.87
Overcharged interest 47,937.91
Service not acceptable 52,235.27
Total 289 801,17

PAYMENTS EFFECTED AS A RESULT OF COMPLAINTS LODGED AGAINST

PAYDAY LENDERS

Ms. Mavenjono gave a breakdown of the redress payments as a result of complaints

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lodged against payday lenders:

Type of complaint Refunds N$

Amount handed over to debt collectors 2,260.50
Illegal deduction 24,837.67
Non-payment of refunds 1,300.00
Overcharged Interest 21,212.35
Request to negotiate loan repayment 5248.05
Service not acceptable 40,939.12
Total 95, 797,69

TYPOLOGY OF COMPLAINTS AGAINST THE MICROLENDING INDUSTRY

Ms. Mavenjono informed the meeting that most of the complaints received against term
lenders were categorized under “extension of the loan period” which amounted to 57
complaints followed by “overcharged interest” which had 41 complaints for the year.

She explained that a consumer would take a loan and the monthly installment would be
deducted, after the loan term ends the consumer would notice that deductions would
continue and the consumer would not be informed of an extension on his/her loan.

She also indicated that most of the complaints received against payday lenders were
categorized under “overcharged interest” which received 42 complaints followed by
“illegal deductions” which received 32 complaints for the year.

She explained that for the payday lenders the consumer would take a loan and if the
consumer defaulted, interest of 30% on the initial loan amount would be charged as
default interest, resulting in overcharging of interest of the loan.

RESOLUTION RATE FOR THE MICROLENDING INDUSTRY

Ms. Mavenjono informed the meeting that the resolution rate for the industry as at
31st December 2019 stood at 96 percent and this amounted to 977 of the 1013

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complaints received relating to the micro lending industry being resolved. She indicated
that 36 complaints were still pending, reason being that there were delays in receiving
written responses from the lenders or the complainant. In some of the cases, the
complaints were lodged within the last week of the quarter.

AMOUNTS PAID OUT TO THE CONSUMERS

Ms. Mavenjono informed the meeting that the total payments received by consumers as
a result of complaints resolved in their amounted to N$ 289,801.17 for term lenders and
N$95,797.69 for payday lenders as at 31 December 2019. She emphasized that the
number may seem insignificant, however, it made a huge difference for the consumers
when they receive their refunds.

Mr. David Lewies (Focus Finance (Pty) Ltd) asked what is the number of complaints
expressed in percentage as per the number of transactions in the industry?

Mr. Frank (Aiso Cash Loan CC) asked whether the complaints are for the existing
microlenders or for the newly registered microlenders as presented by Ms. Mavenjono as
being 309?

Mr. Frank in addition commented that the newly registered microlenders are the ones
that are not fully compliant, as they do not make use of credit bureaus. They look at the
bank statements of clients and find that the microlenders names appears on the bank
statements but when they check on the credit bureaus their names do not appear, giving
the impression that the client has a clean record while this is not so.

Mr. Frank asked what NAMFISA does in scenarios where borrowers insist that the
microlenders keep their bankcards because they don’t want their debit orders to reflect
on their bank statements, claiming that the banks don’t want to assist them due to the
fact that they have taken a loan from a microlender which reflects on their bank
statements.

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Mr. Frank further asked why are some microlenders not members of the MLA and why
NAMFISA does not compel them to be members of the MLA?

Mr. Frank commented that the new microlenders are tarnishing the name of the
microlending industry.

Ms. Ndeshi Kukuri (Ora Financial Services CC) asked if they will receive, a copy of the
presentation after the meeting is over?

Ms. Juliana Lucas (Dupwies Financial Services t/a Lighthouse Financial Services) asked
if there is a distinction of complaints against registered entities and non-registered
entities.

Mr. Daniels responded to the question of Mr. Lewies stating that it’s not a matter of
percentage, and one complaint is one complaint too many in the microlending industry.
He mentioned that Ms. Alberto’s opening remarks regarding the theme for the industry
meeting being orderliness in the industry and he indicated that therefore we must also
bear in mind that not all borrowers know NAMFISA and know that they can lodge
complaints at NAMFISA. Thus, the numbers might potentially increase if more borrowers
should become aware that they can lodge complaints with NAMFISA.

He noted that in the future he would see to what extend the Authority can consider Mr.
Lewies’ request regarding the number of complaints expressed in a percentage as per
the number of transactions.

Mr. Daniels informed the industry that industry meeting participants will be provided with
the presentations and minutes of the meeting.

Ms. Alberto responded to the question of Mr. Frank by stating that the figure that was
produced of 219 relates to entities against whom complaints were lodged and that there
was no distinction of the number of complaints whether they were from newly registered
entities or the existing registered entities but that of all the lenders in the industry.

She further said that one should be careful of using the fact that complaints that have
been received are against the entities who are newly registered in the industry and that
the collection methods used by newly registered entities are being dealt with differently.
She emphasized that if you are new in the industry all the provisions of the act are
applicable to the microlenders whether they are new or not.

Mr. Daniels said that as he previously explained under the penalty regulation, he
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acknowledged the discussions around the card and pin, and payroll deductions as the
collection methods used by some of microlenders.

He further said that the act speaks about responsible borrowing and lending and if
microlenders did not adhere to the principles then you put your own business at risk. The
question he posed to the industry participants is whether they wanted to contribute to the
latter.

Mr. Daniels responded to the question of NAMFISA compelling microlenders to be part of

the MLA. He said that it was rather a sensitive topic and would prefer microlenders to
read the provisions of the act so that they are aware whether the body they want to join
is an approved body or not. He informed the meeting that the MLA is not an approved
body and neither did they submit their application to be recognized as such.

Ms. Mavenjono said that in terms of NAMFISA’s mandate we need to protect the
consumers. It is for all consumers to lodge complaints whether the entity is registered or
unregistered and how the Authority handles the complaints is at the Authority’s
discretion.

5.2. SUBMISSION OF RETURNS AND PAYMENT OF LEVIES

Ms. Lombardt informed the meeting that she would be providing an overview of statistical
returns for Quarter 1 of 2019 to Quarter 4 of 2019. She said the information that was
provided was based on the Quarterly returns that were submitted to industry, reviewed
and approved by the Department.

She indicated that the Department experienced difficulty in reviewing the returns as a
number of entities submit the returns after the submission due date. She further said that
at times the Department ends up calling the microlenders to plead with them to submit
the returns.

She added that at times when the returned is reviewed and there are discrepancies
found in the review and the return would be sent back for corrections to be made, then
the entities do not submit the returns within the three (3) working days as required.

She urged the industry to submit the outstanding returns she further said the data from
the returns is used in the Quarterly Statistical Bulletin; in addition to that, the information
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is also shared with other stakeholders such as the Bank of Namibia. She informed the
participants further that if a microlender has branches such microlenders should provide
a summary along with the management report of the branches to make it easier for
review purposes.

Furthermore, Ms. Lombardt explained the difference between the Quarterly Financial
and Statistical Return, and the Levy return. The former pertains to submission of data in
respect of, amongst others, quarterly loan disbursements, while the other pertains to the
loan disbursements for a six (6) month period and calculation payment of levies on the
total of such disbursements. The latter is submitted to the Finance Department on the
NAMFISA ERS system.

Ms. Lombardt informed the microlenders that the following information should reflect in
the summarized management reports. She explained that the required contents of the
report are:

 The loan disbursements for the quarter (This is the Namibia dollar value of loans
disbursed.);
 The number of loans disbursed;
 The loan book value (outstanding loans, capital including Interest);
 The number of clients at the end of the reporting period;
 The interest charged;
 The debtors age analysis;
 The repayment received for the reporting period; and
 The borrower’s salaries by gender.

She said the submission of the returns as per new standard gazetted are due 30 days
after the end of the quarter. She further highlighted the new due dates for the MLR-2
Returns for 2020/2021 financial year as follows:

 Quarter 1 - 30 April 2020;

 Quarter 2 - 31 July 2020;
 Quarter 3 - 31 October 2020; and

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  Quarter 4 - 31 January 2021.

She urged the industry to please submit the returns on time and that no extension would
be granted after the due date. She further said once the penalty regulation comes into
effect then the microlenders would be subjected to a daily penalty for everyday the return
is submitted late.

STATISTICAL OVERVIEW FOR MICROLENDING INDUSTRY 2019

Ms. Lombardt gave the statistical overview for the microlending industry for 2019 as
follows:

VITAL FIGURES Quarter 1 Quarter 2 Quarter 3 Quarter 4

Total Number of loans disbursed 130 972 132 473 142 375 141 435
- Term lenders 28279 29993 31057 29647
- Pay day lenders 102 693 102 480 111 318 111 788
Total Number of clients 225 712 223 408 234 501 230 683
- Term lenders 188 826 188 414 189 123 180 803
- Pay day lenders 36 836 34 994 45 378 49 880
N$ N$ N$ N$
Total Value of loans disbursed 886 793 936 085 975 854 996 916
- Term lenders 713 635 764 952 766 892 766 806
- Pay day lenders 173 158 171 133 208 962 230 110

Total Value of loan book 5 950 430 6 017 710 5 972 103 5 758 210
- Term lenders 5 829 727 5 893 301 5 843 625 5 674 266
- Pay day lenders 120 703 124 409 128 478 83 944

She explained that the total value of loans disbursed for the term lenders stood at N$3
billion. In percentage terms, it would be 79% of the total loans disbursed by the entire
industry, whilst for payday lenders it stood at N$783.3 million, which is 21% of the total
loans disbursed. The total loans disbursed across the industry for the period under
discussion was N$3.7 billion.

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She further explained that the loan book value for the industry stood at N$5.7 billion. The
loan book value for the term lenders stood at N$5.6 billion or 99% of the industry total.
While the loan book value for payday lenders stood at N$83.9 million or 1%.

Ms. Lombardt informed the meeting that the term lenders had 90% market share of the
industry.

Mr. Ronald Weber (Finaid Financial Services (Pty) Ltd) asked if there are 360 lenders,
how many clients are there for each microlender?

Mr. Daniels said that a large number of microlenders do not submit their returns. As for
those that do submit their returns, their returns are processed and that is the information
that will be used for the compilation of the statistical review.

He explained that if you want to provide a proper overview of how the industry is doing in
terms of statistical data then you need to process all the returns. We engage the
microlenders and asked them to submit their returns but we have come to realize that
they submit their returns in their own time and at times not at all.

Mr. Daniels explained that the information from the quarterly returns are used for the
publication of the Quarterly Statistical Bulletins. What is published in the bulletins is
based on what is provided by the industry, thus, making it important for microlenders to
submit their returns on time.

5.3. FEEDBACK ON INSPECTIONS CONDUCTED

Ms. Marion Shumane presented the feedback on inspections conducted and she
informed the meeting that during the past financial year (2018/19), nine (9) inspections
were planned for the year. Out of the nine (9) inspections that were, planned only eight
(8) full-compliance inspections were conducted. One (1) full compliance inspection could
not be conducted. When the inspectors arrived at premises of the entity, the inspectors
found the entity dormant and no microlending activities were taking place at the
premises. Ms. Shumane further said that the full-compliance inspections were to confirm
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that the registered lenders comply with the Microlending Act, 2018 (Act No. 7 of 2018).

From the major findings that were identified during the full-compliance inspections, she
highlighted the following, namely:

1. Loans were disbursed without proper affordability assessments done and as such,
loans were provided while the borrower could not afford the installment of the
loan.
2. Entities were either submitting their MLR-2 returns late or not submitting the
returns at all when the quarter ends for a particular period.
3. The retention of Card and PIN of borrowers. Entities make borrowers sign
mandate forms giving consent to the entity to keep their bankcard and pin.

Ms. Shumane further explained the full-compliance inspection findings. She indicated
that other issues noted during the course of the inspections include the fact that no
proper record keeping was in place. This meant that copies of ID’s, pay slips and bank
statements were filed separately from loan agreements.

Some of the other issues picked up were the loan agreements were not signed by both
parties in order to conclude the microlending transaction. There are instances that the
loan agreement was signed by the borrower and not the lender and other instances that
they were signed by the lender and not the borrower. She also said indicated that there
were other instances that neither of the parties signed the loan agreement.

Ms. Shumane informed the meeting that some Principal Officers and Branch Managers
had no knowledge of the Financial Intelligence Act (“FIA”) and the requirements
thereunder. She further indicated that some Principal Officers were not in the full-time
employment of the microlending business. She said, the Principal Officers would appoint
acting Principal Officers without the approval of the Authority and the Acting Principal
Officers are employed elsewhere and only visit the microlending business once a month.
Ms. Shumane informed the meeting that there are consequences when the major
findings of the inspections are not addressed. She explained that it could affect the
renewal of the license of the entity, it could lead to the cancellation of the entity and it

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could lead to penalties being imposed against the entity, depending on the nature of the
contravention.

Summary of Major inspection findings

Full
Compliance
Inspection
(8 entities)
Loans disbursed without proper assessment for
affordability. ✓
Late or non-submission of MLR-2 Returns. ✓
No proper record keeping in place (copies of ID’s, pay ✓
slips and bank statements filed separately from loan
agreements.
Retention of bank cards and pins (mandate for retention 
forms signed by borrowers).
Loan agreements not signed by both parties (borrower ✓
and lender).
Principal Officers and Branch Managers have no 
knowledge of FIA and requirements.
Principal Officers not in full-time employment of ✓
microlender.

Mr. Neels Lewies asked whether the 42% of the complaints came from unregistered
lenders and if there were complaints against unregistered lenders, was NAMFISA
planning to do any inspection at the unregistered lenders?

Ms. Rosalia (N and S Cash Loan CC) said that she has been operating for 5 years and
no inspection has been conducted at their business and asked when can she expect
NAMFISA to do an inspection at her business?

She further asked what should she do in the event that the Principal Officer goes on
maternity leave?

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Mr. David Lewies (Focus Finance (Pty) Ltd) asked if the Principal Officer should be
onsite at the branch?

Mr. Daniels responded that when it comes to the inspections of registered and
unregistered microlenders there are a few things that need to be taken into
consideration. He said, firstly, when considering the resources, the Conduct and
Compliance Department team currently consists of six (6) people, including himself, and
that it would be impossible for the team to be inspecting all unregistered and registered
microlenders in Namibia, in addition to the other compliance work that it is expected to
be carried out.

Mr. Daniels explained that the Department interrogates the issues pertaining to
unregistered lenders that comes to their attention. In addition, NAMFISA considers those
microlenders that pose the biggest risk, and their respective geographical locations. He
said at the same time we take the list of complaints that was received and see if there
are unregistered entities in the areas where the team plans to conduct inspections for the
year.

He further said after these factors have been taken into consideration an inspection plan
is drafted. He said even where the Authority is not always able to conduct an inspection,
it would always do something to address compliance matters. He mentioned that at
times the teams would go to the premises of the unregistered lender and find that there
no microlending activities taking place or the unregistered lender has moved.

He explained the two types of inspections, being the onsite inspections and off-site
inspections. In addition, he indicated that NAMFISA did off-site inspections on all
registered entities during the re-registration process regardless of whether the entities
submitted applications for registration under the Microlending Act or not.

Mr. Daniels indicated that at times, developments in the industry can result in the change
of the inspection plan.

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Mr. Daniels responded to the question of the Principal Officer not being at a branch by
stating that the authority considers the fit and proper status of all key responsible
persons. The expectation is that when the inspectors arrive at the premises whoever is
the key responsible person at that particular branch or office should be there at the
premises.

6. NEW MATTERS

6.1. Outcome of the Money Laundering, Terrorist Financing, Proliferation

Financing Sectorial Risk Assessment

Mr. Alfred van Rooi informed the meeting that he would provide an overview of the risk
assessment that was done on the microlending industry. He indicated that the risk
assessment was compiled through the questionnaire that was sent to the microlenders to
complete and send back to the Anti-Money Laundering Department (AML) by a particular
date. He further informed the meeting that what he would present was based on the
information that was provided by the industry.

6.1.1. Manifestation of Money Laundering risks in the Micro-lending Industry

Mr. van Rooi highlighted the red flags in the microlending industry, he mentioned that
unusual or suspicious identification documents that could not be readily verified by the
microlender. He also mentioned that a borrower’s home or business telephone is
disconnected when the microlender wants to make contact with the borrower.

He explained that the borrower’s background differs from that which would be expected
on the basis of his or her business activities, he said the customer can claim that he/she
is in a different type of business activity but the background of the customer considered
is different.

He further mentioned that some borrowers repay the high outstanding balance in cash
earlier than the due date, in particular for term loans, not in line with financial profiles. He
mentioned that exceptional cases would be the instance where the client received a
bonus to clear up the balance. However, there are cases were the salary of the borrower
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is not sufficient and he or she was able to settle the loan without providing clarity where
he or she got the money from.

Mr. van Rooi referred to instances where a borrower is not clear in explaining the source
of funds for the cash payments or settlement of large outstanding balances with cash or
third party payments. This is for instances where the borrower does not really want to
disclose where they are getting the money from.

Lastly, he mentioned that when a borrower prefers to repay the loan by cash and prefers
that as the collection method for the loan they have taken.

6.1.2. Microlending risk associated with Clients/Borrowers

Mr. van Rooi informed the meeting that microlenders preferred clients that are salary
earners and such clients are inherently perceived as very low risk for money laundering.

Mr. van Rooi explained that some microlenders might provide loans to legal persons
where income from unlawful activities may be mixed with income from lawful activities,
which may elevate the microlending risk especially when repayments are done in cash.
He further said it is usually complicated to detect what proceeds come from lawful or
unlawful activities or at time, there is no trail for cash transactions.

6.1.3. Money Laundering risk associated with micro loans and term loans

Mr. van Rooi informed the meeting that the possibility exists for co-mingling of cash from
lawful and unlawful sources, which renders a micro loan vulnerable to abuse in money
laundering. He explained that loans paid into borrowers own bank accounts and repaid
via own bank accounts or via salary deduction, reduces the money laundering risk
considerably. He further explained that banks are a second line of defense to lower the
risk of money laundering posed to microlenders if the banks’ AML controls are stringent
and effective.

20
 6.1.4. Money laundering risk associated with the Distribution channel of a
Microlender.
Mr. van Rooi explained in the meeting that all clients of microlenders are serviced face-to
face at application stage and are required to submit proof of identity, source of income,
which in this instance would be ’’pay slips’’ and bank statements for every three months,
recent address and updated addresses in instances where the client receives recurring
loans until the business, relationship terminates. He concluded that, therefore, the
distribution channel for microlenders poses relatively low Money Laundering risk.

6.1.5. Money laundering risk associated with the Geographical location of a

Microlender.

Mr. van Rooi said that microlenders only disburse loans within the Namibian borders.
Micro-lenders are not engaged in cross border transactions, thus making the risk of
Money Laundering in relation to geographical exposure relatively low.

6.1.6. Money Laundering risk rating for the Microlending Sector

Mr. van Rooi indicated that the overall inherent Money Laundering risk rating for the
micro-lending industry as low.

Industry Inherent Risk Rating Low 1.0

6.1.7. Manifestation of Terrorist Financing risk in the micro-lending industry

Mr. van Rooi informed the meeting that microlenders are usually not attractive to
terrorists or financiers because of non-existent cross border activities. He said, however,
there are possible red flag signals of terrorist financing.

He explained that it included unexplained connections with movement of monies

between other jurisdictions. He further explained that this would only be possible if a

21
foreigner residing in Namibia who has links to terrorist networks borrows money from a
microlender and channels the funds to destinations where terrorism activities are
present.

He said another area of concerns is when the clients’ bank accounts where the loan
should be paid is not local (within the Namibian boarders) in relation to where the client
resides and requests to make payment of the loan to a third party.

7. Terrorism Financing Risk Assessment

7.1. Terrorism Financing risk associated with Clients/borrowers

Mr. van Rooi explained that there might be sympathizers of terrorist affiliates amongst
salary earners who may use a micro-lender for purposes of terrorist financing. He further
said the majority of the micro-lenders have clients who prefer to receive their loans in
cash and repay in cash. He said with that it is very difficult to follow the trail of cash, thus,
the possibility exists that cash loans may be used for terrorist financing purposes.
7.2. Terrorism Financing risk associated with Micro loans and Term loans

Mr. van Rooi said that micro loans or term loans, which are disbursed in the form of
cash, as well as repaid in cash, are vulnerable to abuse for terrorism financing purposes.
In addition, a micro loan or term loan, which is disbursed to a third party, presents the
risk of Terrorism Financing, and is highly vulnerable to abuse for Terrorism financing
purposes.

7.3. Terrorism Financing risk associated with distribution channel

Mr. van Rooi explained in the meeting that micro loan or term loans, which are usually
disbursed face to face poses relatively low Terrorism Financing risk.

22
 7.4. Terrorism Financing risk associated with Geographical location

Mr. van Rooi explained during the meeting that microlenders clients are local clients and
there is no risk of disbursing loans to jurisdictions that are considered high-risk or non-
cooperative as listed by the Financial Action Task Force (FATF).

7.5. Terrorism Financing risk rating for the Microlending Sector

Mr. van Rooi presented the overall inherent terrorism financing risk rating for the
microlending industry.

Industry Inherent Risk Rating Low 1.0

8. Overview of Money Laundering, Terrorist Financing and Proliferation Financing

Mr. van Rooi informed the meeting that inherently, micro-lenders have strong
management controls designed according to the nature of their business. He explained
that weaknesses identified as far as implementation of Money Laundering, Terrorist
Financing and Proliferation Financing combating measures are as follows:

 Lack of risk management processes;

 Inadequate staff training on Money Laundering (“ML”), Terrorist Financing (“TF”)
and Proliferation Financing (“PF”) combating measures;
 Inadequate audit review of ML, TF and PF management controls;
 Failure to screen clients against the UNSC sanctions lists;
 Failure to monitor transactions and report suspicious transactions and activities to
the FIC and
 Failure to keep records as prescribed in FIA.

23
 8.1. Net risk rating for the Microlending Sector

Mr. van Rooi presented a table that illustrates the overall net risk rating of ML, TF and PF
risks for the microlending industry. He explained that it would be difficult to provide the
calculations on how the overall rating was calculated, but assured the industry
participants that the microlending sector remained a low risk sector.

Overall ML Overall ML Overall Overall Overall TF/PF Overall

Inherent Management ML Net TF/PF Management TF/PF
Risk and Control Risk Inherent and Control Net
Rating Effectiveness Rating Risk Effectiveness Risk
Rating Rating Rating Rating

Industry
Net/Residual 1.0 2.87 1.94 1.0 2.87 2.06
Risk Rating

9. Actions required to address the risks identified

Mr. van Rooi informed the meeting that NAMFISA would apply a risk-based approach
when supervising and monitoring microlenders. In that regard, NAMFISA would focus on
the risk and materiality significant to the microlenders in terms of size, structure and
weakness in controls, which include the following:

 Failure to conduct ML and TF risk assessments. Microlenders who did not

conduct Money Laundering and Terrorist Financing risk assessments must
conduct these assessments in order to understand the risks of Money Laundering
and Terrorism Financing posed by their clients and apply a risk based approach
when implementing AML/CFT measures. He said that they must also assess and
understand the risks of Money Laundering and Terrorism Financing associated
with the type of loans, delivery channels and geographical exposure.
 Failure to train or ensure that staff members are trained on ML, TF and PF
combating measures.

24
  Failure to ensure that independent audit review of ML, TF and PF management
controls is done and the findings thereof are addressed
 Failure to screen clients against the UNSC sanctions list at onboarding and as
and when the sanctions lists are updated.
 Failure to monitor transactions
 Failure to report suspicious transactions and activities to the FIC and
 Failure to keep records as prescribed in FIA.

Mr. van Rooi further explained that NAMFISA will impose proportionate and dissuasive
administrative sanctions when non-compliance is detected and this could include the
following:
 A caution;
 A reprimand;
 A directive;
 Suspension of part of business posing the risks of ML, TF and PF where controls
are weak or non-existent; or
 A financial penalty not exceeding N$10 million.

Mr. van Rooi said that each case of non-compliance would be treated differently
depending on the merits of the non-compliance.

10. Mutual Evaluation

Mr. van Rooi informed that Namibia would undergo a Mutual Evaluation by the Financial
Action Task Force (FATF) this year (2020) to establish whether there are measures in
place to combat ML, TF and PF activities and the effectiveness thereof. He said the
Mutual Evaluation would begin with off-site assessments in June 2020, and on-site
assessments in November 2020.

He further informed that assessors are drawn from East and Southern Africa Anti-Money
Laundering Group (“ESAAMLG”) member countries, and they would interview key
stakeholders including the supervisory and regulatory bodies as well as the regulated
institutions. He said that this implied that they would also interview a few microlenders to
25
establish how well they understand their risks of ML and TF and how preventative
measures are implemented.

He concluded to say that NAMFISA would identify some of the microlenders who will be
interviewed and there will be preparatory sessions before the onsite visit assessors.

Mr. David Lewies (Focus Finance (Pty) Ltd) commented that it would be a test of
endurance.

11. Section 11 Applications

Ms. Lucrecia Lombardt informed that a person who conducts or who intends to conduct
microlending business must apply to NAMFISA for registration as a microlender. She
said that microlenders registered under the Exemption Notice were required to apply for
re-registration under the Microlending Act and they had until 14 October 2019 to submit
their applications.

She explained that microlenders did not make the deadline which was provided, will be
informed via individual letters that their registration had lapsed.

Ms. Lombardt informed that 219 microlenders submitted their applications for re-
registration. She said those microlenders that did not submit their applications for re-
registration under the Microlending Act will have their names published in the papers for
the public to be cautious when engaging these microlenders, as they were no longer
registered with NAMFISA.

Mr. Ronald Weber (Finaid Financial Services (Pty) Ltd) asked what happened to the 180
microlenders that did not submit their applications, did their applications lapsed and
asked if they are still operating?

He further asked about applications that have been submitted before 14 October 2019,
five (5) months have passed, and when will they receive an answer from NAMFISA?

Mr. David Lewies (Focus Finance (Pty) Ltd) commented that when they had to register
under the Exemption Notice they waited for five (5) years to be registered.

26
Ms. Alberto informed the meeting that the numbers mentioned relates to the
microlenders that are existing and that have applied for re-registration. She mentioned
that the 149 microlenders that did not apply for re-registration under the Microlending Act
would soon receive notice from NAMFISA and their names would be published.

She informed the meeting that she would not speak on specifically about a certain
entity’s application as that is a bilateral matter. She said that this was a new exercise that
the Department went through, and they have taken into consideration how long the
process takes and have not set a timeline by when they should have assessed the
applications.

She further explained that after this process is done, the renewal of the license
applications would be made simpler, less cumbersome and faster for microlenders to
receive an answer from NAMFISA.

Mr. Daniels said that there is no certainty that if you have submitted your application for
re-registration that the outcome would be successful in being registered but the point of
the matter is when you have submitted your application you continue with business until
such a time that NAMFISA provides you with a response on your application.

He further explained that there is no standard in place concerning the renewal process,
however, in future the process would be a lighter assessment, if you wish to continue
with business, with minimum requirements.

11.1. Annual Renewal of Registration

Ms. Lombardt informed that the registration for microlenders under the Microlending Act
was valid for 12 months from the date of registration. She further said that microlenders
had to apply for the renewal of their license 60 days prior to the expiry date of their
registration.

27
She explained that if the renewal application form were not submitted to NAMFISA within
60 days prior to expiry of registration, the microlender would pay penalties for each day
that the application is late.

Ms. Rosalia (N and S Cash Loan CC) asked if one would pay for the renewal of the
registration of the license.

Mr. Frank (Aiso Cash Loan CC) asked if the N$2000-00 would be paid every year? And
commented that there should be no fee for the renewal of the license.

Mr. Wilbard Namboga (Rosh Pinah Cash Loan CC) asked when they should apply for
the 12 months to be effective and for how long should they wait until they receive
feedback for the application that was submitted.

Ms. Liffie Champion (Entrepo Finance (Pty) Ltd) asked if they needed to wait to get
formal approval of their re-registration application before a branch application can be
applied for.

Ms. Alberto responded that when you receive your certificate you would be able to know
from when the registration period runs and when it ends. She said that there is no
service level commitment time frame in place for the renewal registration as it is a new
process. She further said however, the registration under the Microlending Act could be
improved.

She said concerning the application for a branch that you could submit the application
but it would only be considered after the approval for re-registration has taken place but
did not want to dictate whether you should submit the application before the approval or
after.

Mr. Daniels responded with regards to the renewal fee, that he had taken note of the
question and would go back to find out how much the renewal fee would be and
communicate to the industry in that regard.

28
12. DATE OF NEXT INDUSTRY FORUM

Mr. Daniels thanked the microlenders for their attendance and participation as the
session was very engaging. He asked the industry participants whether March was a
suitable month for the microlenders to have the next meeting and provided the
microlenders the floor to comment on how the Authority can improve on their
engagement platforms.

Mr. Daniels took note of the suggestion to have the meeting for the entire day as
microlenders would like to have enough time to ask questions and informed the meeting
that the Authority would go back and have a look at it. Another suggestion that was
proposed was that the meeting should take place on a Friday and not a Monday.
Mr. Daniels informed the meeting due to the logistics arrangements that go into planning
the industry meetings, it could not be guaranteed that the next Windhoek meeting will be
held on a Friday. He said that there are other factors that also play a role in deciding on
the dates of the meetings. For instance, he mentioned that the Authority try to avoid the
dates of the 20th, 25th and 31st, as they are busy days for the microlenders. He further
explained that he is well aware that industry would like to be at their respective
businesses in order to collect the money that needs to be collected from customers that
are coming to pay cash at their respective businesses on the aforementioned days.

Mr. Daniels once again thanked the meeting for their suggestions and attendance of the
meeting.

CLOSURE

Mr. Daniels announced closure of the meeting and invited the microlenders to join
NAMFISA for finger snacks. The meeting adjourned at 13h10 p.m.

22 July 2020
________________________________ _____________________
CHAIRPERSON DATE
29
 ANNEXURE A

ATTENDANCE REGISTER

MICROLENDERS’ INDUSTRY FORUM

9 MARCH 2020

NAMIBIA INSTITUTE AND PUBLIC ADMINISTRATION (NIPAM)

Microlending Industry Forum Attendance List

Meeting Date: Friday, 9 March 2020

Microlending Industry Forum
Meeting Convener: Ms. Hilka
Alberto
Venue: Windhoek, NIPAM
General Manager: Market
Conduct

MICROLENDER NAME E-MAIL ADDRESS CONTAC

T TEL
NO.
1. Kitenge Cash Loan CC Sakaria Amoonga samoonga@gmail.com 08131722
16
2. Express Credit Cash Eckhardt Marais eckhardt.marais@express 08141999
Advance (Pty) Ltd credit.com.na 03
3. Kasirenge Cash Loan CC Reino Siteketa rsiteketa8@gmail.com 08145208
73

30
4. P.S. Financial Services Perdio Strauss perdiostrauss@yahoo.co 08122191
CC m 18
5. 08112819
Trustco Finance (Pty) Ltd Riaan Steyn riaans@tgh.na 98

6. Kudu Finance CC Winnie Engelbrecht winnievd@iway.na 08141383

98
7. Aina and Emmy Five Emilia Amupala eamupala@gmail.com 08129986
Cash Loan CC 53
8. Aina and Emmy Five Libertine Nawa ainaemmyfinance@gmail. 08136323
Cash Loan CC com 95
9. Otjimariva Cash Loan Maria Alfeus otjimariva@gmail.com 08530634
93
10. Otjimariva Cash Loan Margreth Kandovazu otjimariva@gmail.com 08120857
01
11. Luu’s Financial Services Lucia Kadhikwa luciakadhikwa@gmail.co
CC m

12. Luu’s Financial Services Hendrik Vatilifa 08122311

CC 13

13. Ndeutully Financial Thomas Salomo ndeutullyfinancialservices 08141846

Services CC @gmail.com 94

14. Ndeutully Financial Diana Kahoro 08131528

Services CC 83
15. Inobani Cash Loan CC Lydiana Van Der Byl lydianavanderbyl@gmail. 08148554
com 30
16. Inobani Cash Loan CC Merlin Byl 08168000
21
17. Omayele Financial Sakeus Kalikuma omayelefinancials19@gm 08121867
Services CC ail.com 06

18. Omayele Financial Elizabeth Kandjabanga omayelefinancials19@gm 08132588

Services CC ail.com 4

19. Naiyuma Kaikonya Cash Ndina Shaameulu natangwedavid@gmail.co 08149844

Loan CC m 36

31
20. Naiyuma Kaikonya Cash Ndadaleka Sakaria natangwedavid@gmail.co 08149844
Loan CC m 36
21. Letshego Micro Financial Jaco Kruger barendk@letshego.com 08114738
Services (Pty) Ltd 03

22. Letshego Micro Financial Chriszelda Gontes 08112600

Services (Pty) Ltd 99

23. Top-Notch Financial Sasha Nghiteke topnotchfs@yahoo.com 08141036

Servies CC 86
24. Top-Notch Financial Lydya lydyanepolo@icloud.com 08147298
Services CC 02
25. FNB Easy Loans (Pty) Ltd Martha Murorua mmurorua@fnbnamibia.c 08112844
om.na 88
26. FNB Easy Loans (Pty) Ltd Imelda Moller molleri@fnbnamibia.com. 2992487
na
27. ADDP Cash Loan CC Frieda Hosea addpcashloan 08127937
42
28. Old Mutual Finance (Pty) Otto Makemba omakemba@oldmutual.co 2993217
Ltd m
29. Old Mutual Finance (Pty) Leandro Sitler isitler@oldmutual.com 2993211
Ltd

30. BW Finance (Pty) Ltd Hans Sauer sauerh@bankwindhoek.c 2990451

om.na
31. N and S Cash Loan CC Rosalia Nakambunda saknakambunda@yahoo. 08137208
com 54
32. Waidiva Cash Loan CC Oscar Mwandingi toivonanghonga2@gmail. 08145005
com 28
33. Kongalend Financial Immanuel Puleinge itpuleinge@konga.na 06124144
Services (Pty) Ltd 0
34. Kamwi Cash Loan Bekezela Sithole kamwicashloan@gmail.co 066-
m 253092
35. M. Trading t/a Quick Albert Piechazek pika@pikaql.com 08116000
Loans Pika 60
36. M. Trading t/a Quick Daniel Hamukoshi danieljack.jk@gmail.com 08112219

32
 Loans Pika 9

37. Namletu Finance Luuli Immanuel idluuli@gmail.com 08131353

29
38. Kwafa Financial Services N. Shilongo kwafacc@gmail.com 08128636
CC 97
39. MIG Finance (Pty) Ltd Polita Julie info@migfin-nam.com 08112399
9
40. MIG Finance (Pty) Ltd Moebasen /Gaoses 08141208
10
41. Sharp Financial Services Pieter Swartz pieter@sharpnamibia.co 08117010
(Pty) Ltd m 98
42. Varisu Financial Services Valerie Murphy Varisu.financialservicescc 08168015
CC @yahoo.com 55

43. Varisu Financial Services Francina Mushambati 08112275

CC 09

44. Kingsway Financial Watae Nawa finance@kingswaygroup. 08172830

Services (Pty) Ltd com.na 27
45. Kingsway Financial Rochelle Kangeriko 08114444
Services (Pty) Ltd 88
46. Ponda Cash Loan CC Linyando Nicodemus pondacashloan@gmail.co
08149601
m
49

47. Ponda Cash Loan CC Murere Simon

08122107
12

48. Seltho Cash Loan CC Selma Thomas selmat90@gmail.com 08120501

16
49. Finaid Financial Services Ronald Weber rweber@finaid.com.na 08112200
(Pty) Ltd 28

50. Musukuwamali Cash Sitongeni Mangundu fabianessitongeni@gmail. 08149554

Loan CC com 22
51. Musukuwamali Cash Muronga Mpasi clemence96@outlook.co 08188372
Loan CC m 72
52. Deria Cash Loan CC Amaria Kanenguni Deriacashloan2018@gma 08128593

33
 il.com 19

53. Deria Cash Loan CC Fillemon Haufiku 08120091

07
54. Flash Cash Services CC Joey Blaauw flash@iway.na 08127343
82
55. Onime Cash Loan CC Maria Egumbo onime@iway.na 08121914
82
56. Onime Cash Loan CC Elizabeth Hamwaanyena 08112903
17
57. Kama Financial Services Rafael Kalumbu rafael@kamafinancial.co 08128283
CC m 34

58. Kafumba Cash Loan Ester Lyambayi kafumbatradinge@yahoo. 08133588

com 49
59. Reho Cash Loan Louis C. Vries gabzone1@iway.na 08121508
30
60. Reho Cash Loan Liza Mafupe gabzone1@iway.na 08171522
88
61. Dupwies Financial Juliana Lucas juliana@lewfingroup.com 08112998
Services t/a Lighthouse 33
Financial Services
62. Mr. Cash CC Neels Lewies neels@pioneergroup.com
.na
63. Ombatero Financial Zarika Lewies zarika@pioneergroup.co
Services CC m.na

64. Focus Finance (Pty) Ltd David Lewies david@pioneergroup.com

.na
65. Pioneer Finance (Pty) Ltd Festus Tsheehama festus@lewfingroup.com. 08145106
na 46
66. Ndjundo Cash Loan CC Olivia Nghiwana 08166862
20
67. Ndjundo Cash Loan CC Erastus Mufenda ndjundocashloan@gmail. 08130438
com 15
68. Onhofi Financial Services Pendukeni Nayoma etutuma@gmail.com 08114746
86

34
69. Onhofi Financial Services Tuliikeni David 08114746
26
70. EMH Financial Services Elton Howoseb ehowoseb@gmail.com 08114500
CC 11
71. EMH Financial Services Jennifer Geises jenniferdenilson@gmail.c 08143014
CC om 460

72. SHE Financial Services James Matsika simataacherien@gmail.co 08166174

CC m 63
73. Four T. Cash Loan CC Fiina Vatuva fvatuva4@gmail.com 08127173
05
74. Elivans Cash Loan Elizabeth Isaacks elisabethisaacks@yahoo. 08121019
com 63
75. Ngayove Cash Loan Joseph Lyambezei ljosephimanuel@gmail.co 08130427
m 80
76. Doorstep Loans CC Shaleen Mokalabatho bernadettetjombe@yahoo 08167202
,com 32
77. Tweety Cash Express CC Elina N. Unoovene elinavellious@gmail.com 08138343
09
78. Getbucks Namibia (Pty) Charmaine Diergaardt charmainevr@getbucks.c 08131039
Ltd om 53

79. Rosh Pinah Cash Loan Wilbard Namboga ganaseba@iway.na 06327452

CC 2

80. Greensquare Financial Tylves Alweendo tylveskaizer@gmail.com 08122654

Services CC 48

81. L and J Payday Loans Jyrus Amukalu ilekaleevi@gmail.com 08120465

CC 60
82. Getrud Kaizemi t/a Ulie Kaizemi helensfinancialsolutions@ 08125000
Helens Financial Solutions gmail.com 3
83. Getrud Kaizemi t/a Getrud Kaizemi 08123001
Helens Financial Solutions 01

84. Venuscor Financial Unombuiro Mujoro mrmujoro@gmail.com 08128823

35
 Services CC 90

85. FNB Easy Loans Christel Van Schalkwyk christel.vanschalkwyk@fn 2998324

bnamibia.com.na
86. Ntembwa Small Cash Elizabeth Kandenge ntembwakachimine@yah 08129209
Loan oo.com 22
87. Ntembwa Small Cash Michelle Kamuhapita ntembwakachimine@yah 08144655
Loan oo.com 79
88. Binacent Cashloan Foibe Kandolo binacentcashloan@gmail. 08126608
com 49
89. Al-So Madawa Financial Macbeth So-Odoes dlsmfs@gmail.com 08181862
Services CC 12
90. KTS Quick Finance Catherine Sunde kcsunde@gmail.com 08138009
19
91. VPS Financial Services Shikoyeni Olivia vps@gmail.com 08125581
28
92. Fowl Cash Loan CC Malvern fowlcashloan@gmail.com 08182644
41
93. Fowl Cash Loan CC Theophelis L.N fowlcashloan@gmail.com 08139942
78
94. Munshop Financial Hansen Edward ehansen@iway.na 08127234
Service 5
95. Ya Tema Finance Ndatolewe Amon yatemafin@gmail.com 08121023
35
96. Junino Cash Loan Kakunde Daniel junino@gmail.com 08160601
3
97. Walo Finanincial Abisai Beronardu walofinancialn@yahoo.co 08112236
Services m 18
98. OJ Cash Loan John Sitoti jms.toti@gmail.com 08178052
78
99. First African Finance Davey Farmer larochelle@jsslots.com.na 08124027
21
100. Ora Financial Services Ndeshi Kukuri ndeshikukuri@yahoo.com 08129241
CC 58
101. Nam Synergy Taala Johannes taaraj21@gmail.com 08126146
Microlender CC 62
102. Nampost Financial Patrick Gardiner patrickga@postfin.com.na 08130190
37

36
 Brokers t/a Postfin
103. Nampost Financial Holger Klitzke holgerkl@postfin.com.na 08129136
Brokers t/a Postfin 03
104. Aiso Cash Loan CC Frank/ Eveline info@aisofin.com 06123497
0
105. Nafkom Financial Festus/Iyaloo nafkomin@gmail.com 08125524
Services CC 24
106. Express Credit Cash Nicolaas P. Esterhuyse npesterhuyse@ecfinance 08173760
Advance (Pty) Ltd group.com 50
107. Penny Cash Loan CC Penoshinge Kakunde pennykakunde@gmail.co 061-
m 221774
108. NMT Financial Services Lydia Amukwa nmt.tuhafeleni@gmail.co 061-
CC m 225534
109. Sitapata Cash Loans CC George L. Sitapata sitapatacashloans@gmail.
com
110. Okahandja Financial Frans Haushiku ofs@iway.na (062)
Solution 500601
111. Kambushe Cash Loan Ndinelago kambushecashloan@gma 08160455
CC il.com 16

37