Philippines |

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1 Introduction and
background
1.1 Key demographic and
economic data
An archipelagic state,
the Philippines has a land mass comprising some 7,000 islands, although 94 per cent of the
total area of 300,000 square kilometres is on the eleven largest islands. With a
population in 1995 of 68.6 million, the Philippines experiences a population density of
around 230 persons per square kilometre, which is substantially higher than that of the
other Southeast Asian countries included in this survey, and approaching the densities
recorded for Sri Lanka and India in South Asia.
With a population
growth rate of 2.2 per cent between 1990 and 1995 and a total fertility rate (births per
woman) of 3.7 in 1995, population in the Philippines is growing substantially faster than
in either Indonesia or Thailand (although Malaysias growth in a much less
resource-constrained situation is slightly higher at 2.4 per cent). Gross national product
(GNP) per capita in 1995 was $1,050, slightly higher than for Indonesia and substantially
higher than in the South Asian countries included in this study. However, it was well
below the levels of Malaysia ($3,890) and Thailand ($2,740). On a purchasing power parity
basis, the Philippines has income per head well below all the other Southeast Asian states
in this study, and also below Sri Lanka.
In terms of the
structure of production, agriculture (which contributes 22 per cent of GNP) remains
relatively more important than in the other Southeast Asian states in this study. Industry
(which contributes 32 per cent of output) is weighted substantially less than in the
Philippines Southeast Asian neighbours. This reflects the relative stagnation of the
Philippine economy over the past 25 years, with implications for the incidence of poverty
which are discussed below. In the decade 19851995, income per head increased at only
1.5 per cent annually, sluggish by Southeast Asian standards and below the rate of almost
all the countries in this study.
UNDP classifies the
Philippines as a medium level country in terms of human development. With a
human development index of 0.672 in 1994, the Philippines is at around the same level as
Indonesia and substantially higher than most of the South Asian countries (although it
ranks below Sri Lanka). The degree of its human development is substantially below that of
both Malaysia and Thailand which are ranked in the high category by UNDP. Life
expectancy at birth in 1995 was 66 years and the infant mortality rate was 39 per 1,000
live births, close to the average for East Asia as a whole. However, some 95 per cent of
adults were literate, the highest proportion among the nine countries in this study.
1.2 Poverty
Estimates of poverty
Poverty continues to be
the most important development problem confronting the Philippines. The incidence of
poverty is substantially higher than in other market economies of East and Southeast Asia,
while Philippine performance in poverty reduction has been relatively disappointing over
an extended period. In part, as a recent report notes (World Bank 1996), poor performance
in poverty alleviation has been related to disappointing economic growth performance:
so far, the country has not been able to sustain growth long enough to reduce its
incidence of poverty to the levels attained in other East Asian countries. The World
Bank also points to structural distortions in the economy which have acted to prevent the
benefits of economic growth flowing through to the poor.
While the incidence of
poverty is known to be high, actual measurement is elusive. Official Philippine government
measures of poverty incidence are thought to be overstated, because the poverty line is
set using a standard food basket unrepresentative of the consumption patterns of the poor.
As the World Bank points out, various measures of poverty incidence, depending on
definition, showed anything from 37 to 54 per cent of the total population below the
poverty line in 1991 (table 3). While the incidence of poverty appears to have fallen over
a 30-year period from 1961, the decline has been slow and by no means continuous. The
proportion of urban families living in poverty appears to have declined more rapidly than
for rural families. However, with urbanisation, the urban poor actually formed a larger
proportion of the total population in poverty than was the case thirty years earlier.
A national family
income and expenditure survey, conducted in 1994, appears to indicate further modest
declines in overall and sectoral measures of poverty. However, the economic setback
affecting the East Asian region since mid-1997 (which in the Philippines has resulted in
currency depreciation, higher interest rates and a slowdown in economic activity) has
probably halted or even reversed this trend for the time being.
Table 3 adjusts
official estimates to show 37 per cent of all families below the poverty line (23 per cent
in urban areas and 53 per cent in rural) in 1991. The unadjusted estimate of 39 per for
1991 compares with 35.7 per cent for 1994, based on the family income and expenditure
survey. This is the latest national poverty estimate. At that time about 4.7 million
Philippine households were classed as poor. The relatively poor performance of the
Philippines in reducing poverty, by comparison with the other Southeast Asian states in
this study, is shown in table 4.
Other Southeast Asian
countries included in this comparative study succeeded in reducing the incidence of
poverty by annual rates of between 1.4 and 2.0 percentage points over an extended period
of two to three decades. In the Philippines the annual average reduction was considerably
less. Moreover, economic growth in the Philippines was narrowly based and
inequitable, trapping many people in marginal, low paying occupations . . . (World
Bank 1996, p.4). This was a consequence of what the World Bank describes as a highly
inequitable distribution of incomes and assets.
By contrast, in
Indonesia where per capita income is roughly equivalent to that in the Philippines, the
distribution of income was much more even and the incidence of poverty substantially
lower. The World Bank notes that most other East Asian countries have experienced
dramatic improvements in income distribution, whereas income inequality in the
Philippines has not improved over time (p.4). The respective Gini Coefficients
for Indonesia and the Philippines were 0.317 and 0.407, with the lower figure indicating
greater equality. The richest 20 per cent of the population in Indonesia had some five
times the income of the poorest fifth: in the Philippines the ratio was ten to one.
Thus, at the beginning
of the 1990s more than one third of households in the Philippines still had income below
the poverty line and more than a half of the rural population was poor. As against that,
despite the relatively high proportion beneath the poverty line, it appeared that the poor
were relatively better off, in the sense that the gap between the income of the poor and
the poverty line had narrowed. The World Bank noted that a substantial proportion of those
below the poverty line could be lifted out by a combination of sustained growth and a more
effective poverty alleviation strategy. Here is where appropriate interventions, including
microfinance, could make a difference, although recent economic difficulties in the region
(even though less severe in the Philippines than elsewhere) have made the task more
difficult.
Policies for poverty
reduction
After the
peoples power revolution and the restoration of democracy in 1986, the
primary concerns of the Aquino administration were governmental reform and macroeconomic
stabilisation. Further progress towards financial sector liberalisation occurred and
positive encouragement was given to the development role of NGOs. The advent of the Ramos
administration in 1992 saw a number of significant initiatives explicitly directed at
poverty as a primary objective. A persistent theme has been the need to rationalise the
wide range of government programs directed towards aspects of poverty, and to secure
greater effectiveness and better targeting.
The World Bank report
of 1996 which commented upon the persistence of poverty in the Philippines referred to the
limited success of safety net programs directed to various needs of the poor.
A bewildering range of such schemes had come into existence during the 1970s and 1980s.
These included employment creation, food subsidies and livelihood programs.
Much of this effort had been ineffective and ill-directed (a judgement applying both to
the broad range of poverty programs, and to the proliferation of specific
livelihood programs offering credit).
With the election of
President Fidel Ramos in 1992, the new Administration created the Presidential Commission
to Fight Poverty whose head held Cabinet rank. The potential for access to credit to play
a role in poverty alleviation was acknowledged in several initiatives. These included the
Social Pact on Credit, forged in 1993 between government agencies, government financial
institutions, private banks, cooperative rural banks and farmers groups, and the
Social Reform Agenda of 1994. The Social Pact led to the creation of a National Credit
Council (NCC), discussed below.
The Presidential
Commission to Fight Poverty identified five major strategies to address poverty, which
have been endorsed by the Philippines government. These involve a blend of broad-brush
macroeconomic measures, microeconomic reform and decentralised, people-centred initiatives
with the short-term goal of bringing the incidence of poverty down to 30 per cent by 1998,
when the term of the current Administration expires. In summary, these strategies are as
follows:
(1) Promote and
sustain economic growth to create employment and livelihood opportunities: this is to
be done by a combination of infrastructure development, taxation reform, financial sector
development, microeconomic reform directed at various impediments to growth, and targeted
government spending.
(2) Sustain growth
based on people-friendly strategies: the promotion of labour-intensive technologies,
removal of policy biases against agriculture, reform and revival of rural financing
facilities, redirection of credit in livelihood programs to the ultra-poor.
(3) Expand social
services to provide minimum basic needs: primary health care and family planning,
elementary education, nutrition, housing, water supply and sanitation.
(4) Foster
sustainable income-generating community projects: emphasise livelihood
programs providing skills training, credit and technical extension; consolidate lending
programs for the core poor under the Presidential Commission to Fight Poverty; extend
credit at commercial rates and without collateral.
(5) Build the
capabilities of the poor to help themselves: involve local leadership through
implementation of programs through local government, mobilise the private voluntary sector
(including NGOs) and facilitate the formation of peoples organisations.
Key elements of this
program are embodied in the Social Reform Agenda (SRA), approved by the President in 1994.
The SRA focuses on the provision of health, nutrition, education, credit and shelter to
the target groups. Implementation of the Agenda required the creation of nine
flagship programs focusing on basic needs of the poor; one of these is
concerned with credit. Various initiatives flowing from this are discussed below.
Since 1993 the National
Credit Council (NCC) has been charged with the task of rationalising and coordinating the
numerous credit programs operated by agencies of government. It has also conducted a
series of studies on aspects of credit policy, with the support of a USAID-funded
consultancy. While the articulation of policy guidelines is one thing, and their
implementation another, those articulated in the Philippines (most recently, in the
National Strategy for Microfinance completed by the NCC in January 1997) are unusually
explicit in situating microfinance within the broader financial system, and in according
it a key role in poverty alleviation.
The microfinance
strategy is set in a framework in which the role of the private sector (including MFIs) is
emphasised and an enabling policy environment is to be established. Market interest rates
are to apply to loans and deposits, and government line agencies are supposed to withdraw
from the implementation of credit and guarantee programs in favour of specialised lending
agencies. The institutional framework for microfinance is to be one in which:
(1) MFIs engage in
sustainable microfinance intermediation
(2) the government
(through the NCC) provides a policy environment supportive of efficient financial markets
and private MFI participation in those markets
(3) specialised
government financial institutions (in particular, the Peoples Credit and Finance
Corporation) provide wholesale funds and technical assistance to MFIs
(4) commercial banks
provide wholesale funds and financial services to MFIs and work with them in mobilising
savings
(5) NGOs will provide
services of non-financial intermediation between poor households and MFIs
(6) donors will provide
assistance for social preparation activities and support the more efficient
operation of the microfinance market and microfinance institutions.
Finally, at the time of
writing, the Philippines Congress is considering a major piece of legislation for An
Act institutionalising a national strategy for poverty alleviation. This Act passed
into law in December 1997. The intention was (inter alia) to institutionalise the Social
Reform Agenda, strengthen the Peoples Credit and Finance Corporation, establish a
Peoples Development Fund as a permanent vehicle for providing capacity building for
microfinance, and introduce new savings instruments designed for small savers while
setting up special new credit windows in government financial institutions for the poor.
1.3 Overview of the
financial system
As at end-1996 there
were 49 commercial banks in the Philippines, supervised by the central bank, Bangko
Sentral ng Pilipinas, and offering the full range of banking services. These banks are
represented by an umbrella organisation, the Bankers Association of the Philippines
(BAP). In addition, Bangko Sentral supervises some 108 thrift banks and 805 rural banks,
the latter including some 47 cooperative banks. Thrift and rural banks are more restricted
in their operations than commercial banks, typically serving a community or limited
geographic area, and being more widespread throughout the provinces. They have much lower
minimum capital requirements. For 1993, del Rosario (1995) reported that the commercial
banks dominated the banking sector. Their assets constituted some 76 per cent of those of
the banking system and 56 per cent of those of the whole formal financial sector.
There are also three
specialised government banks, the Development Bank of the Philippines, the Land Bank of
the Philippines (LandBank) and Al-Amanah Islamic Investment Bank of the Philippines. These
banks are governed by their respective charters, and supervised and regulated by Bangko
Sentral. Bangko Sentral also regulates various non-bank financial intermediaries,
including finance companies, mutual building and loan associations, and non-stock savings
and loan associations.
There have been a
number of financial reforms since the early 1980s. Interest rate ceilings for banks were
removed in 1981 for deposits and in 1983 for loans. Bangko Sentral has considerably
relaxed the previous restrictive rules for bank entry. In 1989 the moratorium on the
establishment of new commercial banks was lifted. In 1994 the entry of foreign banks was
permitted. Restrictions on branching by existing banks were reduced in 1989 and again in
1993. Since 1987 the role of government banks has been reduced, with a shift in emphasis
from retail lending to wholesale lending using private banks as conduits. There have also
been changes to various prudential requirements, and certain foreign exchange transactions
have been liberalised. Bangko Sentral has set up a committee to review the Banking Act of
1935.
Notwithstanding these
reforms, the financial system of the Philippines remains relatively undeveloped. As a
measure of financial depth, in 1995 the ratio of money and quasi-money to GDP stood at
45.4 per cent. This ratio of money and quasi-money to the value of output is at
approximately the same level as in India (with a very much lower per capita income)
although higher than in any other of the South Asian countries considered here. It is
somewhat higher than in Indonesia, but well below the levels in Malaysia and Thailand (85
and 74 per cent, respectively). Bank deposit rates were virtually zero in real terms,
while an interest rate spread of more than 6 per cent between deposit and lending rates in
1995 appeared to reflect a domestic banking environment still somewhat cosseted from
market forces.
Reviewing financial
sector development in the Philippines soon after the commencement of the current regional
financial crisis, Intal and Llanto (1998) credit the financial system with achieving
progress in provision of financial services to the broader population over the last few
years:
The robust economic
recovery since 1994 in the Philippines has encouraged greater financial deepening. The
stable macroeconomy in recent years, with the implicit low inflation expectations, has
encouraged expansion of formal financial institutions deeper into the countryside and the
urban informal sector, thereby providing stronger competitive pressure vis-a-vis informal
financial intermediaries (for example, moneylenders) (p.48).
However, by early 1998,
the Philippines was experiencing currency devaluation, higher interest rates and loss of
output with higher unemployment. Yet no regulated financial institution had failed and the
severity of the crisis appeared much less than elsewhere in Southeast Asia. This was
attributed by Intal and Llanto to the countrys more robust financial system and its
comparatively recent participation in the regional boom in capital inflows. This has meant
lower and more favourable composition of external debt, and less speculation in real
estate.
1.4 Overview of
microfinance
In the Philippines the
terms microfinance and microenterprise development are still used
in some quarters as though they were synonymous. Many credit programs run by government
agencies, and the programs of a range of financial institutions (including rural and
thrift banks, credit cooperatives and the bankers association) may be referred to as
microfinancing but are in practice programs for microenterprise development
and not directed towards what in the Philippines are termed the ultra poor. Even among the
NGOs, many are concerned with the economic activities of persons of limited means and
without access to banks. But serving this category of people is not poverty alleviation
and the service itself is not microfinance.
In general, the banks
do not provide financial services to poor clients. Of all the banks, it is the rural banks
that are best placed to engage in microfinance. Rural banks are established to meet the
credit needs of borrowers who are often outside the catchment areas of commercial banks
and/or who may be considered poor risks by other banks. They are authorised to accept
savings and time deposits, and provide short-term loans for productive purposes with
minimum collateral requirements. In addition, cooperative banks may be organised to
perform banking and credit services for the cooperatives. Most rural and cooperative banks
do not have means-tested programs targeted to poor borrowers, and it is understood that
most of their clients are people in the rural areas who are slightly better off.
Nevertheless, there are
a number of rural banks that are active in providing small loans to poor borrowers, such
as the Cooperative Rural Bank of Santa Cruz, the Cooperative Rural Bank of Aklan, the
Davao Cooperative Rural Bank, and St Leonardo Rural Bank (which operates a microfinance
program based on the Grameen system). The World Bank (1996, p.64) comments that sufficient
evidence exists of the profitable provision of savings and credit services to the poor by
cooperative rural banks to suggest that . . . these banks offer an interesting
possibility for reaching the poor effectively without setting up alternative
institutions.
The Philippines has a
vibrant NGO community, and there are an estimated 500 NGOs providing microfinance
services. Most of the larger ones replicate the Grameen approach, with means testing of
borrowers, group formation and preparation, and the use of group guarantees. While there
is a large number of NGOs, none have particularly large programs and most are very small.
It is estimated that as at end-1995, the largest NGO program had only around 3,100 poor
borrowers, and the total outreach of the 500 odd programs was only around 30,000. However,
this is an area where estimates differ widely.
Most NGO programs are a
long way from operating on a sustainable basis. Llanto, Garcia and Callanta (1996) report
that fewer than 50 MFIs employ commercial lending and partly cover their costs. Most of
the larger NGOs lend at market-based interest rates and seek at least to cover their
operating costs. Nevertheless, in their study of six major MFIs and one cooperative rural
bank engaged in microfinance, only the cooperative rural bank was financially
self-sufficient, and only one of the MFIs was operationally self-sufficient.
There is a large number
of government credit programs designed to provide financial services to the poor. The
National Credit Council identified 111 government credit programs in 1995, of which no
more than 13 are targeted to the ultra poor. Of these, only four have significant
outreach: namely the Tulong sa Tao program of the Department of Trade and Industry; the
linkage program of the National Livelihood Support Fund; the microfinance program of the
Department of Social Welfare and Development; and the Micro Credit Program for the Bottom
Poor, a Grameen Bank replication project implemented by the Agricultural Credit Policy
Council and LandBank. Apart from the Department of Social Welfare and Development program,
these programs involve lending through NGOs as credit conduits. For instance, the
Agricultural Credit Policy Council project involves 23 NGOs and cooperative rural banks.
In general, credit programs operated by the government are highly subsidised. Llanto et
al. (p.14) comment that:
. . . Philippine
experience has shown the huge inefficiency and high costs of using government
non-financial institutions to implement credit programs. Recent research has shown the
unsustainability of government supply-led credit programs, the great capacity for leakage
of the benefits of government credit programs leading to gross inefficiencies, the
distortion of the financial market and weakening of private sector incentive to innovate.
In addition to the
banks and specialised microfinance institutions, non-stock savings and loan associations
supervised by Bangko Sentral provide savings and credit facilities to members. Membership
is confined to a well-defined group of persons, and they are not allowed to provide
financial services to the general public. As at end-December 1995, there were 88 non-stock
savings and loan associations in the Philippines.
There are also
cooperatives and credit unions, supervised by the Cooperative Development Authority. Some
42,000 cooperatives are registered under the Cooperative Code of March 1990 but half of
these are considered non-operative. Credit unions and cooperatives offer members fixed
deposits which cannot be withdrawn until membership ends, as well as savings and time
deposits which are withdrawable. This gives the cooperatives a larger resource base for
lending than is available to the NGOs.
Among the cooperatives
there are those promoted by the government to implement livelihood programs, most of whose
equity is contributed by LandBank. There are also grassroots cooperatives which have
national-level federations of their own. There are four such national federations, one of
which is NATCCO, the National Confederation of Cooperatives. This has a network of 1,700
affiliated primary cooperatives, a quarter of which are credit cooperatives. NATCCO
provides a range of services, including deposit guarantee insurance which is being
developed for selected member institutions. It may eventually open the guarantee scheme to
other cooperative federations. NATCCOs primary credit cooperatives may be cited here
as an example of privately initiated microfinance institutions which, on the evidence of
their small loan sizes (Ps5,000 to Ps6,000 or $200 to 240), certainly reach down to the
poor even if not serving them exclusively.
A distinctive form of
microfinance is provided by the lending investor. Lending investors are
basically moneylenders who are licensed by Bangko Sentral and subject to minimal
regulatory requirements and supervision. They are permitted to accept deposits from a
maximum of 19 individuals, and are permitted to make loans to whomever they wish. There
has been a rapid increase in the number of lending investors in recent years, and
increased competition has led to reductions in the interest rates they charge. Some 1,400
lending investors typically charge interest of between 3.5 and 4 per cent flat per month.
Together with more than 2,000 pawnshops, they deal with segments of the population usually
beyond the reach of formal financial institutions and compete with informal financial
sector lenders. They are characterised by simple procedures, low transaction costs, rapid
response and accessibility, but normally require collateral and probably do not reach the
ultra poor.
2 Arrangements for
direct support
The government has been
heavily involved in directly supporting microfinance, with the multiplicity of government
credit programs already discussed above. In some cases, government agencies lend directly
to final borrowers. However, the government has increasingly channelled funds through NGOs
as a means of providing credit to the poor. For instance, programs such as the Department
of Trade and Industrys Microcredit Project and the Grameen Replication Project of
the Agricultural Policy Credit Council use NGOs as credit conduits. LandBank uses the
National Livelihood Support Fund to channel funds to NGOs and other institutions for
relending to the poor. The government credit programs have been criticised for being
inefficient, highly politicised, uncoordinated and unsustainable; as described below, the
Department of Finance and the National Credit Council are currently working to rationalise
them. In their emerging framework, the Peoples Finance and Credit Cooperation (PCFC)
has a major role, also discussed below.
2.1 Support for
specialised microfinance institutions
As mentioned
previously, the government established the National Credit Council following the 1993
Social Pact on Credit. It has 22 members drawn from government agencies, government
financial institutions and the private sector. The council has four major objectives:
(1) to rationalise and
optimise government lending programs
(2) to develop a
national credit delivery system
(3) to encourage
private sector participation
(4) to define and
rationalise the role of guarantee and guarantee agencies.
The councils
focus has been exclusively on small credit and microcredit; it is concerned with the
operations of regulated financial institutions only to the extent that their activities
impinge upon these concerns. It has developed a set of guidelines, Policy Guidelines for
Credit for the Poor, applying to government agencies undertaking lending programs or
programs with a credit component. These guidelines argue that the Philippine banking and
financial system is capable of supplying most of the financial requirements for
microfinance, and that the role of donor agencies and external funding should be primarily
in technical assistance. The NCC guidelines also provide that government line agencies
should focus on technical assistance and capacity building for microfinance, and should
channel all their lending activities through banks and MFIs, including credit unions,
cooperatives and NGOs.
To date, NCC has had
limited success in achieving its objectives, as embodied in the National Strategy for
Microfinance of January 1997, or the credit policy guidelines described above. This is
because it has no authority to require modification or elimination of policies or programs
it believes are inconsistent with sound microfinance. The NCC has been relocated from
LandBank to the Department of Finance, to eliminate perceptions of conflict of interest
(given its aim of stripping lending functions from line agencies). USAID has provided a
technical assistance grant to strengthen it, but since the councils efforts at
rationalisation confront powerful bureaucratic and political interests, real progress is
likely to require sustained political backing at the highest level. The timetable for the
NCC calls for its work to be completed by mid-1998, at the end of the term of the current
Administration. No continuing role is envisaged for it beyond that date.
In addition to
establishing the National Credit Council for policy guidance, the government has taken a
number of other program initiatives with respect to microfinance. In 1994, credit was
included as one of nine flagship programs under the Social Reform Agenda of
the President, mentioned above. Following this, the government created the Task Force on
Credit for the Poor, from which flowed the Credit for the Poor Program.
This program has
developed a strategy of segmenting the various groups of the poor and encouraging
sustainable microfinance provision, with particular emphasis on the Grameen Bank approach
for the ultra-poor group. One of the major outcomes of this strategy has been the
Peoples Credit and Finance Corporation (PCFC), a second tier financial institution
to serve the credit needs of the poor.
The Peoples
Credit and Finance Corporation
In 1995 LandBank
established the Peoples Credit and Finance Corporation as a government finance
company for lending to the poor, and it continues to hold 99 per cent of the share
capital. It is incorporated under the Corporations Act and regulated by the Securities and
Exchange Commission. Its Articles provide for it to be privatised in due course.
PCFC is the executing
agency for a $26.3 million program funded by a loan from the Asian Development Bank (ADB)
and the International Fund for Agricultural Development (IFAD). These funds are to be
provided exclusively for PCFC to support MFIs replicating the Grameen Bank approach. The
loan allocates resources in favour of a particular model, rather than by objective
evaluation of the performance of MFIs already active, whatever model they follow.
As this study shows,
there is a variety of indigenous institutions exploring various paths to sustainable
microfinance provision in the Philippines. Thus, in mid-1997, PCFC was funding 58 conduit
institutions from its National Livelihood Support Fund (NLSF) reserves, only 17 of which
were Grameen replicators. The World Bank (1996, p.65) notes that:
The Grameen Bank model
is not the only successful approach to microfinance, and the current emphasis on Grameen
replication as the only way to reach the ultra-poor may be discouraging the expansion of
other successful models in the Philippines.
PCFC should be
permitted to be even-handed in its support of MFIs, focusing on their effectiveness and
performance, objectively evaluated. Failure to maintain even-handedness is likely, under
current conditions of a credit squeeze affecting commercial bank sources of
credit for microfinance (discussed in section 2.2 below) to cause the impact of financial
sector stringency to fall disproportionatly on non-Grameen Bank MFIs.
PCFC is registered as a
finance company, not supervised by the central bank, but reporting to it. More onerous
supervision, and adherence to banking ratios and other norms, would be required for it to
progress to quasi-bank status. PCFC has given undertakings to the ADB to conform with the
quasi-bank guidelines as a preparation for upgrading to that status.
PCFCs issued
capital is Ps100 million and will be increased to Ps400 million. The initial
capitalisation was provided by NLSF, and the corporation commenced operations by taking
over NLSFs loan portfolio. PCFC defines microfinance institutions broadly: it
provides funds to NGOs, rural banks, cooperatives and other intermediaries as conduits for
on-lending to the poor, and aims to ensure that such intermediaries are replicable,
self-sustaining and operationally viable. NCCs strategy for the corporation calls
for it gradually to replace many of the other lending programs operated by line agencies
of government.
The ADB is requiring
PCFC to complete a privatisation plan by mid-1998, with a view to completing the process
by end-1999. Its shareholding is envisaged as a mixture of government and public
shareholding. In particular, it is hoped that MFIs and other institutions which form the
constituency for PCFC will take up stock. In preparation for privatisation, the
corporation has been called upon to show a profit. Consequently, for the present PCFC has
adopted the policy of extending credit lines only to intermediate and
advanced MFIs, where profitability is more assured. For MFIs at the
start-up or beginner phase, it plans in due course to mobilise
funds from government, UNDP and bilateral sources. It could thus become a force for
multiplying the numbers of MFIs, as well as increasing the outreach of established
institutions.
At the time of the
fieldwork for this study, PCFCs loanable funds were sourced entirely from NLSF. With
a cost of funds of 6 per cent, the corporation was lending to intermediaries at 12 per
cent on the diminishing balance and required them to charge a market rate (at least 2 per
cent per month). The corporations spread of 6 percentage points was felt
adequate for normal operations. However, funds were also loaned to conduits
for capacity building. These were soft loans, and although limited to 20 per cent of total
outstandings, were a source of concern, given the need for PCFC to show a profit. After
privatisation, the government should accept greater responsibility for capacity building.
A further concern, in
regard to PCFCs ability to turn a profit, was that the ADB/IFAD funding proposals
would allow it a spread of less than 6 percentage points and that the pass-on
rate stipulated for these funds was only 10 per cent. This would compare with a cost of
funds for non-Grameen intermediaries, as noted above, of 12 per cent. PCFC should be
permitted to be even-handed in regard to interest rates for all MFIs, and to avoid the
distortions which differential rates would involve. Continuing negotiations over this and
other issues appeared to be delaying the disbursement of the loan by the multilaterals. A
second ADB/IFAD loan of $157 million has also been signed.
PCFC deserves support
as an integral part of the strategy to rationalise the provision of microfinance in the
Philippines. Donor agencies should seek so far as possible to channel support for
microfinance through PCFC in preference to line agencies of government. They should also
avoid supporting unsustainable credit operations mounted through such agencies, which
would be better employed offering technical assistance in the areas of their special
competence.
Support for capacity
building
PCFC is also
responsible for providing technical assistance to strengthen NGOs. The soft loans it
provides for this purpose are mentioned above in the context of its needs to achieve
profitability prior to privatisation. In this respect the corporation is better resourced
than PKSF in Bangladesh, which has only loanable funds to offer MFIs. In the 1997 budget,
the government allocated Ps100 million for capacity building for MFIs under its national
Poverty Alleviation Fund, a quick response fund targeting minimum basic needs,
of which the corporation is an implementing agency. The ADB/IFAD loan to PCFC also has a
capacity-building component. Soft credits will be available to Grameen replicators for
start-up costs, training and self-help group formation and training.
In regard to capacity
building for MFIs, the corporation works with the Punla sa Tao Foundation (Punla). A
complementary initiative to PCFC, Punla is a non-stock non-profit entity operating as an
NGO. It was created at the initiative of the Presidential Commission to Fight Poverty and
business interests to build the capacity of institutions to provide financial services to
the poor. Punla is represented on the board of PCFC, and on the NCC working group
concerned with the ultra-poor, and provides microfinance training services (for example,
preparing the training modules for capacity building financed this year under the Poverty
Alleviation Fund). It operates on a fee-for-service basis as well as raising funds from
the corporate sector and elsewhere. It is an interesting model for an organisation
designed to catalyse public and private support for capacity building in microfinance, and
will offer management and research as well as training. Punla should be adequately
financed and creatively involved by government in the process of equipping MFIs to meet
the challenge of greatly expanding their outreach in the Philippines.
2.2 Support through
the banking system
Directed credit schemes
Banking institutions
are required to allocate at least 25 per cent of loanable funds to agricultural credit, of
which at least 10 per cent must be for agrarian reform credit. The 25 per cent allocation
can include investments in certain government securities and loans to educational
institutions, cooperatives, hospitals, low-cost housing and local government units.
However, in 1995 banks were exempted from these requirements so long as a minimum of 5 per
cent of their loanable funds were lent to farmers associations or cooperatives.
Under the Magna Carta for Small Enterprises, all lending institutions are required to set
aside portion of their loan portfolios for small enterprise credit. The portion mandated
is 5 per cent from 31 December 1996, although the requirement may be abolished by 31
December 1997. Such lending has had little relevance to poverty alleviation in any case
and the case for retaining it is not strong, given that conditions appear favourable for
market forces increasingly to provide the necessary services.
Programs channelled
through the banking system
Government agencies
also provide support to banks involved in microfinance. Rural banks are able to rediscount
eligible papers with Bangko Sentral at preferential rates of interest. In an emergency or
financial crisis, Bangko Sentral may give a loan to a rural bank against the security of
its assets. Bangko Sentral also provides technical support to rural and cooperative banks.
It provides them with free technical assistance both during the process of organisation,
and when they are already in operation. It also conducts training programmes for rural
bank personnel free of charge.
Linkages between
banks and specialised microfinance institutions
Linkages between
commercial banks and MFIs are seen as one means by which the resources of domestic
financial systems can be marshalled for the benefit of the poor. Such linkages have arisen
in the Philippines with the support of external donors, as the result of political
pressure, and with the benefit of tax breaks designed to encourage corporate philanthropy.
At the time of fieldwork for this study, in mid-1997, there was also increasing evidence
of such linkages occurring on a commercial basis.
One such project with
official support is the Project Linking Banks with Self-Help Groups, conducted jointly by
the LandBank, the Philippine Council for Rural Savings and Finance and the German
technical cooperation agency, GTZ. With heavy emphasis on institution-building support
from GTZ, this is one of a number of such projects the German government is supporting in
Asia. At end-1995, according to APRACA (1996), a total of 16 conduit MFIs
served by 53 bank branches were dealing with some 670 self-help groups in the Philippines.
These groups, with more than 32,000 members, received loan disbursements of almost $8
million and mobilised deposits of some $0.7 million. Not much otherwise is known about the
performance or sustainability of these group-based schemes.
There have also been a
number of private Philippine initiatives in this field. The Social Pact on Credit,
mentioned above, was agreed in 1993. It involved private banks, as well as government
agencies and financial institutions and other stakeholders. Among its results was
increased awareness among private commercial bankers of the possibilities of microfinance.
Subsequently, during 1994 the Bankers Association of the Philippines (BAP)
established its own Credit Guarantee Corporation (CGC) to provide guarantee cover to
member banks lending to microfinance institutions. BAP has also supported training courses
for NGOs in microfinance management.
A total of Ps784
million ($31.36 million) was reported to have been lent as working capital
loans with the facilitation of CGC during the first three years of its operation. The
average loan size was Ps264,000 (around $10,500), not a very useful statistic for our
purposes, since it seems to relate both to loans made to MFIs and to individual loans.
Loans written under CGC auspices cover a very wide range and certainly include small
(rather than micro) business borrowers. The borrowers assisted are marginal to the
commercial banking system, and unable to qualify for loans under normal criteria. To that
degree, the scheme answers a social need and can be seen as a response to the Social Pact
on Credit. However, the need addressed does not seem to be poverty alleviation, except
perhaps at the bottom end of the range of CGC-guaranteed loans.
Linkages between
commercial banks and MFIs are facilitated by tax breaks available to corporations in the
Philippines (including private commercial banks) which set up charitable foundations. In a
number of cases, banks have been able to conduct exploratory ventures in support of MFIs
by channelling the necessary resources via their foundations (and reducing their exposure
to losses in the process). One such foundation is the BPI (Bank of the Philippine Islands)
Foundation.
The BPI Foundation had
resources of about Ps30 million ($1.2 million) in mid-1997, and had extended lines of
credit to nine NGOs and three credit cooperatives at a soft interest rate of 8
per cent for on-lending to the poor (as against commercial rates of between 14 and 16 per
cent). On average, each of these MFIs had received a line of credit of Ps1 million
($38,000) from the foundation, and on-lent to group members at interest rates ranging from
18 to 30 per cent, which yields a fairly high margin. About 1,600 individual loans had
been financed in this manner. The BPI Foundations dealings with NGOs had been more
satisfactory than those with credit cooperatives; the repayment rate from NGOs was 100 per
cent and that from cooperatives around 80 per cent. However, total funds made available
through this window to NGOs have not been very significant in relation to the
foundations current resources, indicating a very cautious approach to this lending.
MFIs intending to
borrow from the BPI Foundation have to meet the following conditions:
(1) a good track record
for at least three years
(2) annual audited
accounts
(3) repayment rate not
less than 90 per cent
(4) loans targeted to
the poor (although the foundation does not apply a means test).
The BPI Foundation
monitors the continuing compliance of MFIs with these requirements.
A number of other
banks, including Solid Bank and Far East Bank, have also set up foundations. Motives for
involvement in microfinance in this way are mixed, ranging from tokenism to a genuine
interest in trialling microfinancing in an environment of reduced risk. Banks which
commenced financing MFIs in this way, notably BPI itself, were in 1997 making the
transition to full and profitable commercial financing of MFI operations without benefit
of a tax shelter. The study conducted for the BWTP Network in the Philippines by Ms Ruth
Goodwin-Groen (forthcoming) provides empirical data relating to the successes of these
private commercial initiatives. In India the publication of guidelines in support of
bank/MFI linkages by NABARD has been a positive influence. Bangko Sentral could play a
similar leadership role in the Philippines.
One powerful motive for
the growing interest of commercial banks in microfinance is the potential for savings
mobilisation from relatively untapped sections of the national population, allied with the
growing competitive pressures to which the industry is becoming subject. They are
acquiring small banks and showing increasing interest in agency arrangements with NGOs to
tap into the market. The possibility exists for them to assist in the creation of NGOs for
this purpose or (as happens in Indonesia) forming self-help groups directly for financial
services. These would be positive developments and should be encouraged. Such
principal/agent relationships need not be exploitative, and the demand for
savings services is in the long run likely to be much greater than the demand for credit,
as the experience of Bank Rakyat in Indonesia suggests.
However, effects of the
regional financial crisis in the Philippines financial sector since late 1997 have
included interest rate increases and the reversion to extremely conservative lending
practices by commercial banks. Credit lines available to MFIs, where they are rolled over
at all, are renewed at higher rates of interest and with stricter collateral requirements.
While the overall impact is not yet clear, current conditions are not conducive to
expanded commercial bank engagement with microfinance.
2.3 Direct government
programs
Mention has been made
at a number of points of the multiplicity of government-administered credit programs which
persists in the Philippines, whose rationalisation is the objective of the National Credit
Council. The NCC has classified them by sector (table 5).
These government-run
credit programs were enumerated in 1995 and involved many agencies of government. Only 13
were said to focus on the ultra poor. More recent information indicates that
the actual number of programs is even greater; the latest tally appears to be between 140
and 150, involving around 45 agencies. Lending under these programs is direct as well as
through NGO conduits.
3 Regulation of
non-bank microfinance institutions
3.1 The broad
regulatory framework
Non-governmental
organisations
Non-governmental
organisations (NGOs) in the Philippines are classed as non-stock, non-profit
organisations, and registered with the Securities and Exchange Commission (SEC). They are
not closely supervised by the SEC, but must file audited annual financial statements with
it. For an NGO to achieve registration, it must nominate a board of directors (between
five and 15 members) a majority of whom should be citizens of the Philippines. Personal
information must be provided to determine the standing of persons nominated. The initial
capitalisation required is a minimum of Ps50,000 ($2,000). The NGO must provide proof of
its financial standing.
After the approval of a
name for the organisation, it is necessary to file articles of incorporation and by-laws.
The SEC provides a pro forma set of by-laws as a guide. Applications are
reviewed in less than a month and are normally approved, following which the business name
of the NGO is registered with the Department of Trade and Industry. Registration with the
Bureau of Internal Revenue is also required. Finally, it is necessary to obtain approval
at the municipal level, and a licence to operate in a particular locality.
In principle, NGOs are
liable to tax at the rate of 5 per cent of gross revenue. However, after operating for a
minimum of one year, application can be made to the Bureau of Internal Revenue for tax
exemption, on the basis that the NGO has shown itself a bona fide charitable organisation.
This, however, appears to be an area of some concern to many NGOs. Annual reports must be
filed with the SEC, together with a general information statement and audited financials.
These are copied to the Bureau of Internal Revenue. The processes of registration and
annual reporting are relatively simple, with the exception of proving bona fide status for
tax exemption. It is necessary to show that activities are not conducted for benefit of
directors.
While NGOs are subject
in principle to ongoing supervision, in practice they appear to be examined rarely. NGOs
are required to keep all records for a minimum of five years, to observe minimum wage
legislation and to register employees with the social security system. Foreign donations
must be reported with the annual accounts, but are not subject to any control or
supervision.
Guidelines for
governance are set out in the pro forma Articles supplied by the SEC. In cases of dispute
within an NGO, an appeal can be made to the SEC. Overall, the SEC appears to apply a very
light touch with registered NGOs and the regulatory environment appears relatively
permissive. On the other hand, ambiguities affecting the tax status of NGOs appear to be
of concern to many organisations. For example, rural banks and cooperatives are exempt
from income taxation and some NGOs feel that this is discriminatory. The procedures for
exempting bona fide NGOs from tax should be clarified and simplified, and such exemptions
should not unreasonably be withheld.
NGOs are not permitted
to accept deposits from the general public. Moreover, the legal situation with regard to
accepting deposits from members is unclear. Many NGOs are reported to have an informal
deposit-taking relationship with members, using devices such as accepting
funds for capital buildup. Llanto, Garcia and Callanta (1996) comment that
this is skating on thin ice because of potential legal sanctions against this illegal
activity. Under the Banking Act non-stock and non-profit organisations are not permitted
to accept savings and deposits in any form. As a consequence, they have to depend on
external sources for funding. External funding being uncertain and limited, NGOs
ability to expand their lending outreach has been correspondingly limited.
This has caused some to
call for a separate legal framework to be created for NGOs, with their being authorised to
collect deposits. The reaction of some NGOs has been to seek registration as formal
financial institutions under the laws currently applicable, accepting the regulatory and
prudential requirements of Bangko Sentral. Some argue for special arrangements to suit
their circumstances, in regard to the capital requirements for small banks, and whether
the current requirements for rural banks can be stretched to accommodate NGOs.
Others see the value of continuing within the relaxed regulatory environment which has
facilitated NGO activity in the Philippines.
These are major issues
in the current state of development of NGOs as microfinance institutions in the
Philippines, on which there is no consensus as yet. The review of the Banking Act of 1935,
mentioned in section 1.3 above, may involve consideration of the range of deposit-taking
institutions; for NGOs to gain this capacity would require amendment of the Act. The NCC
is also considering the overall regulatory framework for MFIs in the Philippines.
NGOs should be
permitted to collect compulsory savings from clients in the course of providing
microfinance services. In the same context, they should probably also be permitted to
handle voluntary savings while satisfying agreed standards of accounting and reporting.
The issue of how such standards might be agreed is discussed below, but it is relevant to
note here that most commentators in other countries do not think that MFIs should be
subject to official prudential regulation and supervision. This much is clear from the
case studies conducted in parallel with this study of the Philippines, and from the wider
literature.
Credit unions and
cooperatives
Credit unions and
cooperatives are registered under the Cooperative Code of 1989, which for the first time
brought all types of cooperatives under one law and one government agency. The legislation
recognises the role of cooperatives in promoting equity, social justice and economic
development. This code also covers credit cooperatives and cooperative banks. The
responsible agency is the Cooperative Development Authority (CDA). Apart from its
regulatory and supervisory roles, the CDA also has a developmental role with respect to
the cooperative movement. There is some suggestion that the developmental role of the CDA
is not entirely consistent with its regulatory and supervisory roles.
A primary cooperative
may be organised and registered by as few as 15 persons, and with minimum cash reserves of
Ps2,000 ($80). To support the application, a simple economic survey justifying
the purposes and economic feasibility of the proposed cooperative must be prepared. The
encouragement of thrift and savings mobilisation among the members, and the granting of
loans to members for productive purposes are among the basic objectives of cooperatives
mentioned in the legislation.
A primary cooperative
is registered with limited liability and share capital held by the members. It is required
to file Articles of Cooperation, as well as by-laws dealing with membership and governance
of the cooperative, consistent with the provisions of the Cooperative Code. Applications
for registration must be dealt with promptly by the CDA.
The Cooperative Code
makes provision for credit cooperatives to mobilise savings among their members and to
pool such savings for the purpose of granting loans to members for productive or
provident purposes. Credit cooperatives may not, however, accept deposits from the
public. All cooperatives are exempt from the payment of taxes for a period of ten years
after their formation. Cooperatives which deal with non-members and which accumulate
assets beyond Ps10 million ($400,000) may incur some tax liabilities after ten years. The
code also provides for the registration of cooperative banks under the supervision of the
central bank, but with provision for exemption from some central bank rules and
regulations.
3.2 Interest rates
There are no interest
rate restrictions applying to MFIs, leaving them free to set their own interest rates. On
the other hand, the proliferation of government-sponsored credit schemes introduces
substantial subsidy elements into microfinance in the Philippines. The possible
discrepancy between interest rates to be charged by the Peoples Credit and Finance
Corporation (PCFC) to MFIs which are Grameen replicators and qualify for ADB/IFAD funding,
and other MFIs which do not, has been noted above. Such discrepancies and the battery of
subsidies already in existence, introduce damaging distortions into the market for
microfinance, discouraging private initiatives. These distortions should not be allowed to
continue.
3.3 Prudential
regulation and supervision
At present, there is no
prudential regulation of NGOs operating microfinance programs. There are no minimum
capital requirements, nor are there any requirements concerning capital adequacy,
liquidity, reserves or loan loss provisioning. For cooperatives, prudential requirements
monitored by the CDA include the filing of annual reports. It appears that the level of
compliance with full audit requirements is only around 20 to 30 per cent for all
cooperatives. There are no minimum capital or provisioning requirements. As mentioned
above, NATCCO (one of the national federations of private cooperatives) is establishing a
deposit guarantee scheme for member credit cooperatives. This has regulatory implications
since NATCCO is setting performance standards for members to join the scheme, and may also
widen membership to other federations in time. This could have beneficial effects by
encouraging higher standards more widely throughout the cooperative movement.
Some standards for MFIs
would appear appropriate. Llanto et al. found that a number of major MFIs have inadequate
financial reporting and monitoring, making it difficult to determine past due loans and
the extent of arrears. They also found that the absence of adequate and sound performance
standards and a standardised accounting and reporting system makes it difficult to
evaluate the relative performance of MFIs. They concluded that:
In sum, internal
financial policies and practices need a lot of improvement, particularly in the
installation of sound financial reporting and monitoring systems, portfolio management,
assessment and management of risks, product packaging and pricing, management of loan
arrears and strategic business planning. Related to these will be the need to upgrade and
institutionalise performance standards, particularly in loan repayment, appreciation of
loan default and ageing of delinquent accounts, and the installation of appropriate
accounting and internal audit systems (p.21).
The National Credit
Council will shortly conduct a review of the regulatory environment for NGOs engaged in
microfinance. This work is supported by a technical grant from USAID and could lead to the
establishment of standards for prudential regulation and supervision, perhaps (as
suggested below) in concert with the self-regulatory efforts of MFIs themselves.
3.4 Performance and
reporting standards of second tier institutions and other agencies
A number of agencies
with some degree of oversight of MFIs are in a position to establish performance and
reporting standards for them. In the Philippines, such agencies include the second tier
body set up for the industry by government, the Peoples Credit and Finance
Corporation (PCFC). Others which might do so include the National Credit Council and
LandBank. The latter has the potential to do so by virtue of its position as a major
provider of loanable funds to MFIs (a role which would be strengthened if NCCs goal
of stripping lending away from government line agencies is achieved).
PCFC is not a
regulator, but rather a funding body which provides lines of credit at concessional
interest rates to NGOs and other MFIs. Nevertheless, it imposes certain conditions on MFIs
before they can obtain loans from it. Accreditation for NGOs and peoples
organisations (that is, cooperatives and credit unions) with PCFC is secured on the basis
that:
- they are duly registered with the SEC,
central bank or Cooperative Development Authority
- they have a three-year track record in
lending
- their working capital is at least
Ps250,000 ($10,000)
- lending operations are segregated from
other activities with appropriate full-time staff
- past due loans are not more than 20 per
cent
- no loans are in arrears to PCFC or other
agency
- established systems of proven
effectiveness are in place.
PCFC has set minimum
performance standards for its accredited MFIs in start-up, intermediate and advanced
categories. This recognises that institutions progress as their capacities improve, and
provides for this progression in the standards. The corporation is critical of the single
set of ultimate standards promulgated by CGAP (the Consultative Group to
Assist the Poorest, whose secretariat is located in the World Bank), seeing them as out of
reach for the great majority of Philippine practitioners at present. Some quantifiable
standards are set out below (table 6). In addition, the corporation has set guidelines
relating to such qualitative issues as governance, information systems and staffing to
benchmark the standards thought necessary at each stage of an institutions
development.
In the case of banks,
PCFC requires a 10 per cent ratio of capital to risk-weighted assets; a past due rate not
exceeding 15 per cent for commercial banks and 20 per cent for rural financial
institutions; no deficiencies in reserve requirements for one year preceding the
application; no major deficiencies in the most recent Bangko Sentral audit; and no loan in
arrears with any public or private lending institution.
These requirements are
not very detailed. Nevertheless, as PCFC expands its role in lending to MFIs and to the
extent that other programs are rationalised, there is considerable scope for any standards
imposed by PCFC to become more general industry standards. In this connection, the
experience of PKSF in Bangladesh is likely to be of value. In developing such standards,
it would clearly be desirable to coordinate with the work being done by the National
Credit Council and the Microfinance Coalition for Standards as well as ensuring
consistency with requirements imposed on MFIs (principally cooperatives) by LandBank. The
work of the coalition is discussed below in section 3.5 on self-regulation.
The NCC has developed
the Policy Guidelines for Credit for the Poor applying to government agencies undertaking
lending programs or programs with a credit component. In some respects, these also provide
a basis for a regulatory framework for the industry. For instance, the guidelines provide
that credit programs must promote a savings mobilisation or capital build-up program. (In
this respect the NCC goes further than PCFC, which does not emphasise savings in its
performance standards for MFIs.) The guidelines suggest that such savings be deposited
with banks to serve as partial collateral for loans. They also cover such matters as the
equity contribution of borrowers, interest rates, and collateral and guarantees.
Nevertheless, the relevance of the current guidelines for prudential regulation and
supervision of MFIs is limited because of the following:
(1) The guidelines are
intended primarily for government agencies, and even here the NCC has not been effective
in ensuring compliance.
(2) Some of the
guidelines do not seem appropriate in terms of encouraging sustainable microfinance. For
instance, the guidelines on interest rates appear confusing and inconsistent. On the one
hand, the guidelines state that interest rates should cover the full lending cost,
including the cost of funds and transactions, administrative and monitoring costs. On the
other hand, they suggest that in the case of loans to small farmers, the maximum rate of
interest should not exceed 75 per cent of the commercial rate inclusive of all charges.
(3) The guidelines do
not cover many items relevant to prudential supervision. For instance, they do not cover
issues such a minimum capital requirements, capital adequacy, reserve or liquidity
requirements, loan loss provisions or reporting standards.
In summary, it is clear
that some setting of standards for MFIs would be appropriate. The task will be facilitated
if second tier agencies and other strategically placed institutions are involved in the
regulatory process. Agencies with oversight of MFIs, notably PCFC, but also the National
Credit Council and LandBank, are in a position to exert influence. For the credit
cooperatives, the deposit insurance facility being created by NATCCO may also provide the
opportunity for setting standards, perhaps leaving the Cooperative Development Authority
more free to concentrate on its developmental functions for the great mass of
cooperatives.
All these second tier
agencies have commenced to set criteria for accreditation for MFIs, and to define
performance standards for them. It is important that there be coordination and consistency
between the standards set; if the National Credit Council is to have a continuing
existence this coordinating function could appropriately rest with it. Otherwise, PCFC
should accept responsibility for coordinating standards for MFIs; in this regard the
experience of second tier institutions such as PKSF in Bangladesh would prove instructive.
Where initiative exists
within the private sector to take the lead in self-regulation, this is usually preferable
to the imposition of standards by second tier or other supervisory institutions. This
possibility is discussed below.
3.5 Self-regulation
Networks of
microfinance institutions
There are two major
networks of MFIs in the Philippines. These provide a focal point for coordination and, to
a more limited degree, self-regulation among their members. However, both have limited
memberships, with each embracing only a small number of MFIs. The two networks are APPEND
(the Association of Philippine Partners in Enterprise Development) and PHILNET, a group of
MFIs engaged in Grameen replication, affiliated with the international CASHPOR network of
Grameen institutions. Reference has also been made in section 3.3 to the efforts of NATCCO
to set performance standards for credit cooperatives as a condition for membership of its
proposed deposit guarantee scheme. This would provide a mechanism for self-regulation in
the cooperative movement, where formal regulation under the Cooperative Code is lacking.
APPEND is an NGO
registered on the same basis as its nine member institutions. Its regulatory functions
include the examination of the financial statements and operations of member
organisations. APPEND acts in a collegial manner to secure adherence to agreed standards
by member institutions, with its executive director having responsibility for oversight.
In addition, APPEND has a number of other functions:
(1) joint provision of
training for member institutions (conducted for boards, chief executives and management
staff, loans officers and others)
(2) resource
mobilisation on behalf of member institutions (both donor funds and commercially sourced
funding)
(3) acting as a project
management office for special projects conducted jointly by APPEND members with donor
agencies
(4) acting as a lender
of last resort to member institutions with liquidity problems
(5) performing an
advocacy role on behalf of member institutions.
PHILNET has seven
member institutions and is planning to appoint full-time staff to perform administrative
and regulatory functions, in particular, the accreditation of potential new members of the
network. Regulatory standards within the group are based on the essentials of the Grameen
model; member institutions are required to report program and financial data to CASHPOR,
and these data serve as the basis for monitoring individual institutions. The Chair of
PHILNET intervenes when necessary to assure improvement in performance of member
institutions. However, to date, the regulatory capacity has resided more within CASHPOR
than in PHILNET itself (an exercise in transnational self-regulation).
In addition to the two
networks described above, a major new initiative in self-regulation, the Developing
Standards for Microfinance Project (DSMP) was set up in 1996. Funded by USAID the project
has set out to develop and promote standards for microfinance operations. In the process
of developing these standards, the project has achieved the following:
(1) It has formed a
coalition (the Microfinance Coalition for Standards) that will develop and promote the
standards. The coalition has 55 member institutions including leading NGO microfinance
practitioners, the central bank, PCFC and other government planning and regulatory bodies,
two commercial banks, private foundations, academic and research organisations and donor
agencies.
(2) It has begun to
build the database necessary for benchmarking and standard setting (this has involved a
nationwide inventory of microfinance NGOs and in-depth studies of selected MFIs).
(3) It has commenced
the process of documenting best practice among MFIs in the Philippines, with the objective
of arriving at benchmarks or standards for good practice.
(4) It has encouraged
consultation and consensus building among the members of the coalition.
(5) It has conducted
seminars, training activities and conferences (to build awareness of the need for
standards and to disseminate standards). These will culminate in a national microfinance
summit in 1998).
The DSMP is now working
towards these objectives and has developed a conceptual framework for benchmarking the
performance of MFIs. Setting these benchmarks and measuring the performance of
institutions against them involves the collection of quantitative and qualitative data by
institutions themselves and external observation of their performance. Table 7 summarises
the yardsticks available for the measurement and evaluation of performance.
The yardsticks draw on
the observation of past performance within particular institutions and on the observation
of performance of the microfinance industry as a whole. This enables the
determination of benchmarks which embody best practice in the industry. Finally,
benchmarks are extended into the future with the shaping of budgets, strategic plans and
business plans, to guide the future development of institutions. The quality of these
plans is an important indicator of the standing of an institution.
The indicators to be
observed (which seem to be based quite closely on those of the Donor Working Group,
published in 1995) are categorised by the DSMP in its conceptual framework as under:
(1) Organisational
and operational factors organisation structure, culture and capacity
management information systems operational efficiency
(2) Outreach and
services scale and depth of outreach microfinance services
(3) Financial
sustainability self-sufficiency portfolio quality
Developing performance
standards such as those sketched out above is the first step in a process. Further steps
include assisting MFIs to adopt the standards, and moving beyond that to assure widespread
implementation of them by MFIs. This may involve some regulation of the MFI sector
(whether self-regulation or the external imposition of standards upon the industry).
In any case, the DSMP
is working towards the development of a capacity measurement system to
identify the strengths and weaknesses of individual MFIs. This implies a rating system for
MFIs based on the indicators which have been developed. A rating system would be useful to
domestic financial institutions which need information to assess the bankability of MFIs.
Government and donor agencies would find a rating system for MFIs useful in indicating the
need for interventions and support.1
Finally, the coalition
suggests that a regulatory and supervisory framework will have to be developed for the
microfinance industry: This may involve establishing a system of accrediting NGOs
which have adopted the standards, a system of reporting and validation and a system of
rewards or penalties for compliance or non-compliance. The coalition hopes to arrive
at an agreed consensus on standards and to present its recommendations to the Philippines
National Microcredit Summit to be held in 1998.
In summary,
considerable progress has already been made by the Microfinance Coalition for Standards
and the two major microfinance networks, APPEND and PHILNET. The work of the Developing
Standards for Microfinance Project is receiving support from USAID. This could lead to the
development of systems of capacity measurement for MFIs and a rating system
which would be useful to domestic financial institutions and government and donor
agencies.
It is appropriate to
continue support for the development of a regulatory and supervisory framework by the
microfinance industry itself, leading to a system of accrediting NGOs. To the extent this
goes beyond self-regulation, close liaison between the microfinance coalition and PCFC,
the National Credit Council and other interested agencies should be encouraged.
4 Regulation of
banks
4.1 Licensing and
minimum capital requirements
All institutions which
engage in the lending of funds obtained from the public through the receipt of deposits
are required to be approved by the board of Bangko Sentral for licensing as banking
institutions. As such, NGOs wishing to expand their sources of funds by accepting deposits
from the public need to become licensed as financial institutions. At least two NGOs, in
Nueva Ecija and Zambales provinces, have already become rural banks and some other NGOs
are considering becoming banks.
As noted above, there
are a number of different types of banks, in particular, commercial banks, thrift banks
(including savings and mortgage banks, private development banks, and stock savings and
loans associations), and rural and cooperative banks.
All of these banks are
regulated by Bangko Sentral, but they are licensed under different Acts of Parliament. The
General Banking Act defines the scope of activities of each type of bank in broad terms.
In addition, the Rural Banks Act 1992 provides for the creation, organisation and
operation of rural banks, the Cooperative Code of the Philippines (1989) governs the
organisation and operations of cooperative banks, and thrift banks are covered under the
Thrift Banks Act 1995.
The most significant
difference concerns the minimum capital requirements for banks. The minimum capital
required to establish a commercial bank is Ps4.5 billion ($180 million) for expanded
commercial banks (which combine the powers of commercial banks and investment houses), and
Ps2 billion ($80 million) for ordinary commercial banks. However, capital requirements for
other types of banks are much lower. The requirement for a thrift bank is Ps250 million
($10 million) if the head office is in Metro Manila, and Ps40 million ($1.6 million) if
the head office is outside Metro Manila. In the case of rural banks, minimum capital
varies from Ps20 million ($800,000) down to Ps2 million ($80,000), depending on the
location of the head office. There are also minimum capital requirements for establishing
bank branches, with higher requirements for commercial banks than for thrift banks and
rural banks. A national cooperative bank requires minimum share capital of Ps200 million
($8 million), while a local cooperative bank may have minimum share capital of as little
as Ps20 million ($800,000).
The regulatory
framework in the Philippines which enables rural banks and local cooperative banks to be
established with modest capital requirements is a positive feature of the environment of
microfinance in that country. Together with similarly favourable provisions in Indonesia,
this provides a model for other countries in the region, since such banks have
demonstrated their capacity to access the poor.
For MFIs wishing to
expand their operations by accepting deposits from the general public, the requirements
for obtaining a banking licence as a rural bank or even a thrift bank would not appear to
be too difficult to overcome. At least two NGOs have already obtained licences as rural
banks. The largest NGO engaged in microfinance, TSPI Development Corporation, is currently
applying for a licence as a thrift bank, and a number of other NGOs are also looking at
becoming banks.
4.2 Interest rates
Deregulation of
interest rates in the banking sector, with respect to both deposits and advances, is now
complete. This has established an environment in which the involvement of regulated
financial institutions with microfinance can flourish if other conditions are favourable.
Interest rate distortions in the market for microfinance, arising from the activities of
government line agencies engaged in a proliferation of subsidised credit programs, are a
continuing disincentive to private initiative in the field.
4.3 Prudential
regulation and supervision
Regulatory and
prudential requirements differ between the different types of banks. Capital adequacy
ratios are generally the same for all banks at 10 per cent of risk-weighted assets.
However, some large commercial banks are permitted to lend out 12.5 times their capital
base with approval from the Monetary Board. Reserve requirements differ between the
different types of banks. Since July 1997, the reserve requirement for demand, savings and
time deposits and deposit substitutes is in general 13 per cent. However, there are lower
requirements in the case of savings and time deposits for thrift banks (11 per cent) and
rural banks (5 per cent). In addition to these reserve requirements, all financial
intermediaries are required to maintain a liquidity reserve equal to 2 per cent of deposit
liabilities and deposit substitutes, in the form of short-term market yielding government
securities.
Bangko Sentral does not
require that loans by banks be secured, except in the case of loans to directors, officers
and stockholders. However, the central bank has issued detailed instructions concerning
loan loss provisioning, and loans without collateral are treated differently to secured
loans. Loans in arrears are divided into three categories based on a number of criteria,
with a required loan loss provision of 25 per cent for the unsecured portion of
substandard loans, 50 per cent for doubtful loans and 100 per cent for loss loans. The
categorisation of loans depends in part on the security. For instance, an unsecured loan
is generally classified as substandard where it is past due for more than ninety days,
whereas a secured loan is generally only classified as substandard where it is past due
for more than six months.
Reporting requirements
are broadly similar for all banks. All banks are required to submit a weekly report to
Bangko Sentral on their reserve holdings and capital position. In addition, they are
required to submit a consolidated balance sheet on a monthly basis, and a quarterly report
on income and expenses. All banks are required to have articles of incorporation and
by-laws covering matters such as the stock and stockholders, meetings of stockholders,
board of directors and similar matters.
Thrift banks and rural
banks are exempted from all taxes and charges, except for income tax and local taxes and
charges, for five years from the date they commence operations. Existing rural banks
received tax exemption for five years when the Rural Banks Act 1992 was passed, while
existing thrift banks also received tax exemption for five years under the Thrift Banks
Act 1995.
5 Summary and
recommendations
Poverty remains the
most important development problem for the Philippines. The incidence of poverty is
relatively high, due in part to a disappointing economic growth performance and the
inequitable distribution of income. The Presidential Commission to Fight Poverty created
by the Philippines government has identified major strategies to overcome poverty in which
microfinance is given an explicit role.
The Social Reform
Agenda of the government focuses on basic needs of the poor. The flagship program on
credit flowing from this agenda has resulted in a number of initiatives, among them
the establishment of the Peoples Credit and Finance Corporation (PCFC), a second
tier financial institution. The establishment of the National Credit Council (NCC) has
enabled the articulation of a strategy for microfinance in which the role of the private
sector (including MFIs) is emphasised, and an enabling policy environment is to be
established. The Philippines is unique in the degree to which an explicit role is accorded
to microfinance in national poverty strategies, and in the coherence of the policy
framework for microfinance (although much remains to be done to reconcile the practice of
government agencies with that framework).
The Philippine
financial system includes both commercial banks and a number of categories of smaller
banks. These serve limited geographic areas and have comparatively low minimum capital
requirements. Among the specialised government banks, the Land Bank of the Philippines
plays a particularly important role in relation to microfinance and MFIs. A substantial
degree of financial sector liberalisation has occurred since the early 1980s. Interest
rate ceilings no longer apply for bank deposits or lending. However, the financial system
remains relatively undeveloped.
In general, the banks
do not provide financial services to poor clients. Small rural banks are best placed to do
so and the World Bank has identified cooperative rural banks as capable of providing
savings and credit services to the poor on a sustainable basis. The cooperative credit
movement includes many grassroots microfinance institutions, some of which succeed in
reaching the poor.
The Philippines has a
dynamic NGO movement, with some 500 NGOs providing microfinance services, although so far
only a small proportion are seriously concerned to operate on a sustainable basis. There
is a large number of government credit programs designed to provide financial services to
the poor, many of which employ microfinance institutions as conduits to channel credit to
the poor. Perhaps as many as 140 such programs exist, involving scores of line agencies of
government; these are characterised by inefficiency, unsustainability due to the
prevalence of subsidies, leakage of benefits to the non-poor, duplication of services, the
distortion of financial markets and the discouragement of private initiative.
Arrangements for
direct support
Channel government
lending through MFIs
The National Credit
Council (NCC) has among its objectives to rationalise government lending programs, develop
a national credit delivery system and encourage private sector participation.
Rationalisation of government credit activity requires that line agencies should focus
their involvement in credit programs on technical assistance and capacity building.
Government lending to the very poor should be conducted by specialised government
financial institutions (most notably PCFC) and be channelled through microfinance
institutions. Donor agencies should also be encouraged to channel support for microfinance
through PCFC, and to avoid funding unsustainable credit operations mounted by line
agencies. NCCs efforts at rationalisation confront powerful bureaucratic and
political interests. These must be overcome. Since the term of the current Administration
expires in mid-1998, the time available to the council is limited, and sustained political
support at the highest level will be required for it to complete its task.
Allow even-handed
support for MFIs
The Peoples
Credit and Finance Corporation (PCFC) is a second tier institution responsible for
nurturing and funding sustainable microfinance institutions. It faces the challenge of
preparing itself for privatisation while performing these tasks and extending the outreach
of the MFIs with which it is dealing. PCFC is currently funding a wide range of MFIs. It
funds institutions, not programs or models. However, a major multilateral loan for PCFC
has been provided exclusively in support of MFIs replicating the Grameen Bank approach.
The World Bank has noted that undue emphasis on Grameen replication as the only way to
reach the ultra poor may discourage the expansion of other successful models in the
Philippines. PCFC should be permitted to be even-handed in its support of MFIs. This
even-handedness should apply also to the pass-on rates of interest applied in
PCFCs funding programs. If these are permitted to differ according to the source of
the funds, distortions will be introduced into the microfinance market.
PCFCs drive to
profitability is necessary to permit privatisation to take place. But the obligation to
support capacity building for MFIs places a strain on the corporations
profitability. It will be necessary either to quarantine the costs of capacity building
from normal operating costs for the purpose of calculating profit and loss or,
alternatively, for the government and donor agencies to make special arrangements to
permit the corporation to perform its institutional development role. After privatisation
the government will need to accept substantially greater responsibility for capacity
building of MFIs. In this regard the Punla sa Tao model of public/private partnership
appears to be promising. It should be adequately resourced and be creatively involved in
collaboration with PCFC and the microfinance sector.
Directed credit
schemes, in the Philippines as elsewhere, are diminishing in importance. This process
should continue; direction of credit is not a cost-effective solution, especially in the
Philippines where conditions are favourable for market forces increasingly to provide the
necessary microfinance services.
Encourage commercial
bank involvement with microfinance
Financial linkages
between banks and specialised microfinance institutions are one means by which
microfinance can be integrated with the formal financial sector. Tax breaks available to
the charitable foundations of private commercial banks have permitted them to explore such
relationships. A number of banks which commenced financing MFIs in this way are now making
the transition to fully commercial financing, although current economic difficulties in
the Philippines are retarding this process. The publication of positive guidelines in
support of such linkages as has been done in India by NABARD would be helpful in
overcoming the conservatism of the commercial banks in relation to such activities. Bangko
Sentral would be the appropriate agency to encourage private commercial banks in this
regard.
Notwithstanding current
economic difficulties, market forces, arising from the progressive impact of financial
sector liberalisation, and a growing awareness of the potential for savings mobilisation
are factors at work in support of linkages. Mainstream commercial banks are acquiring or
setting up small banks for this purpose and display growing interest in agency
arrangements with NGOs. This is a positive development and should be encouraged.
Support
rationalisation of government credit schemes
A multiplicity of
government credit schemes has flourished in the Philippines: up to 150 such schemes
involve more than 40 line agencies of government. In general, these supply-led and
subsidised government credit programs have proved ineffective in tackling poverty.
Moreover, by distorting microfinance markets, subsidies have impeded the advance to
sustainability of genuine MFIs. Rationalisation would mean that credit would be
administered by financial institutions (principally PCFC) while line agencies would
confine themselves to providing technical assistance in the areas of their special
competence. This is an appropriate objective and the necessary political leadership should
be summoned to achieve it.
Regulation of
non-bank microfinance institutions
Clarify tax-exemption
procedures for NGOs
The broad regulatory
framework for NGOs in the Philippines is conducive to their growth by reason of its light
touch. However, there appears to be some anomaly in the taxation treatment of NGOs
compared with rural banks and cooperatives. The procedures for exempting bona fide NGOs
from tax should be clarified and simplified and such exemptions should not unreasonably be
withheld.
Allow NGOs to expand
handling of savings
NGOs are not permitted
to accept deposits from the general public; informal deposit-taking relationships with
clients occur in a legal grey area. NGOs should be permitted to collect compulsory savings
from clients in connection with the provision of other microfinance services. In the same
context, they should probably also be permitted to handle voluntary savings while
satisfying agreed standards of accounting and reporting. The review of the Banking Act may
provide an opportunity to consider these issues.
With regard to the
broader issue of a separate regulatory framework for MFIs, it is relevant to note that
most observers in other countries do not think MFIs should be subject to official
prudential regulation and supervision. This much is clear from the other country studies
conducted in parallel with our work in the Philippines. The answer is more likely to lie
in the development of effective mechanisms for self-regulation, perhaps combined with
guidance from second tier institutions.
Establish
coordinated performance and accreditation standards for MFIs
It is clear that some
setting of standards for MFIs would be appropriate. Agencies with oversight of MFIs,
notably PCFC, but also the National Credit Council and LandBank, are in a position to
exert influence. For the credit cooperatives, the deposit insurance facility being created
by NATCCO may also provide the opportunity for setting standards, perhaps leaving the
Cooperative Development Authority more free to concentrate on its developmental functions
for the great mass of cooperatives.
The National Credit
Council is equipped to articulate regulatory standards, although it does not have the
working relationship with MFIs enjoyed by PCFC. LandBank (for credit cooperatives
implementing government programs) and NATCCO (for private grassroots cooperatives) are
also positioned to play a role. All have commenced to set criteria for accreditation for
MFIs, and to define performance standards for them.
It is important that
there be coordination between the standards set by these agencies; if the National Credit
Council is to have a continuing existence this function could rest with it. Otherwise,
PCFC should accept responsibility for coordinating standards for MFIs. In this regard, the
experience of PKSF in Bangladesh should prove instructive.
Where initiative exists
within the private sector to self-regulate, this is usually preferable to having standards
imposed. Considerable progress has already been made by the Microfinance Coalition for
Standards and the two major microfinance networks, APPEND and PHILNET. The work of the
Developing Standards for Microfinance Project is receiving support from USAID. This could
lead to the development of systems for capacity measurement for MFIs and a rating system
which would be useful to domestic financial institutions and government and donor
agencies.
It is appropriate to
continue support for the development of a regulatory and supervisory framework by the
microfinance industry itself, leading to a system of accrediting NGOs. To the extent that
this goes beyond self-regulation, close liaison between the microfinance coalition, PCFC,
the National Credit Council and other interested agencies should be encouraged.
Regulation of banks
The present regulatory
provisions which make it relatively straightforward for successful MFIs to obtain rural or
thrift banking licences should be maintained or even liberalised further. The modest
capital requirements for establishing small banks are a positive feature of Philippine
legislation.
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