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Responsible Finance in Ghana, Kenya, Tanzania, and Uganda Synthesys Report Published By Promoting Financial Sector Dialogue: Making Finance Work for Africa Ghana Kenya Uganda Tanzania Responsible Finance in Ghana, Kenya, Tanzania, and Uganda Synthesys Report Published by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH Registered offices Bonn and Eschborn, Germany Friedrich-Ebert-Allee 40 53113 Bonn, Germany Phone: +49 228 44 60-0 Fax: +49 228 44 60-17 66 Dag-Hammarskjöld-Weg 1-5 65760 Eschborn, Germany Phone: +49 61 96 79-0 Fax: +49 61 96 79-11 15 Email: [email protected] Internet: [email protected] Author: Pim Engels with contributions from Denise Dias and Kate McKee Pictures: Pictures on the front and back page © KfW-Bildarchiv/Fotoagentur photothek.net Design: Alexandra Müller Eschborn, November 2011 On 1 January 2011, the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH was formed. It brings together the long-standing expertise of the Deutscher Entwicklungsdienst gGmbH (DED), the Deutsche Gesellschaft für Technische Zusammenarbeit (GTZ) GmbH and InWEnt – Internationale Weiterbildung und Entwicklung gGmbH. For further information, go to www.giz.de. Contents Executive Summary 03 1 Introduction 04 1.1 Background to the Synthesis Report 04 1.2 Introduction to Responsible Finance in Africa 05 Consumer protection regulation by governments 06 Self-regualtion: industry standards of practice and codes of conduct 06 Financial capability and education 07 2 Responsible Finance Diagnostic Studies in Selected African Countries 08 2.1 Responsible Finance in Ghana 08 Financial sector profile of Ghana 08 Access to finance in Ghana 09 Consumer protection regulation 10 Self-regulation 11 Financial capability 12 Recommendations of the diagnostic study 12 2.2 Responsible Finance in Kenya 13 Financial sector profile of Kenya 13 Access to finance in Kenya 14 Consumer protection regulation 15 Self-regulation 17 Financial capability 17 Recommendations of the diagnostic study 17 2.3 Responsible Finance in Tanzania 18 Financial sector profile of Tanzania 18 Access to finance in Tanzania 19 Consumer protection regulation 20 Self-regulation 21 Financial capability 21 Recommendations of the diagnostic study 22 2.3 Responsible Finance in Uganda 23 Financial sector profile of Uganda 23 Access to finance in Uganda 24 Consumer protection regulation 26 Self-regulation 27 Financial capability 27 Recommendations of the diagnostic study 28 3 Interesting Emerging Practices and Closing Thoughts 29 3.1 Consumer protection regulation 29 Towards effective interest rate disclosure in Kenya 29 Regulating nonbank mobile financial services: experiences from M-PESA in Kenya 30 Consumer protection regulation in Africa: closing thoughts 30 3.2 Self-regulation 31 The experience of AMFIU in Uganda 31 Self-regulation for consumer protection in Africa: closing thoughts 32 3.3 Financial capability and education 32 The work of the Financial Education Partnership in Kenya 32 The national strategy for financial literacy and consumer education in Ghana 33 Financial capability and education in Africa: closing thoughts 34 3.4 Cross-border Learning 35 Appendix: Financial Sector Regulatory Framework 37 List of Abbreviations APR Annual Percentage Rate ASSFIN Association of Financial NGOs (Ghana) AMFI Association of Microfinance Institutions (Kenya) AMFIU Association of Microfinance Institutions of Uganda ARB Apex Bank Association of Rural Banks (Kenya) BoG Bank of Ghana BoT Bank of Tanzania BoU Bank of Uganda BSD Banking Supervisory Department (Ghana) CBoK Central Bank of Kenya CCK Communication Commission of Kenya CBA Community Banks Association Tanzania CGAP Consultative Group for Assisting the Poor CIN Consumer Information Network (Kenya) CCUA Cooperative of Credit Unions Association (Ghana) CUA Credit Union Association (Ghana) DCCA Department of Cooperatives and the Credit Union Association (Ghana) GIZ Deutsche Gesellschaft für Internationale Zusammenarbeit EAC East African Community ECOWAS Economic Community of West African States FAP Financial Access Partnership (Kenya) FEPP Financial Education and Protection Program (Kenya) FEP Financial Education Partnership (Kenya) FLF Financial Literacy Foundation (Uganda) FSDK Financial Sector Deepening (Kenya) FSDU Financial Sector Deepening Uganda GAB Ghana Association of Bankers GES Ghana Education Service GHAMFIN Ghana Microfinance Institution Network ICRO Investigation and Consumer Reporting Office (Ghana) KBA Kenya Banker Association KYC Know Your Customer MFI Microfinance Institution MFTC Microfinance Technical Committee (Tanzania) MoAFSC Ministry of Agriculture, Food Security and Cooperatives (Tanzania) MoCDM Ministry of Co-operative Development and Marketing (Kenya) MoFK Ministry of Finance (Kenya) MoFT Ministry of Finance (Tanzania) MoFEPG Ministry of Finance and Economic Planning (Ghana) MoFEPU Ministry of Finance and Economic Planning (Uganda) NSPD National Payment System Department (Kenya) NEPAD New Partnership for Africa’s Development NBFI Non Bank Financial Institution RS Repayment Schedule RFSPT Rural Financial Services Programme (Tanzania) RFSPU Rural Financial Services Programme (Uganda) RFSST Rural Financial Services Strategy (Tanzania) RFSSU Rural Financial Services Strategy (Uganda) SACCO Savings and Credit Cooperative Organisation SCCULT Savings and Credit Cooperatives League of Tanzania SME Small and Medium Enterprises SSA Sub-Saharan Africa TBA Tanzania Bankers Association TAMFI Tanzanian Association of Microfinance Institutions TCC Total Cost of Credit UBA Uganda Bankers’ Association UCPA Uganda Consumers’ Protection Association UCSCU Uganda Cooperative Savings and Credit Union KUSCO Union of Savings and Credit Cooperatives (Kenya) WAMI West African Monetary Institute WAMZ West African Monetary Zone WB World Bank Executive Summary Executive Summary nsights from the MFW4A conference »Promoting The final section highlights interesting practices in the IFinancial Capability and Consumer Protection, A studied countries in three areas: consumer protection Step Forward towards Financial Inclusion in Africa«, regulation, self-regulation and financial education and held in 2009, demonstrate the importance of respon- capability. Presenting these experiences allows greater sible finance to unleash the potential of African finan- knowledge sharing and provides an insight into the op- cial sectors to drive economic development and reduce portunities and challenges across these selected markets, poverty across the continent. In the new approach to and useful lessons for other African countries. It conclu- responsible finance governments, financial service pro- des each area with thoughts for the future of responsible viders, a variety of stakeholders and consumers engage finance in Africa, such as the value of cross-border lear- in three mutually reinforcing pillars: consumer protec- ning and outreach; the need to find workable solutions tion by governments, self-regulation by financial service to improve market conduct in semi-formal and infor- providers (and other financial industry actors such as mal markets; the usefulness of cross-market consumer investors), and improvement of financial capability and protection regulations and oversight; and the value of consumer awareness at the client level. Above all, this strengthening existing industry associations and net- approach to responsible finance encourages innovation works. In the field of financial capability, working in to stimulate, expand and improve access to sound and partnerships and towards a national strategy and using safe financial services in developing markets. edutainment and mass media are also discussed. Three Pillar Approach to Responsible Finance Consumer protection regulation Industry self-regulation Financial capability and consumer awareness Following the 2009 conference, responsible finance diagnostic studies on consumer protection regulation, self-regulation and financial capability have been com- missioned and conducted in Ghana, Kenya, Tanzania, and Uganda. The objective of this report is to review these diagnostics, identify interesting practices within these countries, and present some thoughts for the fu- ture of responsible finance in Africa. Following a short introduction, the report summarizes each country dia- gnostic, including an introduction to the local financial sector, the current state of access to finance, and review of the diagnostic’s findings and recommendations for the improvement of consumer protection and financial capability. 03 1 Introduction 1 Introduction 1.1 Background to the Synthesis to be capable of managing better their financial assets and liabilities by understanding their rights and respon- Report sibilities and the services they use contributes to heal- Poor households and low-income individuals often thy and sustainable financial inclusion. In addition, if have limited access to formal financial services, such as there is healthy competition, service providers benefit, payments, savings, loans, and insurance. Consequently, in the medium and long run, from adopting policies, they lack the assets needed to finance life-cycle events practices, and products that protect their customers’ (e.g. birth, marriage, and education), remain vulnerable interests. Individual providers may also see a value in to adverse shocks, and have to revert to expensive and responsible delivery of services to safeguard their own less-reliable informal sources of finance. Even if these reputation and that of the industry as a whole, although services are available, low-income individuals, rural
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