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Program Impact Assessment

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Program Impact Assessment Inclusive Financial Sector Development Program, Subprogram 2 (RRP CAM 44263–015) PROGRAM IMPACT ASSESSMENT 1. Executive Summary 1. Only a few policy actions have been selected to estimate costs and benefits in this assessment. Transfers between agents within the economy are excluded, as far as is practicable, although direct transfers to the poor are incorporated. Benefits are attributed to two channels: reduced borrowing costs and increased access to finance. Reduced borrowing costs are achieved by having a better regulatory framework that reduces risks to lenders and increases confidence among borrowers; this deepens the financial market thus making it more flexible and responsive to consumer needs. Improved access to finance is achieved by improving financial literacy of borrowers, enabling more efficient microfinance and increasing the number of ATMs and bank branches. Improved financial inclusion also helps to alleviate poverty and reduce income inequality, in addition to measures that specifically target the poor, rural people and women. In summary, the program produces benefits to the economy with a present value of between $341 million and $672 million, with the most likely scenario yielding $507 million in benefits. Benefits are split evenly between reduced borrowing costs and financial inclusion. Estimated costs range between $113 and $282 million and arise primarily from staffing and regulatory costs, as well as the establishment of a deposit protection scheme. 2. Macroeconomic context 2. The Cambodian economy has grown above 7% per annum from 2011 to 2016 with a slight decrease to just below 7% in 2017 and 2018. This growth is broadly in line with Association of Southeast Asian Nations (ASEAN) countries in a similar stage of economic development such as Laos, Myanmar and Vietnam. However, from a welfare perspective, GDP per capita has grown at a rate of around 5% per annum and more than 70% of Cambodians live on less than $3 a day. The new Rectangular Strategy (Phase IV) acknowledges that maintaining a 7% broad-based economic growth rate will require structural adjustments, which includes development of the financial sector to make it more inclusive and to deepen and diversify it. 3. Development problem and constraints 3. The finance sector is shallow and lacks diversity. Banks dominate the Cambodian financial sector accounting for 84% of total financial sector assets and representing 142% of GDP, which is higher than comparable ASEAN countries.1 Microfinance institutions account for about 15% of the sector and the remaining 1% consists of financial products relating to insurance, leasing, capital markets and pension funds. Cambodia has yet to develop a local currency government bond market, although local currency corporate bonds were issued for the first time in Cambodia in October 2018, an initiative supported by the Securities and Exchange Commission of Cambodia (SECC). Credit bureau penetration is low, with only 144 reporting institutions out of 2,951 (including 2,476 money changers) in the system. 1 https://www.theglobaleconomy.com/rankings/bank_assets_GDP/ accessed on 26 February 2019. 2 4. Low level of financial inclusion.2 Cambodia ranks 155 out of 176 countries. This is mainly due to low financial literacy, where it ranks 135 out of 144 countries;3 lack of consumer protection from unfair business practices; financial market unresponsive to consumer needs due to inadequate regulatory framework; and limited availability of financial sources for SMEs, small farmers and the agriculture sector. Despite rapid credit growth, lending is fragmented with credit readily available in urban areas, but rural areas remain underserved. A financial inclusion study in 2015,4 highlighted a major problem of financial exclusion in the Cambodia, estimating that only 59% of the adult population had access to formal financial services (68% in urban areas and only 55% in rural), 12% use informal services and 29% were completely excluded having no access to formal and informal financial services. 5. Weak financial sector stability framework due to a lack of coordination among National Bank of Cambodia (NBC), Ministry of Economy and Finance (MEF) and the SECC; absence of a deposit protection scheme (DPS); and the lack of a local currency government bond market. 6. Underdeveloped financial infrastructure due to outdated payment systems; lack of a legal framework to enable e-commerce and related financial products; and weak anti-money laundering and counter-terrorist financing mechanisms. 4. Policy interventions to overcome constraints 7. The program consists of measures to support financial inclusion, financial stability and financial infrastructure. These build on the achievements of subprogram 1. 4.1 Measures to enhance financial inclusion 8. Under subprogram 2, the government finalized the National Strategy for Financial Inclusion (NSFI). NSFI seeks to provide a framework to broaden the access to financial services for individuals including specific targets for women and micro, small and medium enterprises (MSMEs); and to deepen the provision of financial services making them responsive to consumer demand. Under subprogram 3, the government will launch and implement the NSFI, implement the Consumer Protection Law and establish its enforcement agency, pilot financial literacy programs in schools and license microinsurance operators. 4.2 Measures to strengthen financial stability 9. Under subprogram 2, the government has taken measures to increase coordination among finance regulators, enhance the effectiveness of credit insurance and facilitate the establishment of a bond market in Cambodia. It established a joint financial stability technical group comprising NBC, MEF and SECC to facilitate a coordinated response for crisis management. The government also selected the Paybox Plus DPS model in which the deposit insurer provides additional resolution functions. To establish a basis for a domestic bond market, the government revised its debt strategy to incorporate provisions to authorize the eventual issuance of government debt, which establishes a yield curve and provides a meaningful 2 Park and Mercado Jr, Financial Inclusion, Poverty, and Income Inequality in Developing Asia, ADB Economic Working Paper Series, No 426, January 2015. 3 Atlas. Global financial literacy ranking. https://www.theatlas.com/charts/VJDhtA8Xe (accessed 29 January 2019). 4 United Nations Capital Development Fund. 2015. FinScope Consumer Survey 2015. Phnom Penh. 3 benchmark for capital markets. Under subprogram 3, the government will establish a fully-fledged national financial stability committee, implement the Paybox Plus DPS, and formalize a roadmap for government debt securities. 4.3 Measures to upgrade financial infrastructure 10. Under subprogram 2, the government will launch a Central Shared Switch System for ATMs and point-of-sale terminals to allow all bank cards to be used at all participating merchants; increase coverage of the national credit bureau’s database to include corporate borrowers; and set up a steering committee to formalize an action plan to address evaluation findings of the Asia Pacific Group. Also, significant progress has been made in addressing the lack of an enabling legal framework for modern financial products and services. The Trust Law, which governs the establishment, registration, supervision and termination of trusts thus paving the way for the development of investment vehicles, has been submitted to the National Assembly for approval; and the e-Commerce Law, which provides a framework for domestic and international e- commerce, was also submitted to the National Assembly for approval. Under subprogram 3, the government will establish a Real Time Gross Settlements system, achieving a pre-agreed number of “compliant” or “largely compliant” ratings on FATF Recommendations, establish new financial products under the trust scheme and establish payment system infrastructure to facilitate the introduction of e-Commerce. 5. Benefits and costs of policy intervention 5.1 Policy interventions and impacts 11. Only a few policy measures were selected for estimating the costs and benefits of subprogram 2. Costs calculated and benefits estimated are not exhaustive; hence these are for illustrative purposes only. The three output measures are very much interlinked; therefore, it is difficult to directly link costs to specific benefits. For example, measures to strengthen financial stability will reduce borrowing costs (due to reduced risks), deepen finance (due to more finance providers entering the market and providing more responsive financial products to satisfy borrowers) and enhance financial inclusion (due to small investors being protected). Similarly measures to increase financial inclusion and measures to upgrade financial infrastructure will result in benefits across sectors, all resulting from increased confidence of large- and small-scale investors. Table 1: Summary of measures Policy measure Summary of impact Financial inclusion (4.1) Increased access to finance and associated benefits. Costs are mainly due to staff and administration set up. - A formal process to develop the country’s first comprehensive financial inclusion strategy, to encourage wider and more inclusive participation in the financial sector. 4 Policy measure Summary of impact Financial stability (4.2) Reduction in borrowing costs due to decreased risk (borrowing multiplied by decrease in interest rates). Cost - Coordination among regulators of
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