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An Index of Regulatory Practices for Financial Inclusion in Latin America: Enablers, Promoters and Preventers Liliana Rojas-Suarez and Lucía Pacheco Index

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An Index of Regulatory Practices for Financial Inclusion in Latin America: Enablers, Promoters and Preventers Liliana Rojas-Suarez and Lucía Pacheco Index Nº 17/15 WORKING PAPER An Index of Regulatory Practices for Financial Inclusion in Latin America: Enablers, Promoters and Preventers Liliana Rojas-Suarez and Lucía Pacheco Index Executive Summary 5 I. Introduction 14 II. Assessing Regulations: Scope of the Study and Methodology 15 1. Three dimensions of regulatory practices affecting financial inclusion: Enablers, Promoters and Preventers 15 2. Constructing Indices of Regulatory Quality: The Methodology 18 III. How Enabling are the Regulatory Frameworks in Latin America? Country Comparisons 20 A. Enabler 1: The Quality of Competition Policies 20 B. Enabler 2: The Adequacy of the Supervisory Regime (Supervisory Quality 24 The Enablers Index 27 IV. Assessing Regulations classified as Promoters of Financial Inclusion 28 A. Promoter 1: Simplified Accounts 29 B. Promoter 2: Electronic Money 33 C. Promoter 3: Correspondents 37 D. Promoter 4: Microcredit 42 E. Promoter 5: Credit Reporting Systems 45 F. Promoter 6: Simplified KYC requirements 48 G. A non-Regulatory index: Financial Literacy 52 The Promoters Index 54 V. Assessing Regulations Constraining Financial Inclusion: The Preventers 56 A. Preventer 1: Financial Transaction Taxes 56 B. Preventer 2: Interest rates Ceilings 59 C. Preventer 3: Directed Lending 61 The Preventers Index 64 VI. The Overall Index of Regulations for Financial Inclusion 64 References 69 2 Annexes 82 Annex I: Sub-Indices Indicators—Definitions and Scoring Methodology 82 Annex II: Competition Policies: Summary of Regulatory Findings 122 Annex III: Supervisory Quality: Methodological Considerations 124 Annex IV: Supervisory Quality: Summary of Regulatory Findings 129 Annex V: Regulatory frameworks for simplified accounts 131 Annex VI: Simplified Accounts: Summary of Regulatory Findings 132 Annex VII: Regulatory frameworks for electronic money 134 Annex VIII: Electronic Money: Summary of Regulatory Findings 135 Annex IX: Regulatory frameworks for Correspondents 138 Annex X: Correspondents: Summary of Regulatory Findings 139 Annex XI: Microcredit: Summary of Regulatory Findings 142 Annex XII: Credit Reporting Systems: Summary of Regulatory Findings 145 Annex XIII: Simplified KYC requirements: Summary of Regulatory Findings 147 Annex XIV: Financial Literacy: Summary of Regulatory Findings 149 Annex XV: Financial Transaction Taxes: Summary of Regulatory Findings 151 Annex XVI: Financial Transaction Taxes in Brazil 152 Annex XVII: Interest Rates Ceilings: Summary of Regulatory Findings 155 Annex XVIII: Directed Lending: Summary of Regulatory Findings 156 Abbreviations 157 3 June 2017 An Index of Regulatory Practices for Financial Inclusion in Latin America: Enablers, Promoters and Preventers (*) Liliana Rojas-Suarez (**) Lucía Pacheco Center for Global Development BBVA Research Abstract This paper constructs and index of regulatory quality for improving financial inclusion for the purpose of assessing and comparing the quality of rules and regulations in a sample of eight Latin American countries. The index comprises 11 regulatory practices classified into three categories: those that determine the overall quality of the financial environment where providers of financial services that meet the needs of the poor operate (the enablers); those that deal with specific types of market frictions and regulate the provision of specific financial products and services (the promoters) to large segments of the population; and those that, albeit unintentionally, create distortions and barriers that adversely affect financial inclusion (the preventers). An important novelty of the index is that the assessment of individual regulatory practices not only takes into account accepted standards, but also recognizes that there are important interactions between regulations for financial inclusion as well as between these regulations and other type of government interventions. Among the countries in the sample, by mid-2017, Peru ranked first in this index, followed closely by Mexico. Chile, Colombia, Paraguay and Uruguay obtained lukewarm results, although there were wide differences among these countries’ individual results. Argentina and Brazil were the two countries with the lowest overall scores. An additional contribution of the paper is that, throughout the analysis, countries’ specific areas of strengths and weakness in financial regulatory practices for improving financial inclusion are identified. Key words: financial inclusion, financial regulation, Latin America JEL classification: G21, G22, G23, I25, K21, N26, O10. * We are very grateful to Santiago Fernández de Lis and David Tuesta for their suggestions, comments and invaluable insights. This paper has also benefited from the feedback and input of many BBVA research economists as well as from local experts from the Argentinian, Chilean, Colombia, Mexican, Paraguayan, Peruvian and Uruguayan BBVA teams. We also wish to thank Enestor do Santos for his insightful comments on the Brazilian framework and Giovanni di Placido, from Fundación BBVA MicroFinanzas, for his extremely valuable feedback on the microcredit section. Finally, we would also wish to thank Rosa María Oliveros for her valuable research assistance. Any remaining errors are, of course, the sole responsibility of the authors. ** The views expressed are the author’s own, and do not reflect views of the Center for Global Development, its Board of Directors, or its funders. 4 Executive Summary This paper assesses and compares the quality of rules and regulations impinging on financial inclusion in a sample of eight Latin American countries: Argentina, Brazil, Chile, Colombia, Mexico, Paraguay, Peru and Uruguay. By identifying weaknesses and strengths of specific regulatory practices in individual countries, the paper aims to support the efforts of policymakers in the region mandated with the task of improving financial inclusion. The paper distinguishes itself from other empirical assessments of this kind in two important and complementary ways. First, by concentrating only in Latin America, the analysis focuses on issues and variables that are particularly relevant to the region. Second, the paper recognises that the effectiveness of a number of regulations for financial inclusion is influenced by the quality of other regulatory practices and by certain government interventions. That is, there is an interaction between regulations that affect their overall quality. The 11 regulatory practices discussed in this paper are classified into three categories: those that determine the overall quality of the financial environment where providers of financial services operate (the enablers); those that deal with specific types of market frictions and describe the rules of the game for the provision of specific financial products and services (the promoters); and those that, albeit unintentionally, create distortions and barriers that adversely affect financial inclusion (the preventers), We construct an index for each of these three categories and sub-indices for the 11 regulatory practices/policies that form the indices (Table 1) Table 1: Indices of Regulatory Quality and their components Enablers Promoters Preventers o Simplified Accounts o Electronic Money o Correspondents o Transaction Taxes o Competition Policies o Microcredit o Interest Rate Ceilings o Supervisory Quality o Credit Reporting Systems o Directed Lending o Simplified Know-Your- Customer (KYC) requirements In addition, we also constructed a sub-index for assessing government efforts in promoting Financial Literacy. This sub-index is used as an adjustment factor in calculating the score of the Promoters index. The assessment of individual regulatory practices is based on the construction of sub-indices, whose components include accepted standards as well as relevant interactions with other regulations and government interventions. Sub-indices receive scores in the 0-2 range and are then aggregated by categories to create the enablers, promoters and preventers indices. A final, overall index incorporating all three categories is also constructed. 5 How Enabling are the Regulatory Frameworks in Latin America? A central feature of an enabling regulatory framework for financial inclusion is that it facilitates the adoption and adaptation of innovations that safely allow for an increased usage of financial services by large segments of the population, especially the poor. Thus, such enabling regulatory framework for financial inclusion needs to rest on two pillars. The first is the application of adequate competition policies that encourage a variety of providers to expand the range of customers receiving financial services. The second pillar is a complementary and robust supervisory regime to ensure progress in financial inclusion in a sustainable manner, and this regime requires supervisors to have adequate tools and sufficient autonomy to take action in the event that problems emerge in financial institutions. Thus, the Enablers index is composed of the Competition Policies sub-index and the Supervisory Quality sub-index. The Competition Policies sub-index is made up of four indicators that define rules on (a) market entry, (b) market exit, (c) abuses of market power and (d) the contestability of inputs and interoperability. Results show that regulatory strengths and weaknesses vary significantly across countries. A common characteristic among the highest performers (Argentina, Chile, Colombia, Mexico and Paraguay with a score of either 1.8 or 1.7) is that all countries received the maximum score in
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