Public Disclosure Authorized IFC MOBILE MONEY SCOPING COUNTRY REPORT: GHANA Public Disclosure Authorized John Ngahu, Charles Niehaus, Joseck Mudiri Scoping Mission Dates: Public Disclosure Authorized July 22 to 26, 2013 Public Disclosure Authorized PARTNERSHIP for FINANCIAL INCLUSION The Partnership for Financial Inclusion aims to scale up commercial microfinance institutions and develop mobile financial services to bring affordable financial services to 5.3 million previously unbanked people in Sub-Saharan Africa by 2017. It is a $37.4 million initiative by The MasterCard Foundation and IFC that brings together the intellectual and financial capital of the Foundation with IFC’s market knowledge, expertise and client base. The partnership is also joined by The Development Bank of Austria, OeEB, and The Bill & Melinda gates Foundation, and collaborates with knowledge partners such as the World Bank and CGAP. An important objective of the partnership is to contribute to the global community of practice on financial inclusion, and to share research and lessons learned. This publication is part of a series of reports published by the program. www.ifc.org/financialinclusionafrica Ghana Executive Summary Overall Mobile Money Readiness 3 (medium) Current Mobile Money Solutions 3 Population: 25.37 million (July 2012 est) Mobile Penetration: Approx 17.4m unique subscribers, or 69% of adult population Banked Population: Less than 30% has access to formal financial services Remittance % of GDP: Inbound $151.6 million, 0.83% of GDP Percent under poverty line: 28.5% (2007 est.) Economically Active population: 69.4% in labour force (2011 est.) Adult Literacy: 67.3% (2010 est.) Banks with largest branch networks: Ghana Commercial Bank, Barclays, Agricultural Development Bank, Ecobank Mobile Network Operators: MTN, Vodafone, TIGO, Airtel, Expresso, Glo IFC Opportunities Market level: Assist market in understanding payments convergence MNOs: Work with Tigo and MTN to help them reach scale Financial Institutions: Work with Fidelity bank to help them develop their mobile channel, agency banking and explore merchant services. • Macro-economic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendixes: Interviews Conducted Macro-Economic Overview Key Country Statistics Insights • Population: 25,366,462 (July 2012 est.) • Ghana's economy has strengthened over the past quarter century due to sound management, strong • Age distribution: 38.6% (0-14 years), 57.9% (15- commodity sector reinforced by recent oil 64 years), 3.5% (over 65 years) discoveries, a competitive business environment, • Urban/rural split: 52.5% urban and sustained reductions in poverty levels • GDP (PPP): 51.9 billion, 80th globally • There exists a sound financial system that is anchored by a legal and regulatory framework • GDP per capita (PPP): $2,048 • There’s strong distribution infrastructure that’s • Population below national poverty line: 28.5% private sector driven • Economically active: 15.6 m (66.7%) in labor force • Banking infrastructure is evenly distributed with the (2011 est.) exception of the northern region which has relatively • Literacy rate: 67.3% few bank branches • Scoping results show high market demand for more • Banking penetration: less than 30% of population have access to formal financial services efficient financial services indicating growth opportunity for mobile financial services. • Mobile phone penetration: Approx 17.4 m unique • The outlook in 2012/13 remains positive with subscribers, 69% penetration, 100% adult projected GDP growth of 8.3 % (7.6% non-oil) and • Remittance (% of GDP): 0.39%, $151.6 million 7.7 % (6.3 % non-oil) in 2012 and 2013 respectively Sources: CIA Factbook Website August 2013 and conversations with industry players during scoping visit held between 22 – 26 July 2013 • Macroeconomic Overview • Regulations • Financial Sector • Telecom Sector • Distribution Channel • Mobile Financial Services Landscape • Potential Risks • Appendix: Interviews Conducted Regulatory Bodies Roles & Responsibilities Implications . BoG performs dual roles of payment system oversight and commercial operator. It is a • Payments Systems Act (663 of 2003) designates Payment System Operator through GhIPSS BoG responsibility of overseeing the National and has a commercial interest through Payment System and all relevant regulations eZwitch • BoG also the owners of GhIPPS (Ghana . No evidence of a Payment System Central Bank of Interbank Payment and Settlement System/ACH Management Body (PSMB) made up of and Switch) which process eZwich and GH-Link Ghana(BoG) participants in the Ghana National Payment cards • Branchless Banking Regulations released in System 2008 – limited to deposit taking institutions (bank . BoG mandated industry to use eZwich to and non-bank) solve bank card/ATM interoperability issues but there has been a general lack of support from industry . GhIPSS is in the process of launching GH-link which will connect all proprietary cards. This is National • Responsible for granting of MNO licences and potentially a more efficient solution than ensuring quality standards Communications eZwich • Limited direct role in Branchless Banking/Mobile . eZwich potentially faces competitive Authority Money. Aligned with BoG to drive industry wide (NCA) issues such as awareness and interoperability challenges as Mobile Money offerings develop in rural areas which eZwich is targeting Regulatory Framework & Requirements Current Regulations Implications . Although BoG has implemented a bank-led model, in practice, 3rd party and/or MNOs are actually driving the business • MNO managed MFS deployments fall under . MNO’s would like a closer relationship with BoG Branchless Banking Regulations to articulate their interests. • Banks must lead, MNOs and 3rd party providers . Standardised, non tiered and overly can only operate with a licensed bank partner burdensome KYC requirements limiting • MNO’s do not have a direct relationship with business growth. BoG . Many to Many MFS model has led to individual Branchless • Permissible model is many-to-many and MNO’s partnering with as many as 10 banks, MNO’s must have a minimum of 3 licenced Banking reducing incentives to both MNOs and Banks. bank partners Regulations . Under current regulations all the accounts that • KYC is not tiered MNO’s are building belong to the partner Banks. • Each MFS wallet should be backed by a . In practice banks do not have individual unique bank account on the banking system accounts but are pooled in the MNO’s name • MFS platforms allocate BIN’s (Bank Identity . Banks and MNOs working out acceptable Numbers) for each bank partner, the trust incentives for all partners to grow business. account at that bank must reconcile back to the . MNO’s are in independent discussions with the balance on the BIN on the MFS platform Regulator to change the current model. Draft new regulations are imminent. Retail agents fall under branchless banking . No mention of agent exclusivity in regulations. regulations Agents have direct relationships with . Essentially operate as bank agents under the Retail Agents individual MNO’s and their affiliated banks. regulations (and assigned BIN) but from a . Around 1/3rd of agents are serving multiple branding perspective represent the MNO MFS deployments business Regulatory Framework & Requirements Current Regulations Implications . Acquisition being performed by agents . MNO’s are acquiring customers that due to . Customer falls into BIN (Bank Identity regulation belong to the banks Customer Number) of the merchant where they . Customers are unaware they essentially have an Acquisition are registered (ie if it is a MTN agent underlying bank account, MNO service point staff who falls on the Barclays BIN, then the are also unclear on this. consumer falls under the Barclays BIN) . KYC policy in place, issues of non . MNO’s believe un-tiered KYC regulations is adherence in the past have led to BoG KYC/AML slowing down uptake and usage. releasing a standard Due Diligence form . The operators are lobbying BoG to introduce Requirements . KYC not tier based and all new tiered KYC accounts require full KYC . Regulation means that the banks essentially own the customer and/or agent . MNO’s run and operate the MFS . Due to unique BIN allocations, banks can move businesses but dependant on banks their MFS customers between MNO’s if they wish licences due to regulations or bring them in house, but due to the way the Role of MNOs . Do not have a direct relationship with accounts are pooled and not individual as per BoG regulation they cannot practically do this . Fall under Agency Banking guideline . MNO’s are starting to create lobby groups to be closer to the legislation and aim at driving certain changes such as KYC and Bank-led model • Currently no consumer protection law in . Regulatory traction required to move towards Customer place, but is in draft consumer protection. Absence of protection opens Protection • Consumer Protection Agency (CPA) is a up payment systems to lack of trust lobby group for consumers . CPA legitimacy often questioned in the industry Additional Regulatory Considerations Current Regulations Implications Card: • GhIPSS is the National ACH/Switch and is a • eZwich original intent was to solve card subsidiary of BoG, GhIPSS facilitates interoperability for proprietary ATM cards but switching for eZwitch, GH-Link, ACH required issuance of a new proprietary