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Better Regulations Can Spur Agent Banking in WAEMU

11.04.2018Corinne Riquet, Financial Sector Specialist, CGAP

This blog was originally published on the CGAP website.

The West African Economic and Monetary Union (WAEMU) has taken significant steps toward financial inclusion in recent years. Mobile money has driven much of this progress under the aegis of regulations that make it possible for mobile network operators to offer e-money services and expand their agent networks and the reach of their services. However, WAEMU’s regulations make it difficult for banks and microfinance institutions to expand their own agent networks and contribute fully to financial inclusion. While the number of mobile money accounts and agents in the region roughly doubled between 2014 and 2017 (to 36.4 million and 183,000, respectively), banks and microfinance institutions have lagged behind.

Even in the age of mobile money, these traditional financial institutions have an important role to play in expanding low-income customers’ access to financial services. For example, as Will Cook points out in his recent CGAP blog post, bank accounts in Kenya once again outnumber mobile money accounts – by 30 percent. Alongside partnerships with mobile money providers, a rise in agent banking has contributed to this increase. In 2016, 17 commercial banks developed agent banking and contracted over 40,000 agents. The Central Bank reported that agent banking saw 55.8 million transactions in the first quarter of that year, compared to 10.3 million in the same period the year before. Kenya’s regulators enabled this kind of growth by adopting a risk-based approach when defining the country’s agency banking regulatory framework in 2010 and integrating provisions for consumer protection.

What will it take for WAEMU regulators to similarly unlock the potential of banks and microfinance institutions to drive financial inclusion for the region’s 50 million people living in poverty?

[In November 2017] CGAP published a regulatory diagnostic of digital financial services in Côte d’Ivoire, which has the same agent regulations as the other WAEMU member countries (Benin, Burkina Faso, Guinea-Bissau, Mali, Niger, Senegal and Togo). We found that WAEMU recognizes three types of agents and that the regulations surrounding them contribute to disparities among different types of institutions (banks, nonbank e-money issuers, microfinance institutions, etc.):

  • E-money agents. E-money agents may conduct marketing activities and supply services related to e-money, including account enrollment, cash-in and cash-out and payments. Current regulations provide for a two-tier system of primary agents and subagents (or “distributors” and “subdistributors,” as they are called in the regulation), who act under the responsibility of the e-money issuer. Retailers and other registered businesses, microfinance institutions, the post office and other nonbank financial institutions are permitted to serve as primary agents. These agents may outsource to other registered businesses who act as subagents. These rules have allowed mobile network operators to deploy large agent networks in the eight WAEMU countries.

  • Rapid money transfer agents. Another regulation enables banks, nonbank financial institutions and microfinance institutions to provide over-the-counter transactions, or “rapid fund transfers,” through retail agents called “subagents.” Permitted transactions are limited to real-time transfers that are performed over the counter at an authorized provider or agent and do not involve any bank or e-money account of either the sender or recipient. These providers act under the responsibility of a financial institution and are not allowed to collect funds for deposits for any purpose other than over-the-counter transfers (unless they are microfinance institutions). The best-known of these over-the-counter providers is WARI, which has large networks of subagents in most of the WAEMU countries.

  • Banking agents. Beyond e-money and over-the-counter transfers, the scope for using agents is unclear. The rules that do exist are highly restrictive for banks, and there is no explicit framework for microfinance institutions. Banks are authorized by the banking law and a 2010 instruction from BCEAO (the common central bank for the WAEMU region) to use agents called Intermédiaires en Opérations de Banque (IOBs). An IOB acts under a mandate assigned by a bank, which may include opening accounts and taking deposits. Each IOB is required to obtain approval from the Ministry of Finance, on the advice of BCEAO. It is also subject to fit-and-proper standards – a financial guarantee whose level depends on the nature of the mandate and regular reporting requirements. The IOB model did not arise for the sake of financial inclusion but rather, as a business niche for intermediaries operating within the traditional banking sector comparable to an insurance agency. As a result, since the introduction of these rules in 2010, BCEAO has approved and registered only six IOBs, and two are authorized to just collect deposits.

While regulations on e-money agents have greatly expanded the reach of mobile money, those surrounding agent banking appear too restrictive for the banks and are nonexistent for the microfinance sector. This creates a competitive disadvantage for traditional financial services providers to make use of digital channels in expanding their reach and relevance. Uniform, or at least harmonized, rules across the board for e-money, over-the-counter transactions and banking agents would be a big step in the right direction. Any new framework should provide a comprehensive and proportionate set of risk-based rules on due diligence, supervision, internal control and subagents. And special consideration should be given to replacing or revising IOB rules to support a more flexible agent banking approach.

More harmonized rules around agent networks would ensure a level playing field for all financial services providers to seize the opportunities presented by digitization to reduce cost, increase scale and expand financial inclusion.

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About the Author

Corinne Riquet is an independent microfinance consultant and has worked in several African countries since 2001. She has advised a range of clients, especially MFIs and funders on organizational audit practices, business plan development, appraisals, designing financial service projects in rural areas, and evaluating and defining national microfinance strategies. Since 2002, she has been a resource person for CGAP's MFI Capacity Building Program in Francophone Africa (CAPAF). At CGAP, she has participated in several train-the-trainer seminars in the capacity of Supervisor. Corinne, a French national,  has been living in Côte d'Ivoire for the past 24 years. She is bilingual (French and English) and holds a Master's degree in Developmental Economics from CERDI, University of Clermont Ferrand, France.

Are Banks Necessary? And other Questions

03.04.2018Tokunboh Ishmael, Co-Founder and Managing Director, Alitheia Identity

This blog was originally published on the Medium Website.

Asking this question will no doubt raise eyebrows and much consternation, especially in Nigeria where Alitheia Identity invests in financial services and financial technology aka Fintech. The question is meant to shock banks to get off the fence and into action.

Bill Gates is famously reported by the Economist to have said ‘Banking is necessary, banks are not.’ This quote resonates with my vision of retail banking in a ‘future’ that seems to have already arrived. The retail bank of the future will be ubiquitous, contextual, social and invisible. It will provide personalised services seamlessly/invisibly, much in the same seamless way that Uber receives payments from customers today. Invisible payments will become the norm where customers will walk into certain locations (off and on-line) select or be prompted to enjoy offers on products and services, and have payments automatically deducted. In this regard, the retail banks will be entities that provide non-banking services with embedded banking services. It will be wherever and whenever. Providing payment, savings and credit services in context with the customers’ needs, wants, behaviour and footprint in the driving seat. Amazon has led the foray into this ‘future’ by opening its first checkout-free store.

Currently, entities that are at the vanguard of developing these invisible payments are not traditional banks. They are technology companies such as Amazon and Google. It is widely believed that banks have not been quick to push these technologies for fear of cannibalising their credit and debit card products. Although, this may seem to spell doom for incumbent banks as these seamless technologies enjoy wide adoption, in my view it is unlikely that entities like Google and Amazon will want to completely take over the business of banking, and its attendant regulatory and compliance headaches. Instead they may wish to partner and offer their technologies within a financial services ecosystem. Such an ecosystem would have the retail bank of the future as a platform with incumbent banks at the core providing banking ‘plumbing’ as a service and partnering with Fintech or technology challengers to provide the personalised and contextual experience that customers have come to expect.

Question: Are Nigerian banks ready or preparing for this new reality — a shift from the traditional integrated end-to-end model to a modular plug-and-play model?

It is no surprise that technology shifts will be at the heart of retail banking’s transformation over the next ten years just as it has been over the past ten when the word and concept of digital banking began to gain prominence. However, to date, the use of digital technologies has been majorly focused on automating mundane tasks, and providing shiny new interfaces on old dated banking legacy systems. The retail bank of the future will not merely layer digital interfaces on to existing systems, it will have a digital core upon which it will provide a rich customer experience. To achieve this, software developers, data scientists and design professionals will play a larger role in the management teams and boards of the banks of the future. Their skills will be essential to shift from the emphasis on automating processes to outcomes that delight with a greater focus on customer needs based on insights from treasure troves of customer data.

Question: Have banks started broadening their employee engagement strategies to attract/keep the purveyors of these new skills?

Banks that are still focused on shiny new interfaces and lacking the requisite design/data skills are not at the start line let alone in the race for retail customer growth and stickiness.

The main technologies that will play a key role in the development of the retail bank of the future are Deep Learning and Artificial Intelligence, which will enable the mining of customer data (from both non-financial and financial entities) to set rules based on insights from customer preferences and behaviours. This in turn will enable providers to make informed recommendations for products and services and take pre-determined actions with customer permissions. The winning ‘banks’ in this new world will intelligently use all the information that they have about customers to ‘make life possible and easier’…possible to employ financial services to live life to its full potential, in whatever way the customer chooses to define ‘full’. Smart banks will leverage this data and a customer’s social capital to determine its risk appetite for that customer and how best to use the customer’s social network to market its services. In other words, demand and supply for financial services will emanate from and be fuelled by a customer’s relationship with a non-financial entity and the customer’s social interactions.

On the customer side, the pervasive use of ‘wearable technologies’ and the ‘Internet of Things’ will literally turn the customer and his environment into the ‘branch’ for a personalised and contextual service. The implication of this will be a re-imagining of bank branches and their function. This is already playing out with the reduction of bank branches globally. That said, bank branches will not be completely eliminated but redesigned as places that attract customers to experience their ‘bank’ in a new and modern way.

Question: Are Banks Fintech ready? Are we all ready for this new reality?

The move is inevitable, standing still is actually walking backwards and no one can afford to do that.

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About the Author

Tokunboh Ishmael is an accomplished and experienced private equity investor with a proven track record. She is Managing Director and co-founder of Alitheia Capital (www.thealitheia.com) In 2015, she co-founded Alitheia Identity (www.alitheiaidentity.com) a fund manager that invests in high growth small and medium enterprises (SMEs) with significant opportunity to grow profitably and deliver above-market returns. The firm does this through a proactive approach to funding businesses led by female founders and co-founders towards ensuring greater participation of women at at all levels from boardroom to factory floor. Tokunboh is a CFA Charterholder, corporate financier and M&A banker historically having worked on over $5.6 billion M&A deals across the US, UK and Africa.

Message from the MFW4A Partnership Coordinator

12.01.2018David Ashiagbor

Dear Reader,

As we begin 2018, I would like to wish you all a happy and prosperous New Year on behalf of all of us at MFW4A.

2017 was a pivotal year for us. We began our transition to a more inclusive Partnership with the integration of African financial sector stakeholders into all levels of our platform.  This new phase also includes a revamped value proposition designed to deliver sharper outcomes.

Our work in 2017 strengthened MFW4A’s position as a leading and independent voice on financial sector development in Africa. Mobilising domestic capital for long term investment was a focus for us. We brought together African pension funds, regulators and development finance experts in Abidjan in November, to identify options and instruments to leverage Africa’s growing pension assets for investment in infrastructure, agriculture and affordable housing. A task force was established to follow up on the meeting’s recommendations, which will continue to guide our work in this area. 

A notable outcome in 2017, was the approval of a $3 million Line of Credit to the Union Trust Bank in Sierra Leone, by the African Development Bank (AfDB) in September 2017, following the Conference on Financial Sector Development in African States Facing Fragile Situations co-hosted by MFW4A in June 2016. Another was the resolution taken by Governors of African central banks and Senior officials of international financial institutions, to strengthen supervision and solution plans for Pan-African banks at the ‘’Cross-Border Banking and Regulatory Reforms in Africa‘’ conference, jointly organized with the International Monetary Fund (IMF) and the Basel Committee for Banking Supervision (BCBS) in Mauritius.

Our work in support of a strong and stable African financial sector will continue this year, with national and regional Financial Sector Dialogues in selected regions. These high-level events will provide a platform for African financial sector stakeholders to assess the progress of ongoing reforms in their respective regions and identify future priorities. We will also launch a new programme on Trade Finance to help fill existing knowledge and skills gaps through research, capacity building and advocacy efforts. A Long-term Finance initiative expected to lead to the establishment of a scoreboard that provides comparative indicators of the level of development of long-term finance markets in Africa, will also be launched, in collaboration with AfDB and GIZ.

We will continue to support efforts to develop and implement financial risk management solutions in the agricultural sector while promoting an enabling environment for digital finance. Other activities include research to support diaspora investments and remittances as well as capacity building programmes in our SME Finance and Housing Finance workstreams.

We look forward to your continued support and collaboration.

With our best wishes for a happy and prosperous 2018.

David Ashiagbor
MFW4A Partnership Coordinator


Financing African SMEs: can more of the same help bridge the gap?

24.10.2017Rodrigo Deiana, Junior Policy Analyst & Arthur Minsat, Head of Unit, OCDE

This post was originally published on the OECD Development Matters website.

African firms don’t have it easy. Among the many constraints faced by formal companies, access to finance consistently ranks as a top issue. Almost 20% of formal African companies cite access to finance as a constraint to their business.[i] Overall, African micro, small and medium enterprises (SMEs) face a financing shortfall of about USD 190 billion from the traditional banking sector.[ii] African firms are 19% less likely to have a bank loan, compared to other regions of the world. Within Africa, small enterprises are 30% less likely to obtain bank loans than large ones and medium-sized enterprises are 13% less likely.[iii]

To bridge this gap, governments and market players need to strengthen existing credit channels as well as expand new financing mechanisms.

Various innovative financing instruments are currently expanding or present strong growth potential across Africa. Private equity funds invested a total of USD 22.7 billion in Africa across 919 deals between 2011 and 2016, although less transactions took place in the last months. Most took place in capital-intensive sectors such as telecommunications and energy.[iv] Asset-based lending can ease some stringent conditions associated with traditional credit. Experiences in Burkina Faso (with Burkina Bail) and South Africa suggest that commercial banks and other financial operators can engage in factoring and leasing services, without the need for additional legislation.[v]

At the same time, many entrepreneurs can directly harness new financing mechanisms such as crowd-funding or venture capital within and outside Africa. Togolese entrepreneur Afate Gnikou successfully used crowdfunding to raise the capital for a prototype 3D printer from recycled electronic waste selling at an affordable price of less than USD 100. Nigeria’s online movie entrepreneur Jason Njoku, for one, raised USD 8 million in venture capital from African and global investors. Andela, a pan-African start-up launched in 2014 that pairs coders with global companies, recently obtained USD 40 million in funding from an African venture capital fund.[vi] This opens the door for African entrepreneurs to look for funding within the continent rather than in Europe or North America. Return migrants are using remittances, expatriate savings or loans to fund their businesses. More international equity funds are providing seed or venture capital to African SMEs, often by specialising in African markets with a mix of private and public funds.[vii]

Many other instruments can help fill SMEs’ financing gap: microfinance for SMEs, direct support from development partners (e.g. the African Development Bank’s Souk At-Tanmia initiative, providing financing and mentoring services to entrepreneurs), and philanthropic finance (the Tony Elumelu Foundation’s support to start-ups in Africa regularly makes the headlines; other initiatives are also growing such as the think tank Land of African Business).

However, these innovative financing solutions are out of reach for the majority of small businesses operating in the informal economy. To bridge the financing gap, we must also improve traditional credit channels by expanding best practices in the financial sector.

Some emphasise the role of traditional instruments, such as credit guarantee schemes (CGSs). CGSs are guarantees by third parties -- governments or development partners -- that can cover a portion of the lenders’ losses from loans to SMEs, significantly reducing default risk for banks. CGSs can benefit small businesses that have little collateral, no credit history or are perceived as too risky. Policy experiences outside Africa (from Turkey and Malaysia) have shown that CGSs can avoid creating market distortions.[viii] A set of key principles can guide the design of effective guarantee schemes without incentivising lending to high-risk borrowers. They can also contribute to reducing poverty. In Tanzania, for instance, several of these guarantees effectively channelled funds to the more vulnerable groups otherwise unable to access credit, such as smallholder farmers as well as micro and small entrepreneurs.[ix] CGSs can also work on a larger scale, as shown by the African Guarantee Fund’s experience. Commercial banks leveraged the Fund’s USD 230 million in guarantees to lend out double that amount to 1 300 SMEs, generating 11 000 jobs. The Fund reached break-even point and started turning profits in just three years, quadrupling its revenue.[x] 

Many solutions exist to bridge the financing gap faced by Africa’s SMEs. Finding a balance between traditional and innovative financing depends on each country’s context. While the 54 African countries are very diverse, three main issues stand out. First: developing regulations and policies (e.g. on tax compliance, contract enforcement) that are flexible enough for innovation by African entrepreneurs. Second, broadening and widening financial solutions that are accessible to the most vulnerable groups. For example, Rwanda’s financial sector has been able to diversify despite its small size, with banks, savings cooperatives, microfinance institutions all tailoring their products to different target social groups. Finally, governments must aim to ensure macro-economic stability by avoiding market distortions and excessive risk taking. In this sense, the establishment of SME Authorities may help reduce information asymmetries and reduce lending risks. To achieve these objectives and increase the financial sources available to small African businesses expanded co-operation between governments, development partners and the private sector will remain vital.


[i] AfDB/OECD/UNDP (2017) African Economic Outlook 2017: Entrepreneurship and Industrialisation: 210, calculations based on The World Bank Enterprise Surveys. World Bank Enterprise Surveys cover firms in the formal sector with at least 5 employees.

[ii] Based on data from IFC’s Enterprise Finance Gap Database

[iii] AfDB/OECD/UNDP (2017): 225, based on Beck and Cull (2014), “SME finance in Africa”, Journal of African Economies, Vol. 23 (5), pp. 583-613

[iv] AVCA (2017), 2016 Annual African Private Equity Data Tracker

[v] Based on evidence from factoring and leasing services in Burkina Faso (through the financial company Burkina Bail) and South Africa (through the commercial banking sector), the Bank of Namibia argued for the possibility of successfully replicating such services in Namibia. See AfDB/OECD/UNDP (2017): 226 for further information.

[vii] Severino, J.-M. and J. Hajdenberg (2016), Entreprenante Afrique, Odile Jacob, Paris.

[viii] IFC (2010), Scaling-Up SME Access to Financial Services in the Developing World

[x] AfDB/OECD/UNDP (2017): 226, based on African Guarantee Fund, 2015 Annual Report

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About the Authors

Rodrigo Deiana is a Junior Policy Analyst in the OECD Development Centre's Africa Unit as part of the UN's JPO Programme financed by Italy. He contributed to the 2017 edition of the African Economic Outlook (AEO), and among other topics works on policy aspects of international trade and financial sector development in Africa. Before joining the OECD, Rodrigo was an economist in the Government of Rwanda as part of the ODI Fellowship, advising on regional integration, trade policy, and private sector development. He also worked as consultant to the World Bank Group in Kigali on matters of agricultural policy. Prior to that, he worked at the European Central bank in Frankfurt and at the World Trade Organization in Geneva. Rodrigo holds a Master's degree from the Barcelona Graduate School of Economics and a BA in International Economics from the University of Nottingham.

Arthur Minsat leads the OECD Development Centre's Africa Unit. He is responsible for the African Economic Outlook (AEO), a partnership with the African Development Bank and UNDP, and the Revenue Statistics in Africa, a joint publication by OECD, the African Union Commission and the African Tax Administration Forum. As lead economist, Arthur drafted the thematic chapters of the AEO 2017 on Entrepreneurship and Industrialisation, AEO 2016 on Sustainable Cities, AEO 2015 on Regional Development. Before joining the OECD, Arthur contributed to the UNDP's flagship Human Development Reports. He worked in Abidjan during the electoral crisis in 2010 and 2011, monitoring West Africa's economic outlook for the United Nations Operations in Côte d'Ivoire (ONUCI). Prior to that, he taught economics and international relations in several British universities and gained private sector experience with Wolters Kluwer Transport Services. Arthur holds a PhD from the London School of Economics (LSE) and a Franco-German double diploma from Sciences-Po Lille and the University of Münster.

Capital requirement, bank competition and stability in Africa- Q&A Session

05.09.2017Jacob Oduor, Principal Research Economist, African Development Bank

This Q&A session highlights key insights of a study co-authored by Dr. Jacob Oduor, economist with African Development Bank. The research shows that increased capital beef-up significantly increases financial instability in Africa (except in big banks) implying that higher capital requirements did not make African banks safer.

1. Why did you choose a topic on the banking sector, precisely on regulation? Is there any subdued risk with African banking system that justifies your research?

The banking sector is important in driving economic growth through intermediation of investment resources. Its effectiveness in achieving this role can however be undermined by one-size-fit-all regulations. In Africa, where financial inclusion is still low, any regulation that increases the cost of financial services may be counterproductive in achieving the broader economic growth objectives. If increased capital requirements can achieve its core objective of financial stability without adversely affecting the cost of financial services, then it is welcome. That tradeoff is important but sometimes difficult to strike.

2. Basel I, Basel II and now Basel III have called for capital build-up over time. In your view, how will the latest reform affect African banks?

Capital build up has the consequence of creating bigger banks. There are two main problems with this. First, emerging evidence show that bigger banks are not necessarily safe. They perceive themselves to be "too big to fail" and therefore engage in more risky investments and are more vulnerable to shocks that smaller banks (Berger and Mester, 1997[1]) and such regulation may just as well increase banking sector instability in Africa. The second and more important consequence for Africa is that capital build-up concentrates the banking industry, reduces competition, has the potential to drive up costs of financial services and stifle financial inclusion. The high initial capital stringency requirements can impose entry barriers for new entrants and this would restrict competition and allow existing banks to accumulate market power (Berger et al; 1993[2]). In a continent where financial inclusion is pathetically low, such regulation may have more negative consequences than benefits.

3. Your research was centered on the impact of regulatory build-up on first financial sector stability and second competition. What did your research reveal?

The results show that increased capital beef-up significantly increases financial instability in Africa (except in big banks) implying that higher capital requirements did not make African banks safer. We also find that increased regulatory capital improves competitive pricing for foreign banks while it makes domestic banks less competitive. This is mainly attributed to the high cost of sourcing and holding extra capital for domestic banks compared to foreign banks who can source cheaper capital from parent companies. The results put to question the effectiveness of higher regulatory capital on stability and competitiveness of the African financial system.

4. Did you find in your literature review similar conclusions?

While other studies including Furlong and Keeley (1989)[3] and Keeley (1990)[4] found stabilizing effects of increased capital requirements, other studies have come to similar conclusions as our study. Boot and Greenbaum (1993)[5] for instance find that capital requirements reduce monitoring incentives, which reduces the quality of banks' portfolios increasing the risk of instability. Hakenes and Schnabel (2010)[6] on the other hand show that tighter capital requirements increases the risk of individual loans and may also increase a bank's probability of default because they relax the competition for loans and thus destabilizing the banking sector.

On increased capital requirements and competition, similar findings as ours were obtained by Bikker & Groeneveld (1998)[7] who assessed competitive structure in the banking industry in the EU and finds that concentration impairs competitiveness. Similar findings were also obtained by and Claessens and Laeven, 2004[8] among others.

5. In your research, you also test your model for reserve causality. What was the idea behind the test and what did the test show?

The potential for reverse causality emanates from the fact that banks that are viewed by the regulators to be less stable are likely to be asked to keep higher capital ratios compared to more stable banks. Instability may therefore be a cause of higher capital requirements for banks as much as higher capital requirements may be a source of instability. The results using instrumental variables approach, confirm the findings that increased capital ratio increases instability in the banking sector.

6. You mentioned that some critics argue that Basel III is too complex and allows banks to use in-house creative models to hold less capital than they should. Can you talk more about some of these techniques and how can regulators address the shortcoming? How will/should this be addressed in the context of the African continent?

Amendments to the Basel Accord in 1996 permitted regulators to accept assessments from banks' internal risk-management models in setting capital requirements for the market risk in banks' trading portfolios. Consequently, trading-book models have become increasingly common in banks. These models generally estimate value at risk (VaR). Because of the large number of traded securities, trading-book VaR models inevitably use a large number of simplifying assumptions resulting in different estimates of value at risk. It is therefore not inconceivable that some banks use these internal models to understate their risks in order to maintain less regulatory capital which exposes the whole sector to risks. To remedy such situation, regulators must ensure banks calculate their risk weightings and capital requirements on the basis of a common standardized approach. In-house models could be used to supplement but not substitute standard models. To reduce the ability of banks to hide risky assets there is need for reduced discretion of banks in calculating their risk weightings by narrowing the range of modeling choices for banks and improving public disclosure by banks. There is also need to explore regulation with varying standards based on complexity and risk.

7. In the US, the concept of "too big to fail" has emerged as a hot contentious topic between regulators, policy makers and banks. A debate between breaking up large banks or at the very least the reinstatement of some Glass-Steagall-like legislation and the status quo. You cite the example of Nigeria as evidence that consolidation is not the answer to the banking system stability. Do you see any systemic risk associated with the size of the banks operating in our continent? Have some of them reached that critical level?

While this study did not go into establishing the specific threshold beyond which inefficiency sets in, experience has shown that big banks can fail and there is a threshold size beyond which decreasing marginal returns sets in. Attempting to build resilience through indefinite increase in capital requirements may be counterproductive. In addition, capital buffers on their own without accompanying regulations are at best, inadequate. Regulation must therefore look beyond the size of the banks. Market concentration in the banking industry in Africa is high compared to the developed world and therefore the potential for systemic risk exists, but whether some African banks have reached that threshold is an area for further research. What is clear from our results is that prescriptive blanket regulations on capital buffers has not helped reduce that risk. Dealing with systemic risk should not therefore overemphasize on size, but accompanying regulations to ensure good governance and prudent risk taking irrespective of the size.

8. If capital build-up is not the answer to increase financial sector stability, what types of policy should regulators and policy makers pursue/explore in their quest for a strong, deep and liquid financial sector?

Capital build up is still important in building resilience, but it is not the only way to build resilience, not in all contexts and on its own it is inadequate. Regulators must be able to identify the sources of systemic risks and develop regulatory instruments that are able to deal with different kinds of risks. Internal governance weaknesses is turning out to be a major source of instability in the banking sector in many countries both in Africa and in more developed markets. This kind of risk cannot be cured by increasing capital buffers. Improvements in monitoring and supervision of banks may as well give the same financial stability outcome without jeopardizing financing inclusion objectives.

9. What is your opinion on the emerging rivalry between fintechs and banks and do you see this as an inevitable event to improve efficiency and increase inclusion? From the regulatory stand-point, what if need be, can be improved?

Without a doubt, fintechs have disrupted the business-as-usual way of traditional banks and helped improve financial access and efficiency beyond the boundaries that traditional banks were willing to go. From mobile money payment and transfer services, to savings and credit services through the mobile phone platforms, fintechs have proved to the banks that your can reach the low-income unbanked and still make profits. Banks are increasingly adopting the same approaches to delivery financial services in order to stay in business. However, in some instances, the pace of adoption of new technologies in the financial sector is faster than regulations. A number of regulators have not developed tools and infrastructure including state of the art reporting and analytics infrastructure to support and sufficiently regulate the fintech innovations. In most cases, fintech companies are discouraged by the time and cost of registering and complying with regulations. This is a particular problematic in the financial services sector in Africa where political interests are still intense and where intruders coming to share the profits are not welcome. In addition, regulations should be flexible and fintech companies should not be forced into the same costly regulatory mold as traditional banks, which may stifle innovative capacity of start-ups.

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[1] Berger, A. N. & L. J. Mester. 1997. Inside the black box: What Explains Differences in The Efficiencies of Financial Institutions? Journal of Banking & Finance, Vol. 21, pp. 895-947

[2] Berger A. N., W. Hunter, and S. Timme. 1993. The Efficiency of Financial Institutions: A Review and Preview of Research Past, Present, and Future, Journal of Banking and Finance, Vol.17 pp. 221-249

[3] Furlong, F. T. and M. C. Keeley. 1989. Capital Regulation and Bank Risk-Taking: A Note, Journal of Banking and Finance 13, 883-891.

[4] Keeley, M. C. 1990. Deposit Insurance, Risk and Market Power in Banking, American Economic Review, Vol. 80(5), pp. 1183-1200

[5] Boot, A.W., and S. Greenbaum. 1993. Bank Regulation, Reputation, and Rents: Theory and Policy Implications. In: Mayer, C., and Vives, X. (eds), Capital Markets andFinancial Intermediation. Cambridge, UK: Cambridge University Press, 292-318.

[6] Hakenes, H. and I. Schnabel. 2010. Capital Regulation, Bank Competition, and Financial Stability, Leibniz University of Hannover, MPI Bonn, and CEPR

[7] Bikker J.A. and J.M. Groeneveld. 1998. Competition and Concentration in the EU Banking Industry Research Series Supervision 8, Netherlands Central Bank, Directorate Supervision

[8] Claessens, Stijn, and Luc Laeven. 2004. What Drives Bank Competition? Some International Evidence. Journal of Money, Credit, and BankingVol. 36, pp. 563-583

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About the Author

Dr. Jacob Oduor is Principal Research Economist at African Development Bank (AfDB). He is a holder of Ph.D in Economics from Bielefeld University, Germany. He is also a holder of MA (Economics) and BA (Economics)- First Class Honours from Kenyatta University, Nairobi, Kenya. Prior to joining AfDB, Dr. Oduor lectured in the School of Economics at Kenyatta University and he worked with the Cooperative Bank of Kenya and the Kenya Institute for Public Policy Research and Analysis (KIPPRA). Dr. Oduor is an accomplished time series econometrician specialized in: time series, cointegration, general macroeconomic theory and policy, monetary policy and growth theory.

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Better Regulations Can Spur Agent Banking in WAEMUCorinne Riquet, Financial Sector Specialist, CGAP
Are Banks Necessary? And other QuestionsTokunboh Ishmael, Co-Founder and Managing Director, Alitheia Identity
Solving the Puzzle of Responsible Exists in Impact InvestingHannah Dithrich, Research Associate, The Global Impact Investing Network (GIIN)

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