how can small island nations benefit from agent banking

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Agent Banking: How Can Small Island Nations Benefit and What are the Supervision/Oversight Issues John Owens, Senior Policy Advisor, AFI PIRI Meeting, Dili, Timor-Leste, May 2015

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Page 1: How Can Small Island Nations Benefit From Agent Banking

Agent Banking: How Can Small Island Nations Benefit and What are the Supervision/Oversight Issues

John Owens, Senior Policy Advisor, AFIPIRI Meeting, Dili, Timor-Leste, May 2015

Page 2: How Can Small Island Nations Benefit From Agent Banking

Agents Defined

“Any 3rd party acting on behalf of a bank or other financial services provider (including an e-money

issuer) to deal directly with customers”

AFI | Alliance for Financial Inclusion

AFI Digital Financial Services Working Group (DFSWG) DFS Basic Terminology http://www.afi-global.org/library/publications/mobile-financial-services-basic-terminology-2013

Page 3: How Can Small Island Nations Benefit From Agent Banking

Agent Regulatory Framework

AFI | Alliance for Financial Inclusion

Laws

Regulations

Guidelines

Page 4: How Can Small Island Nations Benefit From Agent Banking

Agent Models

AFI | Alliance for Financial Inclusion http://cfi-blog.org/2014/03/11/microfinance-industry-needs-an-infrastructure-fix/

Bank Non Bank Hybrid

Page 5: How Can Small Island Nations Benefit From Agent Banking

Agents: Basic Services

Client registration

KYC outsourcing

Remote account opening

CICO

Payments

AFI | Alliance for Financial Inclusion http://blog.microsave.net/wp-content/uploads/2014/03/mor-lks2.jpghttp://www.developmentoutlook.org/2012/11/analyzing-business-correspondent-model.html

Page 6: How Can Small Island Nations Benefit From Agent Banking

Types of Agent Banking Services

Collection of small value cash deposits and cash withdrawals

Inward foreign remittance disbursement

Facilitating small value loan disbursement and payments

Facilitating utility bill payments

Cash payment under social safety net programme

Facilitating fund transfer

Balance inquiry

Collection and processing of forms for account opening

Loan application, credit and debit card applications

Monitoring of loans and advances and follow up of loan recovery

Receiving of cheques for deposit

Other functions like collection of insurance premiums

AFI | Alliance for Financial Inclusion https://www.upsides.com/2013/03/25/banking-beyond-branches/

Page 7: How Can Small Island Nations Benefit From Agent Banking

Bangladesh: Mobile-Enabled Agent Banking

AFI | Alliance for Financial Inclusion

Central Bank Issued Clear Guidelines

Agent Banking & Allowable Services

Eligibility Criteria for Agents

Allowance of Non-Exclusive Agreements

Risk & Operational Issues

Consumer Protection Principles

Results

541,000 active agents 25.2 M registered

clients 12.2 M active clients

Page 8: How Can Small Island Nations Benefit From Agent Banking

Agent Banking & Outreach in Brazil

Outreach figures bank agents vs. branches in Brazil

AFI | Alliance for Financial Inclusion

Page 9: How Can Small Island Nations Benefit From Agent Banking

Solomon Islands: An Example of How Small Islands can Benefit from Agents

AFI | Alliance for Financial Inclusion

Central Bank Enabling Environment

Agent Banking Regulations

Expanded Eligibility Criteria for Agents

Tiered KYC Regulations

Close dialogue with the Private Sector in Developing Policies

Financial Literacy and the role of the Private Sector

Results

From 80% without a bank account 5 years ago, 71% now have access to basic banking services.

Page 10: How Can Small Island Nations Benefit From Agent Banking

Minimum Standards for FIs in Requesting Agent License

Policies related to agent selection, management, monitoring, operations, compliance, conduct and service quality

Customer protection measures, including awareness and education strategies

Infrastructure to support agent banking including system and technology requirements

Controls and monitoring to ensure compliance with relevant legislation and regulatory requirements

Business Continuity Plan (BCP) and contingency arrangements to ensure continuity of agent banking services in the event of disruption.

AFI | Alliance for Financial Inclusion

Page 11: How Can Small Island Nations Benefit From Agent Banking

Selection Criteria for Agents

Competence to implement and support the proposed activities

Financial soundness and cash handling capability

Ability to meet commitments under adverse conditions

Business reputation

Ability to offer technology based financial services

Security and internal control, audit coverage, reporting and monitoring capacity

Due diligence and background check to ensure suitability

AFI | Alliance for Financial Inclusion

“Know Your Agent”

Page 12: How Can Small Island Nations Benefit From Agent Banking

Agency Agreement Conditions

Define the rights, expectations & responsibilities of the parties

Set the scope of fee structure

Services are subject to regulatory review & oversight

Allowed & prohibited functions

Safe‐keeping of all relevant records, data & documents

Client confidentiality

KYC requirements

Default, penalties & termination of contract conditions

AFI | Alliance for Financial Inclusion

Page 13: How Can Small Island Nations Benefit From Agent Banking

Other Agent Banking Guidelines

Internal audit & monitoring requirements

Customer protection standards

Dispute resolution rules

AML/CFT guidelines

Risk mitigation rules

Disclosure requirements

Branding & advertisement rules

AFI | Alliance for Financial Inclusion

Page 14: How Can Small Island Nations Benefit From Agent Banking

Exclusivity of Agents?

Should agents be exclusive? Some jurisdictions that allow exclusivity Examples & issues Most now are non-exclusive for non-banks Exclusivity for bank agents

AFI | Alliance for Financial Inclusion http://www.gemalto.com/companyinfo/digital-stories/india

Page 15: How Can Small Island Nations Benefit From Agent Banking

Emerging Issues

AFI | Alliance for Financial Inclusion

Rural vs Urban agents

Inadequate liquidity

AML/KYC abuse Tracking inactive

agents

Lack of business continuity