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Automation of SACCOs - FSD Kenya

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12 • AUTOMATION OF SACCOS: ASSESSMENT OF POTENTIAL SOLUTIONS<br />

We also expect the regulatory authority to require the SACCO management to<br />

have a documented and demonstrably pr<strong>of</strong>ound and structured insight to the<br />

business. For example could the authority require detailed business plans to<br />

approve strategic as well as smaller changes to the SACCO, such as opening a<br />

new branch. Such plans are difficult to develop without access to a significant<br />

amount <strong>of</strong> detailed historic data and if the plan is not accurate it will not be a<br />

useful tool to the SACCO. To gain approval from the authority for various key<br />

activities the management would for example be required to explain:<br />

How can deposits be mobilised?<br />

What is the cost <strong>of</strong> debt (external capital and deposits)?<br />

What are the operating expenses?<br />

What cash reserves are required?<br />

What provisions can be expected to cover delinquency?<br />

What fixed assets would be required to operate the business?<br />

Forecasted operating pr<strong>of</strong>it.<br />

Economic and demographic statistical data about the area.<br />

The authority could also make direct requirements on the minimum features<br />

<strong>of</strong> the system such as: audit trail report, adequate security, integration <strong>of</strong><br />

operations, capacity for future expansion real time and relational database<br />

management.<br />

3.4 rEGuLATIonS ConTEnT<br />

3.4.1 Credit management<br />

We expect the regulations to focus heavily on credit management as the core<br />

business <strong>of</strong> the SACCO and the primary source <strong>of</strong> risks to the viability <strong>of</strong> the<br />

SACCO. The SACCO will need to establish a policy that provides a foundation for<br />

issuing and recovering loans in accordance with the principles <strong>of</strong> the regulation<br />

and supports financial performance at par with or exceeding the regulations.<br />

The policy needs to be applied consistently, without discriminating any person<br />

positively or negatively and the customers need to be provided insight to the<br />

process and its outcome.<br />

Loan issuing<br />

The role <strong>of</strong> the system during loan issuing will be to facilitate the business<br />

processes corresponding to the policy by:<br />

Supporting presentation <strong>of</strong> the SACCO product <strong>of</strong>fering to identify<br />

suitable products to a prospective borrower by presenting the terms and<br />

conditions <strong>of</strong> the loans and loan eligibility criteria.<br />

Capturing applicant’s data such as personal information, financial<br />

background, purpose <strong>of</strong> the loan and all necessary information about<br />

guarantors and collateral.<br />

Support appraisal by 1) calculating the maximum loan amount as<br />

percentage <strong>of</strong> collateral or guarantors’ shares to ensure that all loans<br />

are fully secured. 2) Identify and document any relationship between<br />

borrower and SACCO employee. 3) confirm any required co-signers and<br />

4) any additional eligibility criteria and present outcome.<br />

Capturing the outcome <strong>of</strong> the appraisal process and either enforce<br />

or recommend the subsequent action. Enforcing meaning that only<br />

applicants fully compliant with the appraisal criteria will be approved<br />

and the system would only allow rejection in all other cases. Recommend<br />

meaning that the system provides a recommendation which the users,<br />

depending on seniority, can follow or overrule. In the case over overruling<br />

the system will capture the basis for the decision.<br />

Real-time risk management in parallel with the issuing to understand<br />

how the new loan impacts 1) loan concentration, 2) the portfolio value<br />

per product and 3) the total commitment per guarantor relative to total<br />

value <strong>of</strong> shares to prevent over-commitment.<br />

Release loan disbursement payment when the appropriate authority has<br />

confirmed in the system.<br />

Loan recovery<br />

The system will perform a key role in recovery by providing an ability to<br />

automatically monitor the portfolio and take or suggest collection actions<br />

to mitigate delinquency. The system will also make accounting postings to<br />

maintain accounts in accordance with IFRS. <strong>Automation</strong> <strong>of</strong> these processes<br />

will be necessary in order to reach the efficiency required to comply with<br />

regulations.<br />

Automated monitoring <strong>of</strong> and provisioning for loan aging is one <strong>of</strong> the systems<br />

key features as it provides the SACCO with a continuously accurate and upto-date<br />

view <strong>of</strong> the core operation and ensures regulatory compliance. The<br />

regulations will include categories based on performance and the necessary<br />

corresponding provision as <strong>of</strong> table 2. It is necessary that the system adapts the<br />

performance reporting to the terms and conditions for each product as there<br />

is no generic definition. For example, will a product with balloon payment not<br />

be delinquent despite the fact that no payment might occur for e.g. the first 6<br />

months <strong>of</strong> the loan duration.<br />

In addition to the Act IFRS forms another minimum requirement for especially<br />

revenue recognition. For example no interest may be recognised as revenue<br />

for non-performing loans after 3 months and accrued interest may at no<br />

times exceed 30 days earnings <strong>of</strong> the entire portfolio. The system needs to<br />

automatically adjust when these thresholds are reached.<br />

A SACCO needs to write-<strong>of</strong>f loans under certain conditions. Several <strong>of</strong> these<br />

<strong>SACCOs</strong> cannot with full certainty be automated. The system could be required<br />

to prompt the SACCO but will require manual monitoring. However, as the<br />

posting is made the system should also capture the reason and background

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