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Promoting Financial Inclusion - United Nations Development ...

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price for those provided services on a viable<br />

basis and a lower than optimal volume for<br />

those receiving subsidized services.<br />

It is notable that the rural banking system<br />

(consisting of the DCCBs and RRBs) has<br />

not had to follow interest rate regulation<br />

for around a decade now. Yet, at no point<br />

has it felt free to charge much more than<br />

the commercial banks for the apparently<br />

more inclusive services it provides. A study<br />

by M-CRIL in 2008-09 showed that the<br />

average yields of DCCBs and RRBs were<br />

not significantly more than the 10.5%<br />

average yields of commercial banks (in<br />

2007-08) despite the RRBs operating<br />

expense ratios that were significantly higher<br />

(see Figure 6.1). While DCCB operating<br />

expense ratios were lower this was largely<br />

on account of most origination expenses<br />

being borne by the loss making PACS.<br />

Hence as it turns out the lower yields of<br />

the cooperative banks actually come at<br />

the expense of the target population that<br />

they are trying to protect as it is ultimately<br />

members who must bear the losses of the<br />

PACS.<br />

There is no evidence so far of bank<br />

managements charging higher interest on<br />

financial inclusion products despite the<br />

higher costs of such services. This limits<br />

the business potential of financial inclusion.<br />

Thus, the services available remain limited<br />

in volume (small value SHG loans and nonfunctional<br />

no-frills accounts) and lacking<br />

in innovation. Ultimately, as a result, low<br />

income families continue to remain excluded<br />

and the legendary, rapacious moneylender<br />

flourishes in providing the only real financial<br />

services available to low income families.<br />

6.3 PRUDENCE IN REGULATION<br />

AND PROMOTION IS<br />

PERHAPS A CASE OF ‘NO<br />

RISK, NO RETURN’<br />

The discussion in the earlier sections has<br />

shown extensively how financial regulators<br />

and the government in India have opted for<br />

prudence in relation to financial inclusion<br />

rather than bold, even adventurous,<br />

experimentation. While the easing of KYC<br />

norms and the launching of an extensive<br />

financial literacy programme are excellent<br />

long term measures, some examples of<br />

the limitations of a cautious approach are<br />

discussed below.<br />

1. The prevailing environment of low<br />

cost, cross-subsidized inclusive finance<br />

products to improve the availability of<br />

financial services to low income families<br />

have proved to be a detriment to<br />

volumes as well as to experimentation<br />

and innovation.<br />

2. In an effort to regulate the business<br />

relationship between financial service<br />

providers and clients, the business<br />

correspondent model was constrained<br />

for four years on pricing and by<br />

stipulations on who could and could not<br />

be a correspondent. The prevention of<br />

microfinance NBFCs from playing the<br />

role of BCs continues to be a limitation<br />

on outreach, since it is these institutions<br />

that have a financial relationship with the<br />

largest number of low income families, as<br />

well as on the functioning of MFIs since<br />

they continue to have a uni-dimensional<br />

‘credit only’ relationship with their<br />

clients. A more holistic relationship<br />

would not only protect such families as<br />

borrowers) but would also create a more<br />

secure savings environment for them.<br />

3. Similarly, in the case of the microinsurance<br />

regulation there are significant<br />

rules governing the relationship<br />

between the insurance company, their<br />

agent and the client. Again microfinance<br />

NBFCs are allowed to be distributors<br />

of insurance but not agents resulting in<br />

significant, and unproductive, attempts<br />

at regulatory arbitrage rather than a<br />

direct concentration on the rolling out<br />

of products to large numbers of clients.<br />

PROMOTING FINANCIAL INCLUSION 43

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