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