Smart Campaign Progress Report July 2015
Content
Keeping
Clients First
in Inclusive
Finance
Progress Report
July 2015
Momentum
“Momentum to improve client protection is accelerating,
with scores of FIs across the globe improving their practices
and being recognized for it through certification.”
ISABELLE BARRÈS
Director, Smart Campaign
Our Mission
The Smart Campaign is a global effort to unite leaders
in financial inclusion around a common goal:
to keep clients as the driving force of the industry.
Protecting clients is not only the right thing to do;
it’s the smart thing to do. When financial institutions
implement the Campaign’s Client Protection Principles
into their operations, they build strong, lasting
relationships with clients, increase client retention,
and reduce financial risk. Similarly, by incorporating
client protection principles into their investment
criteria and due diligence, investors can build a
healthier, more clientâfocused industry that will foster
a stronger portfolio and ensure healthy returns.
To help the microfinance industry remain both socially
focused and financially sound, the Smart Campaign
is working with microfinance leaders from around the
world to provide financial institutions with the tools and
resources they need to deliver transparent, respectful
and prudent financial services to all clients. By putting
clients first and collaborating together, we can strengthen
the microfinance industry and elevate it as a model of
responsible banking.
Letter from
The Campaign
Director
Page One
It is in everyone’s interest to ensure that when low-income people seek formal financial services,
they can be confident of receiving fair and appropriate treatment. Around the world today, this
confidence is often lacking. The Smart Campaign works from a provider perspective to embed
the Client Protection Principles throughout the microfinance industry and, increasingly, into the
broader financial inclusion sector. The campaign’s standards of care address such critical issues
as prevention of over-indebtedness, transparency, privacy, respectful treatment, and means for
resolving problems.
The signature program of the Campaign is Smart Certification, launched in 2013. The program
publicly recognizes financial institutions (FIs) that meet all 30 of its standards of care. We envision
certification as a signal to investors, regulators and, ultimately, clients that an FI upholds the Client
Protection Principles. To date, 37 institutions – including some of the world’s largest and most
influential microfinance providers – have achieved certification through a third-party evaluation
of their policies and procedures. Together, those FIs serve more than 19 million clients, or nearly
10 percent of the world’s microfinance clients. In India, Smart-Certified FIs account for 25 percent
of the nation’s microfinance customers. Increasingly, funders look for an FI’s commitment to
Smart Certification when deciding where to invest.
In 2014 the Campaign commissioned two external evaluations, one on its overall strategy (conducted
by the Aspen Planning and Evaluation Program) and one on the certification program (by BSD
Consulting). We were pleased that both evaluations affirmed the widespread industry awareness
and acceptance of the Client Protection Principles, as well as respect for and use of the Campaign
as a resource. Both evaluations made recommendations that we are working to incorporate.
Recommendations on streamlining certification have already resulted in changes announced in April
2015, with further improvements to be released in December.
As we move into a new strategic phase covering 2016-2018, the Campaign is adopting two
significant new directions, both supported by evaluation results. First, the Campaign will expand
to address the broader financial inclusion sector, including digital financial services. Second, it
will work more specifically to improve the market-level environments that strongly influence the
behavior of individual providers. As always, the collaboration of allied organizations – CGAP, the
Social Performance Task Force and many others – is key in successfully achieving these goals.
The journey continues to be a dynamic and rewarding one, and we are moving forward together
for the benefit of low-income clients across the globe.
Isabelle Barrès,
Campaign Director
The Campaign
in Review
Gaining Momentum
As the world increasingly embraces financial
inclusion, two recent research projects undertaken
by the Smart Campaign, ‘Client Voices’ and ‘What
Happens to Microfinance Clients Who Default’,
remind us that if financial inclusion is to fulfill its
promise, client protection must be front and center.
The Client Voice research details, from clients
themselves, the various ways that the microfinance
experience can turn stressful and destructive. The
Default project makes it clear that in countries with
weak regulation, lack of credit
reporting infrastructure and low
client financial capacity, risks to
clients increase notably. Our mission
is to build an ecosystem that
minimizes client risk and champions
good client protection practices,
country by country.
Client Protection Certification
is the tip of a long spear. While
the Campaign aims ultimately
to establish certification as a
competitive necessity for FIs, it is
also the fruit of an extended effort
in improving FI practices that has
reached different stages in different
global regions, as well as among
the thousands of FIs worldwide.
Before launching its certification
program, the Campaign and
its allies had to define client
protection; win recognition
and buy-in across the global
industry; create tools and deploy trainers to make
implementation feasible; build processes of internal
and third-party assessment for FIs; and work with
donors, investors and regulators to create incentives
for sustained client protection efforts. All this laid
the groundwork for certification. All of these efforts
are ongoing.
We are poised to do more to leverage the work of
partners. That means engaging more certifiers,
assessors and trainers; working closely with the most
capable microfinance associations and networks;
coordinating efforts with other global organizations
focused on social performance and client protection;
and encouraging investors and donors to incorporate
the Client Protection Principles in their due diligence.
In coming years, the Campaign will focus increasingly
on standard-setting as our partners build capacity on
the ground. At the same time, as described in more
detail below, we are working to extend client protection
efforts into the broader arena of financial inclusion.
A New Climate for Consumer Protection
In the microfinance movement’s first three decades,
industry leaders were focused almost entirely on
building the capacity to make credit
available to the unbanked. Good
intentions and good works were
largely assumed to flow naturally
from the effort to extend credit to
the poor. By 2008, however, enough
concern about quality of services
prompted industry leaders from
around the world to define what
became the Client Protection
Principles (CPPs). While there was
support for the CPPs, there was a
genuine lack of awareness in the
broader microfinance industry, as
well as hints of skepticism that there
was, in fact, a need for improvement.
Today, receptivity to financial
consumer protection has
improved markedly. Increasingly,
practitioners recognize that client
protection is good for clients, good
for business and good for the
industry. The Campaign’s efforts are
supported and its effects multiplied
by a host of industry groups, including the national
associations that define local codes of conduct and
the international development funds, investors
and donors who design covenants, monitor overindebtedness, and create measurement standards,
often directly incorporating the CPPs. Allies from the
world of finance and development include or have
included Agence Française de Développement, Asia
Development Bank, Credit Suisse, Deutsche Bank,
the Ford Foundation, the Multilateral Investment
Fund of the Inter-American Development Bank, the
International Finance Corporation, The MasterCard
Foundation, SIDBI, USAID, and others.
Campaign
by the Numbers
Page Three
4,496
303
Total Endorsements of the
Smart Campaign and the
Client Protection Principles
(as of June 2015)
Combined Training Events
and Assessments
Conducted Since
Campaign’s Founding
2,193
Individual
Endorsements
184
Network and
Association
Endorsements
184
Investor and Donor
Endorsements
1,584
Microfinance
Institution
Endorsements
Page Four
High-profile crises – in Bosnia, India, Morocco,
Nicaragua and elsewhere – drove home the
importance of strong efforts to avoid overindebtedness and the deep financial implications
of poor client treatment. Regulators, who had
previously focused their energy on prudential
supervision, are now more active in the marketconduct space for financial inclusion. Leaders such
as Peru’s Superintendencia de Banca, Seguros y AFP
(SBS), the Bangko Sentral ng Pilipipinas (BSP) and
the Alliance for Financial Inclusion’s Consumer
Empowerment and Market Conduct Working Group
are creating environments where incentives for client
protection and the Smart Campaign’s work resonate.
The client protection movement is even beginning to
spread to new frontiers of financial inclusion. In late
2014, the Groupe Speciale Mobile Association (GSMA)
launched a code of conduct for digital financial
services that has been endorsed by leading mobile
money providers. The Smart Campaign stands ready
to share the benefit of our long experience in these
emerging efforts.
Tools and Training
How do you guard against client over-indebtedness in
a competitive market with no credit bureaus? Ensure
that collections agents don’t resort to intimidation?
Make loan terms clear to illiterate clients? While
some of the world’s most effective FIs have policies
and procedures to deal with such challenges, in
many parts of the world it can be difficult for an
institution to develop or find best practices.
Enter the Smart Campaign’s library of over 80 tools:
model policies, FI staff training materials, sample
loan contracts, and materials demonstrating how
to communicate with clients. The tools also include
resources for investors, such as due-diligence
guidance and sample loan covenants. The tools have
had significant impact, particularly in getting FIs
started on assessing their practices.
The Campaign staff developed many of the tools and
sourced others from FIs and organizations such as
Microfinance Transparency, MicroSave and CGAP. Many
of the tools are available in French, Spanish, Portuguese,
Russian and Arabic and can be found on Smart
Campaign websites hosted in each of those languages.
The Campaign has also sponsored training sessions,
conference presentations and webinars to ensure
that the entire microfinance industry is exposed to
the nuts and bolts of client protection. Since 2010, the
Campaign has presented at over 300 events worldwide.
The Campaign has trained personnel at FIs, regional
networks and associations, as well as consultants and
investors. The training events are a force multiplier,
equipping a small army of trainers and assessors to
get FIs engaged in improving practices.
Why Certification?
Certification requires an investment of time and
effort from an FI, though most are not left to shoulder
the entire burden, thanks to support from investors,
networks and others. The standard is rigorous: to
date, slightly more than two thirds of the FIs that
have sought certification have achieved it.
Given the many pressures under which an FI
operates, the Campaign has worked to clarify
why they should focus their attention on client
protection and undergo the rigorous certification
process. We make this case:
• Any financial institution’s credibility is undercut
when clients get into too much debt, are sold the
wrong services, fail to understand their payment
obligations, feel intimidated or disrespected by FI
personnel, or can’t get their complaints addressed.
• Failure to prevent these ills can lead to severe
backlashes, both for an institution and an entire
regional or national microfinance industry.
• Certification provides several competitive
advantages. Satisfied customers return, and
refer friends. Staff morale improves. The mark
of excellence generates prospective customers’
trust. Certification is a potent marketing
advantage that boosts an FI’s reputation and
attracts investors.
• Certification has a multiplier effect. When
industry leaders win certification it becomes a
competitive imperative. The drive to ensure client
protection leads to vital cooperation in matters
such as avoiding client overindebtedness and
setting uniform pricing transparency norms.
A Sample of Smart Tools
Smart Operations
The Smart Operations tool allows institutions to
embed the entirety of the Client Protection Principles
throughout their organization. Organized around the
11 most common operational areas (e.g., human
resources, internal audit, etc.), it provides a framework
for understanding and assigning responsibilities within
different departments.
A Guide to Client Protection Assessment
This guide describes the different client protection
assessment options available to financial institutions,
how an institution can benefit from an assessment,
walks the reader through the assessment processes, and
explains how to use the assessment once it is complete.
Resolving Client Complaints: The Example of Ujjivan
All financial service providers should have in place
a timely and responsive mechanism to resolve client
problems and improve their products and services.
This case study describes the successful implementation
of the principle on complaint resolution by the Indian
MFI Ujjivan Financial Services.
Model Legal Framework for
Financial Consumer Protection
This tool creates a legal framework for financial
consumer protection based on the Client
Protection Principles.
How to Develop an Institutional Code of Ethics
This tool guides users in creating a code of ethics,
a ‘living document’ focused on defining clear
standards of ethical behavior at the institutional
level. The tool teaches FIs how to establish a
code of ethics committee, how to draft and review
the code itself, and how to institutionalize it.
Smart Note: Transparent and
Responsible Pricing at Mi-Bospo
This case study, from Bosnian MFI Mi-Bospo,
offers guidelines in setting transparent and
responsible pricing that is both affordable for
the consumer and sustainable for the institution.
It explains how to communicate a product’s
true cost and its applicable terms and conditions
in a way that clients can understand.
The Client Protection Principles
Appropriate Product Design and Delivery
Providers will take adequate care to design products and
delivery channels in such a way that they do not cause
clients harm. Products and delivery channels will be
designed with client characteristics taken into account.
Prevention of Over-Indebtedness
Providers will take adequate care in all phases
of their credit process to determine that clients
have the capacity to repay without becoming
over-indebted.
Transparency
Providers will communicate clear, sufficient and timely
information in a manner and language clients can
understand so that clients can make informed decisions.
Responsible Pricing
Pricing, terms and conditions will be set in a way that is
affordable to clients while allowing financial institutions
to be sustainable.
Fair and Respectful Treatment of Clients
Providers will treat their clients fairly and
respectfully. They will not discriminate. Providers
will ensure adequate safeguards to detect and
correct corruption as well as aggressive or
abusive treatment.
Privacy of Client Data
The privacy of individual client data will be respected in
accordance with the laws and regulations of
individual jurisdictions and will only be used for
the purposes specified when the information is
collected, unless otherwise agreed with the client.
Mechanisms for Complaint Resolution
Providers will have in place timely and responsive
mechanisms for complaints and problem resolution for
their clients, and will use them to resolve
problems and to improve products and services.
Page Seven
The Client Voice
Certification Improvements
The Smart Campaign has recently conducted two
research projects, the ‘Client Voice’ surveys and
‘What Happens to Clients Who Default?’ Both
projects seek to illuminate risks, problems and
abuses that microfinance clients face.
While the Certification program has had a strong
beginning, it will need to be as straightforward as
possible if it is to become an industry hallmark. In
April 2015, having listened carefully to evaluation
results and industry feedback, we launched revisions
designed to reduce process barriers while maintaining
high standards. Enhancements and additions include:
The Client Voice project employs qualitative and
quantitative surveys to hear what clients think about
good and bad treatment by FIs, and to measure the
incidence of problems. The Campaign commissioned
Bankable Frontier Associates to conduct the research
in Pakistan, Benin, Peru and Georgia.
In Pakistan, while only five percent of microfinance
clients reported being dissatisfied, 10 percent
claimed to have experienced one or more problems.
Complaints centered mainly on MFI responses to
late repayment – in particular, that MFI staff had
little empathy for respondents who faced income
and health shocks.
The 1,700 clients surveyed in Benin reported a wider
array of problems, with 13 percent experiencing
some form of problematic treatment, from slow and
burdensome bureaucracy, to inflexible penalties
in response to late payment, to non-transparent
fees. An especially worrisome finding was that nine
percent of clients reported confusion and difficulties
over the withdrawal of their compulsory savings.
The research on treatment of clients during default
examined market conditions and FI collections
practices in Peru, India and Uganda. Researchers
found that the local environment plays a decisive
role in how microfinance clients are treated. Humane
collections are more likely when a country has good
regulators, a functioning credit bureau, and a culture
that upholds fulfillment of debt obligations. When
these features are weak, lenders are pushed into
harsh practices. In Uganda, which lacks both effective
credit reporting and secure identification, researchers
found a “Hobbesian” environment in which lenders,
fearful that defaulting clients will disappear, rush
to harsh measures at the first hint of trouble.
Both projects highlighted issues for industry
discussion and confirmed the need to work at
a market level to create the building blocks for
humane treatment.
• Streamlined certification. To reduce the time to
certification, licensed certifiers may recommend
“streamlined certification” to FIs that pass the vast
majority of the indicators, and whose gaps are
surmountable. In this case, the FI will receive the
certification immediately, with the understanding
that the organization will come into full
compliance within four months. If the FI does
not comply fully within the agreed time frame,
the certification will be withdrawn.
• Extension of certification validity. Originally set
at two years, validity will now last for four years,
but an on-site visit is still required for check-in
at the two-year midpoint.
• Appeals and complaints. A system is now in place to
allow for the resolution of grievances that may arise
during the certification process and to serve as a
mechanism for general feedback from the public.
The improvements that are being implemented in the
latter half of 2015 are, if anything, even more significant.
• Accreditation of certifiers. To make certification
more accessible globally and to maintain
the quality of certifications, the Campaign is
developing a new accreditation system to license
existing and new certifiers. The Campaign expects
newly accredited certifiers to be on-stream by the
end of 2015.
• Standards 2.0 will revise the client protection
standards to remove duplication and ambiguity.
The revision will also further develop standards
for savings and insurance and introduce standards
for digital financial services. Revised standards
will be released by December 2015 and will be
applied in certifications as of June 2016. The
original standards represented the output of
several years of industry collaboration and input,
and the revisions continue in that tradition.
Page Eight
Model Legal Framework
Looking Ahead
As regulators around the world work to install
stronger client protection regimes, the Smart
Campaign is pleased to announce an important
new tool, the Consumer Protection Model Legal
Framework and Commentary. The Model Legal
Framework creates a regulatory template for
financial consumer protection based on the
Client Protection Principles.
In the Campaign’s next phase, extending through
2018, we will continue to advance the goal of
embedding the Client Protection Principles into
the financial inclusion sector. In light of progress
so far, as well as findings from our client research
and the two external evaluations of the Campaign,
we have begun to implement a number of strategic
shifts in our activities.
The Model Legal Framework was developed by a
team of experienced model legislation developers
from the law firm DLA Piper/New Perimeter. The
team drew on a broad survey of experts, relevant
scholarship, and existing laws and regulations
from countries across the globe. Sponsored by the
Microfinance CEO Working Group (MCWG), the
Model Legal Framework project was managed by
Accion on behalf of the MCWG.
1. Broadening to financial inclusion while remaining
active in microfinance. As micro-insurance, savings,
electronic payments and other financial services
targeted at the bottom of the pyramid gain
traction, the imperative to extend client protection
standards into these areas has become pressing.
The Smart Campaign is established enough that
other industry segments look to it when they work
on their groups’ client protection practices. We
have already begun to research issues in digital
financial services and microinsurance and will
incorporate some of the findings in the next round
of standards.
The Model Legal Framework is an excellent focal
point for dialogue among regulators and providers.
It can serve as:
• A template for developing legislation or regulation.
The Model Legal Framework forms a complete
legal regime for client protection in line with the
Client Protection Principles. It can also be adopted
in parts, to fit local precedents and circumstances.
• A tool to assess a given jurisdiction’s client
protection regulatory regime. By setting the
Model Law side-by-side with a jurisdiction’s
current legislation and regulation, policy makers
can easily assess how that jurisdiction’s legal
framework compares with a model approach
based on the Client Protection Principles.
• A resource for the development of codes of
conduct and guidelines, for any group or industry
association. While the document is in the format
of legislation, the systems and approaches
described in the Model Legal Framework may
provide guidance on effective ways to promote
client protection through industry codes, and
can provide a focal point for dialogue between
industry and regulators.
The Model Legal Framework is designed to cover
all financial service providers, including banks,
credit unions, microfinance institutions, money
lenders, and digital financial service providers.
2. Heightened effort in standard-setting and
certification. A strong message from the evaluations
was that stakeholders see standard-setting as a
core function of the Campaign. We will continue
the standard-setting function, extending our efforts
on this front to embrace new products and delivery
channels, e.g. in digital financial services. As for
certification, we are working to introduce updated
standards starting in 2016, streamlining the process.
The Campaign will continue to conduct research
to underpin standard-setting, such as work on
appropriate product design and delivery and pricing
that is under way as of mid-2015.
3. Greater emphasis on market-level activities.
It is hard for individual providers to instill best
practices if their competitors don’t. Findings from
our client voice and default research highlight the
importance of market-level forces in setting the rules
and incentives around client protection practices.
There are multiple opportunities to help shift the
market context. We are working with the two Indian
Self-Regulatory Organizations (SROs), MFIN and
Sa-Dhan, on their client protection responsibilities,
for instance improving membership grievance
redressal mechanisms; with technical assistance
Page Nine
Client Portraits:
The clients of
Smart Certified
MFIs around
the world
Market Profile:
India - A Quarter of
all Clients Covered
MFI Profile:
First Certified Institution in
Africa: Bayport, Botswana
The Smart Campaign has found significant
traction in India, the world’s largest microfinance
market. The Campaign has worked directly with
dozens of FIs, with rating agency MCRIL, and with
microfinance associations MFIN and Sa-Dhan,
which have been designated self-regulatory
organizations by the Reserve Bank of India.
Ten market leaders (Arohan, Cashpor, Equitas,
Grameen Koota, Janalakshmi, SKS, Sonata,
Swadhaar, Ujjivan and Utkarsh), which serve more
than 25 percent of the country’s client base, have
achieved certification.
In March of this year, Bayport Financial
Services Botswana, a financial service provider
headquartered in Gaborone, Botswana, became
the first Client Protection Certified institution in
Africa. Bayport’s success was noteworthy both for
the bank’s own persistence and as an illustration
of how deeply intertwined an FI’s practices are
with local conditions. To improve client protection,
Bayport had to overcome contextual hurdles, and
its success improved the country environment.
Smart Campaign engagement in India gained
urgency in the wake of the Andhra Pradesh overindebtedness crisis in 2010, when the Campaign
initiated a two-year capacity-building program.
From 2011-2013 the Campaign conducted 10
client-protection training sessions, engaging 94
MFIs, as well as MFIN and Sa-Dhan. Assessments
were also a key building block: by the end of
2013, 19 major Indian FIs had undergone them.
The ground was thus well prepared when the
certification program kicked off in 2013. Five
Indian FIs were among the first institutions
certified globally. Certification is a key element
in the post-crisis reconstitution of the country’s
microfinance market.
After coming up short in its initial certification
mission, Bayport treated its missing indicators
as a checklist and took a measured, step-bystep approach to make comprehensive and
sustainable changes. For example, Bayport
adjusted its portfolio quality targets for sales,
revamped its agents’ commission structure,
and updated consumer fact sheets and
customer service procedures.
In the process, Bayport took on a country-wide
consumer-protection challenge – aggressive sales
practices created by the common practice of
paying agents primarily on commission. It used
its success to advocate for regulatory changes to
reduce this threat to over-indebtedness. The fact
that Bayport is a full-service financial institution
adds to the impact of its market-leading clientprotection efforts.
Page Eleven
providers in Cambodia to promote certification
of a critical market share of MFIs; and with the
Pakistan Microfinance Network to respond to
the findings of the client voice research. The
Campaign will shift its modus operandi to work
increasingly at this country level.
4. Revised approaches to building awareness and
commitment. Now that the Campaign is well-known
throughout the global inclusive finance community,
we will shift the focus of our advocacy activities
from general awareness-raising to calls for real
commitment backed by action. This will be supported
by research and evidence on the case for client
protection from both provider and client viewpoints.
Market Profile:
Partner-led Progress
in Kyrgyzstan
The Smart Campaign benefits from effective
partnerships in Kyrgyzstan. Three of the
country’s largest MFIs, serving more than 50
percent of microfinance clients - Kompanion,
FINCA Kyrgyzstan and Bai Tushum Bank have achieved certification, thanks to the
encouragement of IFC, Deutsche Bank and
FINCA. Partners such as these are playing a
similar role in countries such as Cambodia,
where Agence Française de Développement
(AFD) and the Cambodia Microfinance
Association (CMA) have partnered to enable
the market’s largest MFIs to become certified;
and Pakistan, where the Pakistan Microfinance
Network (PMN) has commissioned assessments
for over 20 of its members. Leveraged
partnerships are integral to expanding the
Campaign’s reach and providing incentives
to providers to improve.
5. Turn most FI-level support over to others, while
maintaining a body of resources and know-how.
The Campaign staff will reduce its direct one-on-one
engagement with FIs in the confidence that other
organizations and specialists, including many trained
by the Campaign, can continue to provide this direct
support. This shift is essential to ensure the global
spread of ground-level work. The Campaign will
continue to be a resource hub for this effort, through
the tools and training library and a limited schedule
of trainings of trainers and assessors.
Steering
Committee
Page Twelve
FELIPE ARANGO
Director
BSD Consulting
United States
DAVID BAGUMA
Executive Director
Association of Microfinance
Institutions of Uganda (AMFIU)
ESSMA BEN HAMIDA
Executive Director
Enda Inter-Arabe
Tunisia
ABOUBACRINE DATE
CEO
Bank for the Microfinance
Institutions in West Africa
ROSAMUND GRADY
Senior Financial Sector Specialist
Financial and Markets
Global Practice
World Bank
United States
ANNE HASTINGS
Manager
Microfinance CEO Working Group
United States
CARLOS LOPEZ-MOCTEZUMA
Global Director of
Financial Inclusion
BBVA
Mexico
ASAD MAHMOOD
Executive Director
The SEEP Network
United States
Vice President
Global Social Enterprise and
Financial Innovation
FINCA International
United States
DAVE GRACE
KATE MCKEE
SHARON D’ONOFRIO
Dave Grace & Associates
Independent Cooperative
Consultant
United States
Senior Advisor
CGAP
United States
TOMAS MILLER
Chief
Access to Finance Unit
IADB-Fomin
United States
SYED MOHSIN-AHMED
CEO
Pakistan Microfinance Network
BETH PORTER
Policy Advisor for Financial
Inclusion
United Nations Capital
Development Fund
United States
LARRY REED
Director
Microcredit Summit Campaign
United States
ELISABETH RHYNE
VIPIN SHARMA
Managing Director
Access Development and
Access Alliance
India
BEN SIMMES
Chair
Dutch Microfinance Platform
Netherlands
JAMI SOLLI
Senior Consultant, Financial
Services Consumer Protection
Consumers International
United Kingdom
Managing Director
Center for Financial Inclusion
at Accion
United States
SAHAR TIEBY
PIA ROMAN
MARIELA ZALDÍVAR
Head, Inclusive Finance Advocacy
Central Bank of the Philippines
RUPERT SCOFIELD
President & CEO
Finca International
United States
Executive Director
Sanabel
Jordan
Deputy of Market Conduct
Supervision & Financial Inclusion
Superintendence of Banks
Peru
Acknowledgements
The Smart Campaign gratefully acknowledges the financial support of Agence Française de Développement,
Asia Development Bank, Credit Suisse, Deutsche Bank, the Ford Foundation, the Inter-American Development
Bank’s Multilateral Investment Fund, the International Finance Corporation, The MasterCard Foundation,
the Small Industries Development Bank of India (SIDBI), USAID and Accion, and thanks the many partners
who enable and facilitate its work:
• Access/Assist, India
• Association of Microfinance Institutions in Rwanda
• Association of Microfinance Institutions of Uganda
• Association Professionnelle des Systèmes Financiers
Décentralisés du Côte d’Ivoire
• Azerbaijan Microfinance Association
• Bangko Sentral ng Pilipinas, Philippines (BSP)
• Bankable Frontier Associates
• Cambodia Microfinance Association
• CDF Network
• Centre for Microfinance Nepal
• CERISE
• Consortium Alafia and National Advisory Council
• Consultative Group to Assist the Poor
• COPEME, Peru
• EDA Rural Systems, India
• Emprender, Colombia
• Entrepreneurs du Monde
• Financial Inclusion Equity Council
• Ghana Microfinance Institutions Network
• Good Return
• Lanka Microfinance Practitioners’ Association
• Laos Network
• MAIN Network
• M-CRIL
• Microfinance Center for Eastern Europe and
Central Asia
• Microfinance CEO Working Group
• Microfinance Council of the Philippines
• Microfinance Information Exchange (MIX)
• Microfinance Institutions Network, India (MFIN)
• MicroFinanza Rating
• MicroRate
• Pakistan Microfinance Association
• Planet Rating
• Sa-Dahn , India
• SEEP
• Smart Campaign Client Voice Working Group
• Smart Campaign Evolution of Standards
Working Group
• Social Performance Task Force
• Superintendencia de Banca, Seguros y AFP, Peru
Keeping
Clients First
in Inclusive
Finance
Progress Report
July 2015
The Smart Campaign
c/o The Center for
Financial Inclusion at Accion
1101 15th St. NW, Suite 400
Washington, DC 20005 USA
Tel: (202) 393-5113
Fax: (202) 393-5115
smartcampaign.org
Clients First
in Inclusive
Finance
Progress Report
July 2015
Momentum
“Momentum to improve client protection is accelerating,
with scores of FIs across the globe improving their practices
and being recognized for it through certification.”
ISABELLE BARRÈS
Director, Smart Campaign
Our Mission
The Smart Campaign is a global effort to unite leaders
in financial inclusion around a common goal:
to keep clients as the driving force of the industry.
Protecting clients is not only the right thing to do;
it’s the smart thing to do. When financial institutions
implement the Campaign’s Client Protection Principles
into their operations, they build strong, lasting
relationships with clients, increase client retention,
and reduce financial risk. Similarly, by incorporating
client protection principles into their investment
criteria and due diligence, investors can build a
healthier, more clientâfocused industry that will foster
a stronger portfolio and ensure healthy returns.
To help the microfinance industry remain both socially
focused and financially sound, the Smart Campaign
is working with microfinance leaders from around the
world to provide financial institutions with the tools and
resources they need to deliver transparent, respectful
and prudent financial services to all clients. By putting
clients first and collaborating together, we can strengthen
the microfinance industry and elevate it as a model of
responsible banking.
Letter from
The Campaign
Director
Page One
It is in everyone’s interest to ensure that when low-income people seek formal financial services,
they can be confident of receiving fair and appropriate treatment. Around the world today, this
confidence is often lacking. The Smart Campaign works from a provider perspective to embed
the Client Protection Principles throughout the microfinance industry and, increasingly, into the
broader financial inclusion sector. The campaign’s standards of care address such critical issues
as prevention of over-indebtedness, transparency, privacy, respectful treatment, and means for
resolving problems.
The signature program of the Campaign is Smart Certification, launched in 2013. The program
publicly recognizes financial institutions (FIs) that meet all 30 of its standards of care. We envision
certification as a signal to investors, regulators and, ultimately, clients that an FI upholds the Client
Protection Principles. To date, 37 institutions – including some of the world’s largest and most
influential microfinance providers – have achieved certification through a third-party evaluation
of their policies and procedures. Together, those FIs serve more than 19 million clients, or nearly
10 percent of the world’s microfinance clients. In India, Smart-Certified FIs account for 25 percent
of the nation’s microfinance customers. Increasingly, funders look for an FI’s commitment to
Smart Certification when deciding where to invest.
In 2014 the Campaign commissioned two external evaluations, one on its overall strategy (conducted
by the Aspen Planning and Evaluation Program) and one on the certification program (by BSD
Consulting). We were pleased that both evaluations affirmed the widespread industry awareness
and acceptance of the Client Protection Principles, as well as respect for and use of the Campaign
as a resource. Both evaluations made recommendations that we are working to incorporate.
Recommendations on streamlining certification have already resulted in changes announced in April
2015, with further improvements to be released in December.
As we move into a new strategic phase covering 2016-2018, the Campaign is adopting two
significant new directions, both supported by evaluation results. First, the Campaign will expand
to address the broader financial inclusion sector, including digital financial services. Second, it
will work more specifically to improve the market-level environments that strongly influence the
behavior of individual providers. As always, the collaboration of allied organizations – CGAP, the
Social Performance Task Force and many others – is key in successfully achieving these goals.
The journey continues to be a dynamic and rewarding one, and we are moving forward together
for the benefit of low-income clients across the globe.
Isabelle Barrès,
Campaign Director
The Campaign
in Review
Gaining Momentum
As the world increasingly embraces financial
inclusion, two recent research projects undertaken
by the Smart Campaign, ‘Client Voices’ and ‘What
Happens to Microfinance Clients Who Default’,
remind us that if financial inclusion is to fulfill its
promise, client protection must be front and center.
The Client Voice research details, from clients
themselves, the various ways that the microfinance
experience can turn stressful and destructive. The
Default project makes it clear that in countries with
weak regulation, lack of credit
reporting infrastructure and low
client financial capacity, risks to
clients increase notably. Our mission
is to build an ecosystem that
minimizes client risk and champions
good client protection practices,
country by country.
Client Protection Certification
is the tip of a long spear. While
the Campaign aims ultimately
to establish certification as a
competitive necessity for FIs, it is
also the fruit of an extended effort
in improving FI practices that has
reached different stages in different
global regions, as well as among
the thousands of FIs worldwide.
Before launching its certification
program, the Campaign and
its allies had to define client
protection; win recognition
and buy-in across the global
industry; create tools and deploy trainers to make
implementation feasible; build processes of internal
and third-party assessment for FIs; and work with
donors, investors and regulators to create incentives
for sustained client protection efforts. All this laid
the groundwork for certification. All of these efforts
are ongoing.
We are poised to do more to leverage the work of
partners. That means engaging more certifiers,
assessors and trainers; working closely with the most
capable microfinance associations and networks;
coordinating efforts with other global organizations
focused on social performance and client protection;
and encouraging investors and donors to incorporate
the Client Protection Principles in their due diligence.
In coming years, the Campaign will focus increasingly
on standard-setting as our partners build capacity on
the ground. At the same time, as described in more
detail below, we are working to extend client protection
efforts into the broader arena of financial inclusion.
A New Climate for Consumer Protection
In the microfinance movement’s first three decades,
industry leaders were focused almost entirely on
building the capacity to make credit
available to the unbanked. Good
intentions and good works were
largely assumed to flow naturally
from the effort to extend credit to
the poor. By 2008, however, enough
concern about quality of services
prompted industry leaders from
around the world to define what
became the Client Protection
Principles (CPPs). While there was
support for the CPPs, there was a
genuine lack of awareness in the
broader microfinance industry, as
well as hints of skepticism that there
was, in fact, a need for improvement.
Today, receptivity to financial
consumer protection has
improved markedly. Increasingly,
practitioners recognize that client
protection is good for clients, good
for business and good for the
industry. The Campaign’s efforts are
supported and its effects multiplied
by a host of industry groups, including the national
associations that define local codes of conduct and
the international development funds, investors
and donors who design covenants, monitor overindebtedness, and create measurement standards,
often directly incorporating the CPPs. Allies from the
world of finance and development include or have
included Agence Française de Développement, Asia
Development Bank, Credit Suisse, Deutsche Bank,
the Ford Foundation, the Multilateral Investment
Fund of the Inter-American Development Bank, the
International Finance Corporation, The MasterCard
Foundation, SIDBI, USAID, and others.
Campaign
by the Numbers
Page Three
4,496
303
Total Endorsements of the
Smart Campaign and the
Client Protection Principles
(as of June 2015)
Combined Training Events
and Assessments
Conducted Since
Campaign’s Founding
2,193
Individual
Endorsements
184
Network and
Association
Endorsements
184
Investor and Donor
Endorsements
1,584
Microfinance
Institution
Endorsements
Page Four
High-profile crises – in Bosnia, India, Morocco,
Nicaragua and elsewhere – drove home the
importance of strong efforts to avoid overindebtedness and the deep financial implications
of poor client treatment. Regulators, who had
previously focused their energy on prudential
supervision, are now more active in the marketconduct space for financial inclusion. Leaders such
as Peru’s Superintendencia de Banca, Seguros y AFP
(SBS), the Bangko Sentral ng Pilipipinas (BSP) and
the Alliance for Financial Inclusion’s Consumer
Empowerment and Market Conduct Working Group
are creating environments where incentives for client
protection and the Smart Campaign’s work resonate.
The client protection movement is even beginning to
spread to new frontiers of financial inclusion. In late
2014, the Groupe Speciale Mobile Association (GSMA)
launched a code of conduct for digital financial
services that has been endorsed by leading mobile
money providers. The Smart Campaign stands ready
to share the benefit of our long experience in these
emerging efforts.
Tools and Training
How do you guard against client over-indebtedness in
a competitive market with no credit bureaus? Ensure
that collections agents don’t resort to intimidation?
Make loan terms clear to illiterate clients? While
some of the world’s most effective FIs have policies
and procedures to deal with such challenges, in
many parts of the world it can be difficult for an
institution to develop or find best practices.
Enter the Smart Campaign’s library of over 80 tools:
model policies, FI staff training materials, sample
loan contracts, and materials demonstrating how
to communicate with clients. The tools also include
resources for investors, such as due-diligence
guidance and sample loan covenants. The tools have
had significant impact, particularly in getting FIs
started on assessing their practices.
The Campaign staff developed many of the tools and
sourced others from FIs and organizations such as
Microfinance Transparency, MicroSave and CGAP. Many
of the tools are available in French, Spanish, Portuguese,
Russian and Arabic and can be found on Smart
Campaign websites hosted in each of those languages.
The Campaign has also sponsored training sessions,
conference presentations and webinars to ensure
that the entire microfinance industry is exposed to
the nuts and bolts of client protection. Since 2010, the
Campaign has presented at over 300 events worldwide.
The Campaign has trained personnel at FIs, regional
networks and associations, as well as consultants and
investors. The training events are a force multiplier,
equipping a small army of trainers and assessors to
get FIs engaged in improving practices.
Why Certification?
Certification requires an investment of time and
effort from an FI, though most are not left to shoulder
the entire burden, thanks to support from investors,
networks and others. The standard is rigorous: to
date, slightly more than two thirds of the FIs that
have sought certification have achieved it.
Given the many pressures under which an FI
operates, the Campaign has worked to clarify
why they should focus their attention on client
protection and undergo the rigorous certification
process. We make this case:
• Any financial institution’s credibility is undercut
when clients get into too much debt, are sold the
wrong services, fail to understand their payment
obligations, feel intimidated or disrespected by FI
personnel, or can’t get their complaints addressed.
• Failure to prevent these ills can lead to severe
backlashes, both for an institution and an entire
regional or national microfinance industry.
• Certification provides several competitive
advantages. Satisfied customers return, and
refer friends. Staff morale improves. The mark
of excellence generates prospective customers’
trust. Certification is a potent marketing
advantage that boosts an FI’s reputation and
attracts investors.
• Certification has a multiplier effect. When
industry leaders win certification it becomes a
competitive imperative. The drive to ensure client
protection leads to vital cooperation in matters
such as avoiding client overindebtedness and
setting uniform pricing transparency norms.
A Sample of Smart Tools
Smart Operations
The Smart Operations tool allows institutions to
embed the entirety of the Client Protection Principles
throughout their organization. Organized around the
11 most common operational areas (e.g., human
resources, internal audit, etc.), it provides a framework
for understanding and assigning responsibilities within
different departments.
A Guide to Client Protection Assessment
This guide describes the different client protection
assessment options available to financial institutions,
how an institution can benefit from an assessment,
walks the reader through the assessment processes, and
explains how to use the assessment once it is complete.
Resolving Client Complaints: The Example of Ujjivan
All financial service providers should have in place
a timely and responsive mechanism to resolve client
problems and improve their products and services.
This case study describes the successful implementation
of the principle on complaint resolution by the Indian
MFI Ujjivan Financial Services.
Model Legal Framework for
Financial Consumer Protection
This tool creates a legal framework for financial
consumer protection based on the Client
Protection Principles.
How to Develop an Institutional Code of Ethics
This tool guides users in creating a code of ethics,
a ‘living document’ focused on defining clear
standards of ethical behavior at the institutional
level. The tool teaches FIs how to establish a
code of ethics committee, how to draft and review
the code itself, and how to institutionalize it.
Smart Note: Transparent and
Responsible Pricing at Mi-Bospo
This case study, from Bosnian MFI Mi-Bospo,
offers guidelines in setting transparent and
responsible pricing that is both affordable for
the consumer and sustainable for the institution.
It explains how to communicate a product’s
true cost and its applicable terms and conditions
in a way that clients can understand.
The Client Protection Principles
Appropriate Product Design and Delivery
Providers will take adequate care to design products and
delivery channels in such a way that they do not cause
clients harm. Products and delivery channels will be
designed with client characteristics taken into account.
Prevention of Over-Indebtedness
Providers will take adequate care in all phases
of their credit process to determine that clients
have the capacity to repay without becoming
over-indebted.
Transparency
Providers will communicate clear, sufficient and timely
information in a manner and language clients can
understand so that clients can make informed decisions.
Responsible Pricing
Pricing, terms and conditions will be set in a way that is
affordable to clients while allowing financial institutions
to be sustainable.
Fair and Respectful Treatment of Clients
Providers will treat their clients fairly and
respectfully. They will not discriminate. Providers
will ensure adequate safeguards to detect and
correct corruption as well as aggressive or
abusive treatment.
Privacy of Client Data
The privacy of individual client data will be respected in
accordance with the laws and regulations of
individual jurisdictions and will only be used for
the purposes specified when the information is
collected, unless otherwise agreed with the client.
Mechanisms for Complaint Resolution
Providers will have in place timely and responsive
mechanisms for complaints and problem resolution for
their clients, and will use them to resolve
problems and to improve products and services.
Page Seven
The Client Voice
Certification Improvements
The Smart Campaign has recently conducted two
research projects, the ‘Client Voice’ surveys and
‘What Happens to Clients Who Default?’ Both
projects seek to illuminate risks, problems and
abuses that microfinance clients face.
While the Certification program has had a strong
beginning, it will need to be as straightforward as
possible if it is to become an industry hallmark. In
April 2015, having listened carefully to evaluation
results and industry feedback, we launched revisions
designed to reduce process barriers while maintaining
high standards. Enhancements and additions include:
The Client Voice project employs qualitative and
quantitative surveys to hear what clients think about
good and bad treatment by FIs, and to measure the
incidence of problems. The Campaign commissioned
Bankable Frontier Associates to conduct the research
in Pakistan, Benin, Peru and Georgia.
In Pakistan, while only five percent of microfinance
clients reported being dissatisfied, 10 percent
claimed to have experienced one or more problems.
Complaints centered mainly on MFI responses to
late repayment – in particular, that MFI staff had
little empathy for respondents who faced income
and health shocks.
The 1,700 clients surveyed in Benin reported a wider
array of problems, with 13 percent experiencing
some form of problematic treatment, from slow and
burdensome bureaucracy, to inflexible penalties
in response to late payment, to non-transparent
fees. An especially worrisome finding was that nine
percent of clients reported confusion and difficulties
over the withdrawal of their compulsory savings.
The research on treatment of clients during default
examined market conditions and FI collections
practices in Peru, India and Uganda. Researchers
found that the local environment plays a decisive
role in how microfinance clients are treated. Humane
collections are more likely when a country has good
regulators, a functioning credit bureau, and a culture
that upholds fulfillment of debt obligations. When
these features are weak, lenders are pushed into
harsh practices. In Uganda, which lacks both effective
credit reporting and secure identification, researchers
found a “Hobbesian” environment in which lenders,
fearful that defaulting clients will disappear, rush
to harsh measures at the first hint of trouble.
Both projects highlighted issues for industry
discussion and confirmed the need to work at
a market level to create the building blocks for
humane treatment.
• Streamlined certification. To reduce the time to
certification, licensed certifiers may recommend
“streamlined certification” to FIs that pass the vast
majority of the indicators, and whose gaps are
surmountable. In this case, the FI will receive the
certification immediately, with the understanding
that the organization will come into full
compliance within four months. If the FI does
not comply fully within the agreed time frame,
the certification will be withdrawn.
• Extension of certification validity. Originally set
at two years, validity will now last for four years,
but an on-site visit is still required for check-in
at the two-year midpoint.
• Appeals and complaints. A system is now in place to
allow for the resolution of grievances that may arise
during the certification process and to serve as a
mechanism for general feedback from the public.
The improvements that are being implemented in the
latter half of 2015 are, if anything, even more significant.
• Accreditation of certifiers. To make certification
more accessible globally and to maintain
the quality of certifications, the Campaign is
developing a new accreditation system to license
existing and new certifiers. The Campaign expects
newly accredited certifiers to be on-stream by the
end of 2015.
• Standards 2.0 will revise the client protection
standards to remove duplication and ambiguity.
The revision will also further develop standards
for savings and insurance and introduce standards
for digital financial services. Revised standards
will be released by December 2015 and will be
applied in certifications as of June 2016. The
original standards represented the output of
several years of industry collaboration and input,
and the revisions continue in that tradition.
Page Eight
Model Legal Framework
Looking Ahead
As regulators around the world work to install
stronger client protection regimes, the Smart
Campaign is pleased to announce an important
new tool, the Consumer Protection Model Legal
Framework and Commentary. The Model Legal
Framework creates a regulatory template for
financial consumer protection based on the
Client Protection Principles.
In the Campaign’s next phase, extending through
2018, we will continue to advance the goal of
embedding the Client Protection Principles into
the financial inclusion sector. In light of progress
so far, as well as findings from our client research
and the two external evaluations of the Campaign,
we have begun to implement a number of strategic
shifts in our activities.
The Model Legal Framework was developed by a
team of experienced model legislation developers
from the law firm DLA Piper/New Perimeter. The
team drew on a broad survey of experts, relevant
scholarship, and existing laws and regulations
from countries across the globe. Sponsored by the
Microfinance CEO Working Group (MCWG), the
Model Legal Framework project was managed by
Accion on behalf of the MCWG.
1. Broadening to financial inclusion while remaining
active in microfinance. As micro-insurance, savings,
electronic payments and other financial services
targeted at the bottom of the pyramid gain
traction, the imperative to extend client protection
standards into these areas has become pressing.
The Smart Campaign is established enough that
other industry segments look to it when they work
on their groups’ client protection practices. We
have already begun to research issues in digital
financial services and microinsurance and will
incorporate some of the findings in the next round
of standards.
The Model Legal Framework is an excellent focal
point for dialogue among regulators and providers.
It can serve as:
• A template for developing legislation or regulation.
The Model Legal Framework forms a complete
legal regime for client protection in line with the
Client Protection Principles. It can also be adopted
in parts, to fit local precedents and circumstances.
• A tool to assess a given jurisdiction’s client
protection regulatory regime. By setting the
Model Law side-by-side with a jurisdiction’s
current legislation and regulation, policy makers
can easily assess how that jurisdiction’s legal
framework compares with a model approach
based on the Client Protection Principles.
• A resource for the development of codes of
conduct and guidelines, for any group or industry
association. While the document is in the format
of legislation, the systems and approaches
described in the Model Legal Framework may
provide guidance on effective ways to promote
client protection through industry codes, and
can provide a focal point for dialogue between
industry and regulators.
The Model Legal Framework is designed to cover
all financial service providers, including banks,
credit unions, microfinance institutions, money
lenders, and digital financial service providers.
2. Heightened effort in standard-setting and
certification. A strong message from the evaluations
was that stakeholders see standard-setting as a
core function of the Campaign. We will continue
the standard-setting function, extending our efforts
on this front to embrace new products and delivery
channels, e.g. in digital financial services. As for
certification, we are working to introduce updated
standards starting in 2016, streamlining the process.
The Campaign will continue to conduct research
to underpin standard-setting, such as work on
appropriate product design and delivery and pricing
that is under way as of mid-2015.
3. Greater emphasis on market-level activities.
It is hard for individual providers to instill best
practices if their competitors don’t. Findings from
our client voice and default research highlight the
importance of market-level forces in setting the rules
and incentives around client protection practices.
There are multiple opportunities to help shift the
market context. We are working with the two Indian
Self-Regulatory Organizations (SROs), MFIN and
Sa-Dhan, on their client protection responsibilities,
for instance improving membership grievance
redressal mechanisms; with technical assistance
Page Nine
Client Portraits:
The clients of
Smart Certified
MFIs around
the world
Market Profile:
India - A Quarter of
all Clients Covered
MFI Profile:
First Certified Institution in
Africa: Bayport, Botswana
The Smart Campaign has found significant
traction in India, the world’s largest microfinance
market. The Campaign has worked directly with
dozens of FIs, with rating agency MCRIL, and with
microfinance associations MFIN and Sa-Dhan,
which have been designated self-regulatory
organizations by the Reserve Bank of India.
Ten market leaders (Arohan, Cashpor, Equitas,
Grameen Koota, Janalakshmi, SKS, Sonata,
Swadhaar, Ujjivan and Utkarsh), which serve more
than 25 percent of the country’s client base, have
achieved certification.
In March of this year, Bayport Financial
Services Botswana, a financial service provider
headquartered in Gaborone, Botswana, became
the first Client Protection Certified institution in
Africa. Bayport’s success was noteworthy both for
the bank’s own persistence and as an illustration
of how deeply intertwined an FI’s practices are
with local conditions. To improve client protection,
Bayport had to overcome contextual hurdles, and
its success improved the country environment.
Smart Campaign engagement in India gained
urgency in the wake of the Andhra Pradesh overindebtedness crisis in 2010, when the Campaign
initiated a two-year capacity-building program.
From 2011-2013 the Campaign conducted 10
client-protection training sessions, engaging 94
MFIs, as well as MFIN and Sa-Dhan. Assessments
were also a key building block: by the end of
2013, 19 major Indian FIs had undergone them.
The ground was thus well prepared when the
certification program kicked off in 2013. Five
Indian FIs were among the first institutions
certified globally. Certification is a key element
in the post-crisis reconstitution of the country’s
microfinance market.
After coming up short in its initial certification
mission, Bayport treated its missing indicators
as a checklist and took a measured, step-bystep approach to make comprehensive and
sustainable changes. For example, Bayport
adjusted its portfolio quality targets for sales,
revamped its agents’ commission structure,
and updated consumer fact sheets and
customer service procedures.
In the process, Bayport took on a country-wide
consumer-protection challenge – aggressive sales
practices created by the common practice of
paying agents primarily on commission. It used
its success to advocate for regulatory changes to
reduce this threat to over-indebtedness. The fact
that Bayport is a full-service financial institution
adds to the impact of its market-leading clientprotection efforts.
Page Eleven
providers in Cambodia to promote certification
of a critical market share of MFIs; and with the
Pakistan Microfinance Network to respond to
the findings of the client voice research. The
Campaign will shift its modus operandi to work
increasingly at this country level.
4. Revised approaches to building awareness and
commitment. Now that the Campaign is well-known
throughout the global inclusive finance community,
we will shift the focus of our advocacy activities
from general awareness-raising to calls for real
commitment backed by action. This will be supported
by research and evidence on the case for client
protection from both provider and client viewpoints.
Market Profile:
Partner-led Progress
in Kyrgyzstan
The Smart Campaign benefits from effective
partnerships in Kyrgyzstan. Three of the
country’s largest MFIs, serving more than 50
percent of microfinance clients - Kompanion,
FINCA Kyrgyzstan and Bai Tushum Bank have achieved certification, thanks to the
encouragement of IFC, Deutsche Bank and
FINCA. Partners such as these are playing a
similar role in countries such as Cambodia,
where Agence Française de Développement
(AFD) and the Cambodia Microfinance
Association (CMA) have partnered to enable
the market’s largest MFIs to become certified;
and Pakistan, where the Pakistan Microfinance
Network (PMN) has commissioned assessments
for over 20 of its members. Leveraged
partnerships are integral to expanding the
Campaign’s reach and providing incentives
to providers to improve.
5. Turn most FI-level support over to others, while
maintaining a body of resources and know-how.
The Campaign staff will reduce its direct one-on-one
engagement with FIs in the confidence that other
organizations and specialists, including many trained
by the Campaign, can continue to provide this direct
support. This shift is essential to ensure the global
spread of ground-level work. The Campaign will
continue to be a resource hub for this effort, through
the tools and training library and a limited schedule
of trainings of trainers and assessors.
Steering
Committee
Page Twelve
FELIPE ARANGO
Director
BSD Consulting
United States
DAVID BAGUMA
Executive Director
Association of Microfinance
Institutions of Uganda (AMFIU)
ESSMA BEN HAMIDA
Executive Director
Enda Inter-Arabe
Tunisia
ABOUBACRINE DATE
CEO
Bank for the Microfinance
Institutions in West Africa
ROSAMUND GRADY
Senior Financial Sector Specialist
Financial and Markets
Global Practice
World Bank
United States
ANNE HASTINGS
Manager
Microfinance CEO Working Group
United States
CARLOS LOPEZ-MOCTEZUMA
Global Director of
Financial Inclusion
BBVA
Mexico
ASAD MAHMOOD
Executive Director
The SEEP Network
United States
Vice President
Global Social Enterprise and
Financial Innovation
FINCA International
United States
DAVE GRACE
KATE MCKEE
SHARON D’ONOFRIO
Dave Grace & Associates
Independent Cooperative
Consultant
United States
Senior Advisor
CGAP
United States
TOMAS MILLER
Chief
Access to Finance Unit
IADB-Fomin
United States
SYED MOHSIN-AHMED
CEO
Pakistan Microfinance Network
BETH PORTER
Policy Advisor for Financial
Inclusion
United Nations Capital
Development Fund
United States
LARRY REED
Director
Microcredit Summit Campaign
United States
ELISABETH RHYNE
VIPIN SHARMA
Managing Director
Access Development and
Access Alliance
India
BEN SIMMES
Chair
Dutch Microfinance Platform
Netherlands
JAMI SOLLI
Senior Consultant, Financial
Services Consumer Protection
Consumers International
United Kingdom
Managing Director
Center for Financial Inclusion
at Accion
United States
SAHAR TIEBY
PIA ROMAN
MARIELA ZALDÍVAR
Head, Inclusive Finance Advocacy
Central Bank of the Philippines
RUPERT SCOFIELD
President & CEO
Finca International
United States
Executive Director
Sanabel
Jordan
Deputy of Market Conduct
Supervision & Financial Inclusion
Superintendence of Banks
Peru
Acknowledgements
The Smart Campaign gratefully acknowledges the financial support of Agence Française de Développement,
Asia Development Bank, Credit Suisse, Deutsche Bank, the Ford Foundation, the Inter-American Development
Bank’s Multilateral Investment Fund, the International Finance Corporation, The MasterCard Foundation,
the Small Industries Development Bank of India (SIDBI), USAID and Accion, and thanks the many partners
who enable and facilitate its work:
• Access/Assist, India
• Association of Microfinance Institutions in Rwanda
• Association of Microfinance Institutions of Uganda
• Association Professionnelle des Systèmes Financiers
Décentralisés du Côte d’Ivoire
• Azerbaijan Microfinance Association
• Bangko Sentral ng Pilipinas, Philippines (BSP)
• Bankable Frontier Associates
• Cambodia Microfinance Association
• CDF Network
• Centre for Microfinance Nepal
• CERISE
• Consortium Alafia and National Advisory Council
• Consultative Group to Assist the Poor
• COPEME, Peru
• EDA Rural Systems, India
• Emprender, Colombia
• Entrepreneurs du Monde
• Financial Inclusion Equity Council
• Ghana Microfinance Institutions Network
• Good Return
• Lanka Microfinance Practitioners’ Association
• Laos Network
• MAIN Network
• M-CRIL
• Microfinance Center for Eastern Europe and
Central Asia
• Microfinance CEO Working Group
• Microfinance Council of the Philippines
• Microfinance Information Exchange (MIX)
• Microfinance Institutions Network, India (MFIN)
• MicroFinanza Rating
• MicroRate
• Pakistan Microfinance Association
• Planet Rating
• Sa-Dahn , India
• SEEP
• Smart Campaign Client Voice Working Group
• Smart Campaign Evolution of Standards
Working Group
• Social Performance Task Force
• Superintendencia de Banca, Seguros y AFP, Peru
Keeping
Clients First
in Inclusive
Finance
Progress Report
July 2015
The Smart Campaign
c/o The Center for
Financial Inclusion at Accion
1101 15th St. NW, Suite 400
Washington, DC 20005 USA
Tel: (202) 393-5113
Fax: (202) 393-5115
smartcampaign.org
