Digital Financial Services and

Microfinance: State of Play

A framing note to inform the Evolution of the
Client Protection Standards

Lead Author:
Sonia Arenaza, Director, Channels and Technology

August 21st 2014

Collaboration between the Smart Campaign and the
Accion Channels and Technology Team
DFS and MFI

Digital Financial Services and Microfinance Institutions

Digital Financial Services and Microfinance Institutions .............................................................. 2

1. Introduction ..................................................................................................................... 2

2. Purpose of this Note ......................................................................................................... 2

3. Opportunities and Challenges for MFIs in Digital Financial Services ................................... 3

4. Role of MFIs in Digital Financial Services ........................................................................... 4

a. State of play in deployments ............................................................................................ 4
b. The need for partnerships ............................................................................................... 5
c. What are the benefits for MFIs? ...................................................................................... 5
d. How can MFIs incorporate mobile banking? ................................................................... 6
e. What approach could MFIs take? .................................................................................... 6
f. How are MFIs incorporating loan repayments, disbursement, and savings today? .........7
g. How are MFIs acting as agents? .......................................................................................7
5. MFI Success Factors in implementing mobile banking ....................................................... 8

6. MFI challenges in the implementation of mobile banking ................................................. 9

7. Raising risks to clients in implementation of mobile banking ............................................10

8. Annex A ..........................................................................................................................14
a. Partnerships: Deployments of mobile banking in MFIs ................................................. 14
b. Terminology ................................................................................................................... 16
9. Annex B – The Client Protection Principles and Standards ................................................17

10. Annex C – About the Authors...........................................................................................18

Smart Campaign ................................................................................................................... 18
Accion Channels and Technology Team ................................................................................ 18
11. References ......................................................................................................................18

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DFS and MFI

Digital Financial Services and Microfinance Institutions

1. Introduction

The Client Protection Standards were created to operationalize where the microfinance industry sets the bar
in terms of the minimum behaviors clients should expect from institutions with which they do business.
Building off of the seven Client Protection Principles (CPPs), the Client Protection Standards specify what
‘doing no harm’ must entail in practice. The current 30 standards represent the output of several years of
industry collaboration and input managed by the Smart Campaign (See Annex B for the complete list of the
standards). For the standards released in January 2013 as part of the Client Protection Certification
program, the Campaign worked with a Task Force of over 30 experts representing various stakeholders to
develop and vet the recommendations. The standards are truly a public good for and by the industry.

Standards which reflect social norms and expectations of an evolving industry must be dynamic. In order to
incorporate an ever-growing sector and its diversity of products, services and related client-protection risks,
the Smart Campaign has begun to work to evolve and improve its standards. One of the key directions of
industry evolution is towards the use of Digital Financial Services (DFS). Therefore in partnership with the
Accion Channels and Technology team, and under the management of an Evolution of Standards working
group, the Smart Campaign began a work stream to understand the emerging risks to clients of Digital
Financial Services and how best to mitigate those risks.

Given the Smart Campaign’s momentum of working directly with microfinance and financial service providers
since 2009, the workstream initially sought to understand the intersection of two big questions:

 What are the emerging risks to clients using digital financial services? How do these risks align with
the seven Client Protection Principles?
 How are microfinance providers using digital financial services?

It is the intersection of these two key inquiries from which the first set of recommendations for the Evolution
of the Client Protection standards will emerge. These recommendations will be shared publicly in late
September 2014 for several months of open comment and feedback. These recommendations will then be
discussed, debated and tested in the field for viability before becoming a permanent part of the standards
and part of the Client Protection Certification Program.

It is anticipated that most immediate application of these recommendations will be to microfinance

institutions as part of the Certification program, however the Campaign firmly believes that the Client
Protection Principles and standards are relevant and applicable to the wider ecosystem
encompassed by all digital financial services.

2. Purpose of this Note

In the context of the Evolution of Standards of the Smart Campaign and its Digital Financial Services (DFS)
work stream –which analyzes the risks that the use of these services poses to clients– this paper aims to
provide a deep dive into the intersection of DFS and microfinance.
1
Since DFS covers mobile financial services and branchless banking , it would be difficult to track
exhaustively how microfinance institutions (MFIs) are using DFS. We have focused on branchless banking
2
and mobile banking , a component of DFS, because of the promising opportunities it presents for financial
institutions in reaching scale, leveraging existing deployments, and tapping into large populations at the base
of the pyramid (BoP).

1
Delivery of financial services outside conventional branches by using technology channels such as cards, POS, ATMs,
and mobile phones
2
Mobile banking, for the purpose of this research, incorporates mobile money and mobile payments

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DFS and MFI

Therefore, this desk research is intended to fill a knowledge gap in the intersection between DFS and
MFI by providing an overview of the uses of DFS, especially with regards to mobile banking, and by
answering the following questions:

 What is the role of MFIs in DFS?

 Why is there a need for partnerships?
 What are the benefits for MFIs of implementing mobile banking?
 What are the most common DFS implemented by MFIs and how are MFIs implementing them?
 What are the key success factors and challenges?
 What are the risks to customers in implementing these services?

Understanding the scale and use of DFS in MFI operations will help the Smart Campaign in narrowing the
scope for its initial set of recommendations by understanding what is salient and being used in the field.
Indeed this research will help the Smart Campaign be in a better position to improve the existing Client
Protection Standards to pinpoint safeguards to minimize and mitigate against risks to clients when MFIs
implement DFS. Building off this document, subsequent phases of the research will include a comprehensive
client protection risk to matrix which, when combined with this note, will lead to key recommendations for
service providers implementing DFS who strive to meet the Smart Campaign’s principles of Client Protection.

3. Opportunities and Challenges for MFIs in Digital Financial Services

The revolutionary use of mobile phones in emerging markets presents MFIs –already providers of financial
services to the BoP– the opportunity to improve customer service to current customers by providing
ubiquitous, safe and convenient ways to disburse and repay loans, save money, and check their balance; to
increase customer outreach by bringing services beyond brick and mortar branches; and to reduce
operational costs or generate additional revenue which could be translated into a possible reduction in the
interest rate. Therefore, there is the potential for to have more access to quality and affordable financial
services.

 Evidence shows that mobile money deployments could help MFIs to improve operational
efficiency, reduce costs, and better serve their existing customer base. These services though
have been led mainly by mobile network operators (MNOs) and to some extent large banks. While MFIs
are distinguished for their expertise in knowing clients’ needs and having high interaction with them; their
success with large innovative technology projects or delivery channels is far less recognized. Of those
MFIs that have successfully leveraged mobile banking, the majority are usually located in markets where
the mobile service is widely used.

 Nonetheless, mobile banking involves the use of technology, non-cash transaction (in the form of
electronic money complementing cash in and cash out transactions), and the participation of different
actors with different levels of liabilities (e.g., MNOs, financial institutions, agents, and third-party
providers). As such, mobile banking poses risks to clients (e.g., fraud, data privacy and security,
service availability, hidden prices and fees, discrimination, insolvency, non-authorized ads,
inadequate mechanisms for complaint resolution, etc.)—risks a MFI should pay attention to in order
to provide quality services.

 MFIs can incorporate mobile banking into their business processes (e.g., loan disbursements,
loan repayments, savings, and insurance) or act as agents of mobile money providers; MFIs are
potential teammates if service providers want to tap into a large clientele at the BoP and/or work with
patient agents aiming not only to acquire commissions. The third option– pursued by few MFIs due to
large resource requirements– is to launch the service themselves either by designing and implementing
the service in-house or partnering with a mobile solutions provider. Evidence has shown that this option
is cumbersome, time-consuming, and costly for a MFI. Worth noting is that MFIs are still figuring out the
best way to leverage mobile banking services in their processes and day-to-day operations under the
regulatory, cultural and competitive environment they operate in. The ongoing and planned
implementations will spur experimentation and help find successful deployments –scalable business
models using mobile banking.

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DFS and MFI

 With an increasing number of mobile money/banking deployments and MFIs participating in these
deployments as well as an increase in users of the service such as customers, non-profit organizations,
and governments, there seems to be an opportunity for MFIs to play a role in the mobile ecosystem. In
order to do so, MFIs must develop the capabilities required (e.g., stable infrastructure and
technology systems, adequate process, competitive personnel, experience in partnerships, etc.)
to take advantage of mobile banking services already available or soon to become available in
their countries.

 Some new MFIs are launching their operations using only mobile banking from the very
beginning. This shortens the journey through organizational changes and investments upfront. From
existing MFIs to new MFIs, mobile banking is not only changing the way MFIs operate but also
supporting new business models with the inclusion of mobile technology and data analytics in credit
scoring, decision and under-writing processes.

 The critical success factors for leveraging mobile banking are regulation, partnerships, and
channels strategy. It is important to also recognize that MFIs work in markets with different levels of
maturity of the mobile ecosystem and adoption of service, aspects which contribute to the success or
failure of the channel as well. While the mobile money industry continues to grow, there remain
challenges to its sustainable, scalable, and inclusive growth. These implementations require substantial
investment, skilled resources, adequate infrastructure, agile processes, and a conducive regulatory
environment among other factors to foster customer adoption/usage and subsequently reach scale. As
such, service providers need to carefully assess why, when, where, what, how, and who with, before
embarking on this journey.

Accion’s Channels and Technology team has already played a supportive role to some MFIs in analyzing
deployments and providing guidelines (e.g., how to pursue partnerships, how to closely collaborate with
regulators, liabilities with regulator by working with partners). .

4. Role of MFIs in Digital Financial Services

a. State of play in deployments

In 2013, according to the ITU, there were as many mobile cellular subscriptions as people in the world with
mobile penetration at 96% globally and 89% in developing countries. According to GSMA –MMU deployment
3
tracker and Mobile Money Adoption Survey– there are more mobile money accounts than bank accounts in
4
9 markets and more mobile money agent outlets than bank branches in at least 28 countries; services are
present in 84 countries across different regions. Also 89% of the implementations, 209 out of 233, provide
p2p domestic transfers which do not require a bank account. As of 2014, MNOs still lead the mobile banking
industry with more than 60% of the total number of deployments. Nonetheless, as of Feb 2014, only 13
deployments have reached scale, meaning that only 5% have more than one million active accounts.

By incorporating the use of mobile phones, organizations provide customers access to a wide range of
services such as mobile banking, money transfers, mobile payments, and internet. In other words, customers
could now perform p2p transfers, top-up, bill payments, merchant payments, loan payments, loan
disbursements, savings, insurance, and any other payment streams such as g2p, b2g, and b2p through their
mobile phone devices.

While there are incentives for implementing DFS, the implementation of branchless banking and mobile
banking tend to be divided along geographic lines. Latin America has a long history of innovative
experimentation with mainly banking agents (also known as non-corresponding banks); known examples are
Brazil with approx. 400,000 correspondents, Mexico with approx. 22,000 correspondents, Peru with approx.
17,000 agents, other countries with strong banking agents are Colombia, and Ecuador. More recently, there
are mobile money implementations throughout Latin America; Brazil, Paraguay, and Guatemala have paved
the way to innovation but have yet to see any important uptake. Africa in contrast seems to be the leader in

3
http://www.gsma.com/mobilefordevelopment/programmes/mobile-money-for-the-unbanked/insights/tracker
4
Cameroon, DRC, Gabon, Kenya, Madagascar, Tanzania, Uganda, Zambia, and Zimbabwe.

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DFS and MFI

mobile money with success cases in Kenya, Tanzania, Uganda, and South Africa; among these mPesa is
the leader. Other notable implementations of mobile money exist in Asia, Afghanistan, Pakistan, Philippines
and Bangladesh.

b. The need for partnerships

Among the different service providers (e.g., MNOs, banks, and third party providers), MNOs and large banks
are still the leaders of mobile deployments, operating under an MNO-based, Bank-based, or hybrid
(MNO/Bank) based model. It’s worth noting that MNOs’ business models are often closed-loop and based on
transfers and payments –mainly motivated to reduce prepaid churn and airtime distribution costs; their
services access the poor but lack high quality service because of an incipient knowledge of the needs of
customers at the BoP. Big banks’ models do not necessarily reach the poor and often have limited
understanding of the mobile money market. Third-party providers such as aggregators, integrated solution
vendors, technology and credit card providers also strive for having relevant participation. There are few
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successful third-party-based cases , however third-party providers lack market power and footprint compared
to MNOs and big banks.

Each model has pros and cons and each provider has strengths and weaknesses. While tapping into a vast
population at the BoP is attractive, the incentive of each service provider may vary. If a provider were to
tackle the BoP with customer-centric products, there is a need to identify the best partners to work with as
there are a myriad of conditions and resources required for success. Teaming up with the top players will
help build synergies and increase the chances of customer adoption, provided products/services are easy to
use, appropriate, reliable, affordable, understandable, available, and accessible.

While MFIs are an attractive partner for tapping into a vast poor customer base whom they know well, few
have been tapped due to a dearth of scalable business models and innovative solutions. If working alone on
a deployment MFIs would probably hinder rapid scale-up with the high quality this service requires. Few
6
MFIs have the resources to lead mobile banking deployments let alone reach scale .

c. What are the benefits for MFIs?

The high-touch and in some cases labor intensive model of microfinance poses limitations to reach scale;
MFIs face challenges such as high operational costs and efficiency. By using mobile banking services MFIs
could scale their operations quickly, provide customers high value and convenient services, cross-sell
products, increase customer loyalty and transparency, and decrease cases of fraud and theft. Despite these
potential gains, there is not much evidence on whether mobile banking services help MFIs to reach out to
new customer segments.

The benefits for MFIs, while promising and vast, depend upon the business case on what the institution is
trying to achieve with the channel and could include:
 Better service to clients and loyalty: by using mobile phones and/or agents, clients can pay their loans
easily without incurring additional costs in transportation/time, and theft risk; customers could also
receive reminders and alerts;
 Customer outreach: MFIs could access difficult and costly to reach areas;
 Increase customer service, education and capacity: by leveraging digital channels to better inform the
client, remind them of alerts, and empower them to better use the service;
 Increase transparency and security: by moving cash to electronic streams, MFIs have the opportunity to
be more transparent, reduce fraud risks, provide secure options to clients and field officers and reduce
thefts;
 Operational efficiency: reducing branch congestion, improving the time spent by field officers in the field
–e.g., less time in cash collection if done by mobile phones and more time left for loan monitoring and/or
client education;
 Cost savings: using mobile banking to disburse loans rather than distributing coupons or checks, which
implies logistics and personnel costs;

5
Zoona in Zambia, Selcom in Tanzania, Cellulant in Nigeria and Kenya
6
There are some exceptions such as Tameer and Telenor in Pakistan, BankO in Philippines, Opportunity International in
Malawi, and Musoni in Kenya

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DFS and MFI

 Cross-selling and product diversification: by offering additional products such as savings and micro-
insurance. If a client has the opportunity to save money through her phone, she will create a financial
history that would allow her to access credits to use other products later on. This may also represent
lower cost of funds for the MFI due to the client’s ability to save;
 Increase revenue: In some cases, there is also the possibility –depending upon the business objective of
the channel- that MFIs would receive revenue from transactions commissions and cross-selling of
additional products.

Therefore, there are ample opportunities for MFIs to implement mobile banking into their services and tag
along successful deployments. As there are different stages of development in the mobile money ecosystem,
MFIs need to analyze their current environment and define their strategy for the adoption of mobile banking.

d. How can MFIs incorporate mobile banking?

MFIs have the option to provide additive or transformative DFS. In countries where there is a mobile banking
infrastructure, MFIs could leverage those services in their loan disbursements, repayments, deposits, and
insurance, and could act as agents or master agents on behalf of DFS providers (e.g., MFIs in Kenya and
Tanzania) This requires collaboration between MFIs and service providers (See Annex Partnerships:
Deployments of mobile banking in MFIs) and a close analysis of the conduciveness of the regulatory
environment.

In environments where no mobile money solution has been launched, MFIs have several choices:
 Wait until there are enough solutions providers and assess credible and solid partners with which the
MFI could partner with to launch the service; the service provider could also be a credit card company
(e.g., Urwego Opportunity Bank, UOB, partnered with mVisa in Rwanda to use visa’s mobile platform);
 Use mobile phones for achieving internal improvements and/or for non-cash purposes such as to collect
information, verify customers in the field before moving ahead with the underwriting process (i.e., bureau
and scoring), consult customer status on payments and history, send payment reminders, check bank
7
balance and any other commercial information . MFIs could pave the way of their readiness by using
mobile phones for internal improvements and non-cash purposes before deploying mobile banking
services;
 Lead deployment of mobile banking. Though, leading a mobile money service is complex due to the
levels of readiness, know-how, investments and effort it requires.

e. What approach could MFIs take?

It is important to note that the use of mobile banking services creates a need for options beyond conventional
delivery channels where clients could cash in and cash out. That is, agents such as mom and pop shops,
post offices, and pharmacies act as “human ATMs”. Since a mobile banking service needs to prove its
convenience and serve the needs of its customers, it requires a critical mass of quality agents.

MFIs have two approaches:

 To incorporate the use of mobile banking in their business processes (i.e., loan disbursements, loan
payments, savings, and insurance); or/and
 To act as agents of the mobile providers.

The mobile banking service could be incorporated as follows:

 Use the bill payments functionality of the mobile providers and act as another type of merchant (i.e.,
water, electricity, schools, financial institutions and other service companies). However, this process
requires integration in order to be efficient:
o For allowing minimal reconciliation. It is critical to avoid manual reconciliation. Conversely, some
institutions postpone integration and perform manual reconciliation, which we have found could
potentially lead to perpetrating frauds to clients, misconduct of agents, and collusion between
clients, agents and the service provider’s personnel

7
This research makes special emphasis on financial transactions done through mobile phones and does not cover
additional uses such as data collection, notifications, and innovation in underwriting process.

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DFS and MFI

o For allowing seamless integration by integrating the institutions’ systems and including a
middleware layer; a middleware performs automatic updates and reconciliation of information in
real time. The level of investment and time of implementation depends on the maturity of the
market; for example, markets like Kenya have a compelling number of technology providers with
experience working with MNOs. In some cases MFIs have built their own middleware but this
requires resources that a MFI usually does not have. A middleware is an attractive option as it
improves customer trust in the system. In contrast, a lack of integration presents barrier for
adoption, for example after a client pays a loan through an agent, her loan may still show up as
outstanding in the MFI’s system up until reconciliation issues are solved, thus the client will be
impeded to perform additional transactions;
 Implement digital financial service from inception. We have seen some MFIs in Africa (e.g., Musoni) and
Asia (BanKO) do this;
 Use a provider’s solution and customize it according to the MFI’s needs or create the solution in-house.
Evidence shows that the process of incorporating DFS by these MFIs is gradual. Later on, depending on
the level of maturity and adoption of mobile banking services in the country, MFIs integrate or
complement their offer;
 Use parallel wallets and link mobile accounts, that is, some MFIs have leveraged USSD options to
perform transactions but this in addition to an existing mobile money service usually creates confusion to
customers, who now have to memorize the USSD code for each service. This requires a careful
customer-centric approach to make the whole experience of using either service seamless for
customers.

f. How are MFIs incorporating loan repayments, disbursement, and savings today?
Based on current implementations, the most common service offered to clients is loan repayments followed
8
by savings and loan disbursements. According to CGAP , MFIs that have implemented those services have
reduced costs, fraud and risks of transporting cash for both clients and field officers. Fifteen deployments out
of 233 currently live implementations ( or 6%) provide loan repayments or mobilize savings or loan
disbursements, and five out of these fifteen have a partnership with MFIs. Only 6 deployments include
9
mobile micro insurance . Overall, the inclusion of these services is still incipient.

 Loan repayments: represent a quick win for MFIs as they could leverage a wide network of agents of a
mobile provider (e.g., SMEP, K-Rep, and Faulu in Kenya). While this immediately improves individual
lending repayments, there are some concerns regarding how this could affect the dynamic of group
lending; but after some implementations MFIs have reported it brings added value to both the customer
and field officer as they have more time to go over financial education and loan progress than counting
cash during the group meetings. Another concern, which will depend on the MFI’s business processes, is
the adjustment to new payment options for customers used to MFI officers collecting the repayments;
 Loan disbursements: in contrast to loan repayments, loan disbursements still present challenges due
to liquidity constraints at the agent, amount to disburse, and disbursement limits per agent per day. In
some cases customers have to cash out at several agents –which hinders convenience of the model, or
cash out several times at an agent –which hinders affordability as it is more costly for the customer,
depending on the fee structure of the service;
 Savings: MFIs could increase savings mobilization by using mobile banking. Clients could either transfer
money from their mobile account to their savings account by using their phones or going to an agent
(e.g., KWFT in Kenya, and BRAC in Bangladesh).

g. How are MFIs acting as agents?

Acting as agents of a mobile service could provide MFIs experience on how to handle these services and
options to further their offers and partnerships. At the same time, MFIs could also confront challenges such
as branches with liquidity issues demeaning quality of the service, unclear incentive structures between the
service provider and MFIs –let alone between the headquarter and branches- and, as a consequence, a lack

8
http://www.cgap.org/sites/default/files/CGAP-Focus-Note-Microfinance-and-Mobile-Banking-The-Story-So-Far-Jul-
2010.pdf
9
Colombia with Bancolombia ‘Ahorro a la mano’, Burkina Faso with Inovapay, Burundi with MobiCash, South Africa with
Wizzit, Tanzania with mPesa, and Afghanistan with mHawala

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DFS and MFI

of incentive to provide quality service at the branches. Therefore, MFIs could adopt an incremental approach
and ensure with data analysis where and what kind of services to implement, for example restrictive services
(branches with only customer onboarding and registration) and added services (cash-in and/or cash-out). In
mature markets with wide mobile use, MFIs could have additional revenue by acting as agents if they smartly
decide what services to offer in their branches.

5. MFI Success Factors in implementing mobile banking

The role a MFI could play is strongly influenced by the level of maturity and development of the mobile
ecosystem. For example in markets like Kenya, Tanzania, Philippines, Bangladesh, and Uganda, MFIs can
ride along the existing mobile money roads. In contrast, in nascent mobile money markets, MFIs will have to
go through more costly, difficult, long, and cumbersome processes. Some of the critical success factors are:

 Regulation: dealing with regulation and regulators is a critical success factor. There is increasing
concern over the need for the mobile banking regulatory environment to strike the right balance between
risk and access. That said; regulators have the challenging
task of keeping a ‘proportionality’ principle in which the cost
An example to learn from:
of regulating should not outweigh the impact of risk. As
mobile banking involves the use of technology, non-cash
transaction (in the form of electronic money complementing Afghanistan Telecomm Operators
cash in and cash out transactions), and the participation of Social Association (ATOSA), was
different actors with different levels of liabilities, regulators formed in 2011 by Afghan
face the challenge of monitoring risks (e.g., KYC, fraud, Telecom, Afghan Wireless
money laundering, liquidity, solvency, client protection of
Communications Company,
rights and funds) and at the same time increasing access
(e.g., easy enrollment and onboarding with account Etisalat, MTN and Roshan, to
opening, synergies and leveraging infrastructure, etc.) provide a forum to share
experiences in implementing
Without an enabling market and regulatory environment, mobile financial services and
MFIs will struggle to participate in mobile financial services. strengthen the enabling
Nonetheless, MFIs can and should play an active role by:
environment. ATOSA touches upon
o Building good relationships with the agencies
regulating DFS; topics such as security, client
o Providing them feedback on the dynamics of the protection, public-private
industry and any implementation they are planning partnerships, and lobbying for
to go through, and better public policy.
o Creating alliances with like organizations to
increase their influence in developing inclusive
policies by using digital finance.

This close collaboration will improve the balance between mobile microfinance and client protection (see
text box).

 Partnerships: MFIs could leverage existing infrastructure and networks of agents of service providers
and can prove to be a valuable partner to tap into a large customer base at the BoP and leverage the
knowledge MFIs have of their customers and branch network. On the downside, MFIs frequently do not
have negotiating and bargaining power. It is commonly perceived –if not accepted- that MFIs have a
power imbalance with large third party providers (e.g., some may require exclusive contract conditions,
abusive price tariffs, unfair revenue model, etc.) This could jeopardize the quality of service customers
receive. Before embarking into a partnership MFIs should consider:
o Alignment of business objectives: it is important to clarify each party’s and value proposition to
participate in these deployments;
o Client Protection Issues including privacy, security, intrusive marketing and ads to customers of
MFIs from service providers, and clear definitions of who owns client data;
o Integration: integrating systems could be a double-edged sword if first service providers do not
have appropriate application program interfaces for integration (this was a big hurdle of mPesa
mobile payments) or secure systems to synchronize with; or if MFIs lack readiness and system
stability to go through an integration and data synchronization;

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DFS and MFI

o Interoperability: this reduces client opportunities to transact with clients of other service
providers. However, the level of interoperability required varies depending on the market share
of the service provider. Lately, regulators are paying more attention to interoperability as this
could increase access with quality at affordable prices (e.g., Tanzania is moving forward on this
front).

MFIs could be favored when large service providers companies make explicit commitment to work with
the BoP. It has been proven that MFIs could increase their power of negotiation by associating with other
MFIs or cooperatives (e.g., MABS rural in Philippines)

 Clear channels strategy and channel-product-client mix: mobile banking deployments require a high
volume of transactions, a large customer base, a distinctive value proposition, and vast resources. A MFI
channels strategy should be supported on a careful assessment of the country’s legal, regulatory, and
competitive environments.

 Proven structured approach for implementing mobile banking services: as with any service that uses
technology intensively, replaces cash, and reduces human interface, each mobile banking
implementation presents its own complexities and challenges. MFIs are working by trial and error, but it
is critical first to understand the ecosystem and level of maturity of mobile banking in each country. MFIs
10
should support their implementations on industry guidance :
o Perform a feasibility assessment and market research
o Identify value proposition
o Identify the niche market
o Define the business case and assess it, which includes a cost benefit analysis
o Implement the channel
o Define, execute, monitor, measure success and improve testing and pilot phase
o Perform full scale roll-out and develop extensive agent footprint
o Monitor and maintain/improve quality of service

Overall, though the participation of MFIs is still nascent, there is space to leverage the full potential of
financial services. MFIs seem to be placed at the right time to take advantage of the opportunities they
have ahead: the widespread use of mobile phones, adoption of mobile payment and transfers, and
moreover the benefits that mobile promises to improve operations, reduce costs, and better serve
their clients –who in many cases may already be using mobile money services provided by other
service providers.

6. MFI challenges in the implementation of mobile banking

MFIs face the following challenges:
 External environment: lack of adequate partners (mobile banking, technology providers and platforms)
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and/or few successful implementations, regulatory restrictions , lack of interoperability;
 Internal environment: skilled and experienced personnel, poor technology infrastructure and technology
instability (inadequate MIS or core banking systems) and the need to integrate with other platforms,
operational agility (inadequate process to support the implementation of the mobile channel), budget
constraints to develop the channel/mobile banking, lack of sponsorship from management;
 Lack of clear value proposition for clients to switch from cash to mobile banking or to a mobile wallet;
 Lack of feasibility study and research on client needs and behavior, leading this to poor customer centric
product/services;
 Lack of business case and understanding of the costs involved for these initiatives;
 Measuring what success means in implanting and rolling-out the channel (customer/operational metrics);
 Lack of negotiating power with the service providers; if possible to create alliances with other MFIs or
cooperatives to increase the negotiating and bargaining power;
10
Channels & Technology at Accion has developed a channels methodology that aims to support MFIs to properly plan,
pilot, roll-out, and operate scalable and effective delivery channels
11
According to CGAP, there are two necessary but not sufficient conditions to implement mobile banking services:
authorization to use retail agents as CICO points and development of risk-based anti money laundering and combating
financing of terrorism rules adapted to the realities of remote transactions conducted through agents

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DFS and MFI

Also, as any other service provider, MFIs face the following barriers for adoption, which is influenced by the
culture and behavior of the clients they serve:
 Population / client trust on the mobile service and in some cases on the banking system: users will not
change to mobile money services or mobile wallets unless there is a strong value proposition associated
with these services
 Customer education / illiteracy and Financial literacy
 Trust and confidence: the implementation of mobile money and mobile banking services involves the use
of technology, minimum or non-human interaction, and lack of tangible physical cash that hinders user
confidence
 Data security and privacy

On the regulatory restrictions, the position taken by the regulator affects the implementation of mobile
financial services. Moreover, the existence, or lack thereof, impacts the ability of MFIs to play a role in mobile
banking. MFIs may need to overcome stability in regulation (unclear or conservative guidelines could hurt
innovation), non-existing regulation, additional license required for mobile transactions (does regulation make
it possible to disburse loans in cost-efficient ways?), restrictions on loan disbursement, KYC, and AML/CFT
rules.

7. Raising risks to clients in implementation of mobile banking

It is important to consider the risks MFIs and more importantly the clients they serve face due to the
complexity of mobile banking services and the different players that participate (e.g., MNO, agents, third
party providers, etc.).

The implementation of mobile banking services and the use of non-banking agents carry operational,
financial, reputational (poor customer adoption, trust, and perception), technology, regulatory, compliance,
liquidity, financial, legal, international, market, and credit risks.

Considering the focus of the Campaign and the Evolution of Standards, we have emphasized risks that
hinder quality services to clients aligned with the Client Protection Principles of the Smart Campaign
(appropriate product design and delivery, prevention of over-indebtedness, transparency, responsible
pricing, fair and respectful treatment of clients, privacy of client data, and mechanism for complaint
resolution). MFIs will need to ensure that the service provided by each of the players in the value chain
ensures the same quality of ‘high touch’ service they provide to customers.

See DFS- Risk to Clients Mapping on next page. Additional risks to be examined in subsequent research.

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DFS and MFI

DFS - Risk to clients mapping

Who is Risk Description of risk Maps to Smart Campaign Principle Potential Mitigant (options and considerations) Control of Financial
affected? Impact of Institution
Risk on Client
1 Clients Clients do not make Clients are not adequately 1. Appropriate product design and delivery, 3. ↑ - Focus education on client understanding of the service, trust Medium/High
informed decisiones communicater nor trained on: Transparency, 7.Mechanism for complaint in the service and how the provider will support if things go
because there is not (i) Service understanding (e.g., how resolution wrong.
adequate information does it work, how to use the service,
by providers how to register, how to opt-out) - Continuously reinforce client education and keep an open
(ii) Trust in the service (e.g., reinforce channel of communication.
Client confidence in the service,
security of data) - Perform periodic client surveys.
(iii) Client service (e.g., where to
complain/call if the service does not
work, if the transaction did not go
through, if the agent does not
provide adequate service, etc.)

2 Clients Inadequate or lack Provider offers inadequate support, 1. Appropriate product design and delivery, ↑ - Inform and educate client regarding call center/complaint Medium/High
client care channel dispute resolution, and complaints 7.Mechanism for complaint resolution line and corresponding channels.
mechanisms to clients.
- Clearly define which provider is ultimately responsible for
When issues occur: resolving clients issues and the time those issues should be
(i) clients do not know who to resolved.
approach to,
(ii) these centers are not accessible,
(iii) call centers do not adequately
deal with client queries and
complaints,
(iv) client's concerns are not
addressed in a timely and fair
manner.

3 Clients Data protection and Client identity is stolen and may be 6. Privacy of client data, 7.Mechanism for ↑ - Incorporate data security and encryption requirements. Medium/High
security used to open an account or perform complaint resolution However this could limit the possibility of using SMS
transactions (identity theft) technology for monetary transactions and USSD for Txs with
higher amounts;

- Establish minimum security requirements to the mobile

money provider;

- There is need to clearly identify who is financially liable to

refund funds to the client if those are stolen.

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DFS and MFI

Who is Risk Description of risk Maps to Smart Campaign Principle Potential Mitigant (options and considerations) Control of Financial
affected? Impact of Institution
Risk on Client
4 Clients Fraud perpetrated on Clients are defrauded and lose their 1. Appropriate product design and delivery, 5. ↑ - Improve/repeat client education, users should understand Medium
clients funds when: Fair and respectful treatment of clients,6. the importance of a PIN and not disclose their PIN number to
(i) Service presents faulty security Privacy of data, 7. Mechanism for complaint any other user.
that allows information to be stolen resolution
and misused; - If clients suspect the agent of fraud, they should be able to
(ii) Transactions after a downtime are contact the call center or any client care channels or go to the
lost; nearest provider shop and report the case for investigation.
(iii) Clients share their PINs with
another person; or - Regulate for security minimums.
(iv) a non-Client use a friend or family
Client's account (more than one user - Perform account monitoring and other controls supported
of the service) to perform by technology to evaluate Txs for strange behavior in order to
unauthorized transactions instead of reduce attractiveness of the service for criminal activity
the registered Client; (monitoring systems could detect unusual patterns).

- Evaluate to set Txs limit to avoid ability to cleanup an

account in a period of time. However, this needs a study
because evidence has shown that limits on Txs may hinder
repeat use of the service.
5 Clients Data privacy Users are not informed/misinformed 1. Appropriate product design and delivery, 3. ↑ - There is still a debate on allowing clients to share data Medium
on how their data and history is Transparency, 5. Fair and respectful voluntarily, to opt-out as a default from data tracking.
being used or shared. Hence: treatment of clients, 6. Privacy of client data,
(i) users information could be 7. Mechanism for complaint resolution - The Federal Trade Commission's report, Protecting client
inappropriately sold or track without Privacy in an Era of rapid change, urged providers to adopt
users consent; three practices: (i) privacy by design, (ii) simplified choice for
(ii) users could start receiving businesses and clients, and (iii) more transparency.
abused/unauthorized advertising
online and cross-marketing.

6 Clients Agents incompetence Clients cannot access the service 1. Appropriate product design and delivery, 5. ↑ - Reinforce agent training and monitoring. Medium
lead to lack of service because agent does not how to Fair and respectful treatment of clients, 7.
perform the transaction. Mechanism for complaint resolution - Inform and train client regarding available call centers where
they could inform about these agents.

- In cases where receiver cannot cash out money after a

period of time then funds should return to sender and sender
should receive a notification.

7 Clients Blocked access to Agents often have either cash or float 1. Appropriate product design and delivery ↑ - Improve liquidity management such as providing credit, Medium/High
funds or float when client is asking for other so improving procedures and repeat training and monitoring at
they can't get their money. agents.

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DFS and MFI

Who is Risk Description of risk Maps to Smart Campaign Principle Potential Mitigant (options and considerations) Control of Financial
affected? Impact of Institution
Risk on Client
8 Providers, Insufficient Information on roles and 3. Transparency, 5. Fair and respectful ↑ - Establish minimum disclosure and transparency Medium/High
Clients Transparency and responsibilities of the agent, product treatment of clients, 7. Mechanism for requirements and frequency to the mobile money provider.
disclosure of fees, prices, terms, conditions, complaint resolution
information mechanism to address Client's - Inform and educate client regarding call center/complaint
complaints, and timeliness of line and corresponding channels.
updates/changes are not disclosed to
client.
9 Clients Agent's misconduct or Agents charge unauthorized fees or 1. Appropriate product design and delivery, 2. ↑ - Disclosure of fees. Medium/High
corruption leads to agent does not clearly disclose Prevention of over-indebtedness, 3.
lost funds fees/prices to the client. Transparency, 4. Responsible pricing - Inform and educate client regarding call centers/complaint
5. Fair and respectful treatment of clients line where they could inform about these agents.

10 Clients Agent's Agents discriminate against Clients 1. Appropriate product design and delivery, 5. ↑ - Define clear recruitment, selection, and monitoring process Low/Medium
discrimination against due to lack of liquidity. Fair and respectful treatment of clients, for agents.
clients 7. Mechanism for complaint resolution
- Improve liquidity management procedures at agents.

- Inform and educate client regarding call center/complaint

line and corresponding channels.

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DFS and MFI

8. Annex A

a. Partnerships: Deployments of mobile banking in MFIs

Since it is difficult to identify all mobile banking implementations, the table below –while not exhaustive- provides an
overall idea of what MFIs are doing/offering in the mobile money space and the most commons services they offer. This
table shows strong cases of partnerships.

Country MFIs Model Services offered MFI features

Kenya KWFT Partnership with Loan repayments and 300m active borrowers, loan
mPesa deposits using mPesa’s bill portfolio of $140mm
pay functionality
Kenya Faulu Partnership with Loan repayments and $58.7mm gross portfolio, 79m
mPesa deposits (M active borrowers as of 2012
Kenya K-Rep Partnership with Acting as agent of m- 36 full banking branches, over
mPesa banking services 25,000 loan and 146,000
savings clients
Kenya SMEP Partnership with Allows customers to: Launched in 2009. 51m
mPesa Group loan repayments, customers
deposit and withdraw
savings, check account
balance
Tanzania Tujijenge Partnership with Individual loan repayments Launched in 2009.
mPesa 12m customers, as of March
2010
Mali KAFO Partnership with Allows customers to deposit Launched in 2009 with 300
Jiginew Orange Money and withdraw funds, customers to start; 280,000
transfer money, pay bills, depositors and 46,000
and increase call credit. borrowers; 102 of its 169
branches are Orange Money
agents

Cambodia Vision Fund WING Cambodia Acting as agent of m- By end of 2009 Vision Fund
banking services. WING had 98m customers, $21mm
used VisionFund outlets as loan portfolio outstanding
wING Cash-X-press points
for CICO
Philippines MABS (60 Partnership of banks, Banks are resellers Closed in 2012 having
rural banks) supported by USAID (agents) of GCash in rural provided 322 rural banks TA
areas to 1,019,183 clients. and training in a range of
services incl.
microinsurance and mobile
phone banking. Disbursed
more than 3.2
microfinance, microagri,
and housing microfinance
loans totaling more than
$960 million and were
managing more than 1.4
million microdeposit
accounts with balances of
more than $48 million.
Bangladesh BRAC Partnership with bKash Acting as agent of m- Biggest MFI in Bangladesh,
banking services. BRAC is 6.3mm active borrowers.
still adjusting the pilot, there
are 2000 clients
participating in the pilot
repaying loans

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DFS and MFI

Mongolia XacBank P2p transfers and links 62m active borrowers, 140m
customer’s currents depostors, 80m card holders
account with her mobile
money account,
Pakistan Tameer Partnership between Easypaisa 120m customers, $23.6mm
Microfinance Tameer and Telnor, Allows customers to Loan portfolio outstanding, $17mm
nd
Bank and 2 MNO) repayments and deposits in deposits
Telnor
Malawi Opportunity By itself Provide m-banking services Supports local microfinance
Bank to their customers. Allows organizations that provide
customers to deposit and innovative financial solutions.
withdraw funds, transfer 150,000 customers as of
money, pay bills, and 2007; double from inception.
increase call credit.
Kenya mPesa and Partnerhisp mShwari, Service has 4.8mm accounts
Equity bank Microsavings with an average savings of
of Kenya USD4.2 and a total of USD
21mm, the number of loans is
1.3mm while the outstanding
loans on day 30 are 3.8%, the
average loan size is USD 13
Philippines BankO By itself Payments, savings, credit, Established in 2009 as a
and insurance products milestone partnership between
the Bank of the Philippines
Islands (BPI) and Globe
Telecom. Has extended
over 2B Philippine pesos in
loans to its partner MFIs,
successfully reaching over
400,000 micro-entrepreneurs.
Kenya Musoni By itself (example of a Credit and savings Musoni Kenya, founded in
pure mobile model) 2009, is the first 100% mobile
microfinance institution in the
world. The company has
established five branches,
serves over 10,000 clients and
has disbursed loans with a
combined value of over $15m
to Kenyan micro
entrepreneurs. In April 2013
Musoni created two
subsidiaries: Musoni Services
and Musoni Investments.
Mexico Compartamos Partnership with Oxxo Banking agency Compartamos Banco, S.A., a
Mexican bank specialized in
microfinance, is the largest
lender to microbusiness
owners in Latin America.
Established in 1990 and
headquartered in Mexico City,
Compartamos provides small
loans to low-income Mexican
individuals and business
owners. Has coverage in over
90% of Mexico.

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DFS and MFI

b. Terminology
 AML/CFT: Anti-Money-Laundering and Combating the Financing of Terrorism
 Branchless banking: an alternative delivery channel that allows MFIs to offer customers financial services
beyond the frontiers of brick and mortar branches by using mobile phones of non-bank retail agents. It
incorporates technology channels such as cards, POS (point of sale), and ATMs
 CICO: cash-in and cash-out transactions
 DFS: Digital financial services, s the mix of branchless banking and mobile banking services. DFS = BK and
MFS
 Insurance: Practice by which a company or government agency provides guarantee of compensation for
specified loss, damage, illness, or death in return for payment of a premium
 KYC: Know Your Customer refers to the process used by a business to verify the identity of clients. Also
refers to bank regulation which governs such activities. KYC policies are becoming increasingly important
globally to prevent identity theft, financial fraud, money laundering and terrorist financing.
 Loan Disbursement: The distribution of funds acquired through receipt of a loan contract
 MNO: Mobile network operator
 Mobile banking services: provision of services such as mobile banking and mobile payments by either a
financial institution or a MNO in partnership with a financial institution
 Mobile banking services models
 MNO-led model, the most prominent business model
 Bank-led model, led by a bank or an institution with a financial license (e.g., XacBank in Mongolia)
 Third-party-led model, the institution or organization is created for this purpose (e.g, wizzit, WING,
Yellow Pepper, g-Cash). Usually this organization receives a license from the central bank to offer
financial services or to partner with a financial service provider
 Hybrid model, usually a joint venture between an MNO and a financial institution (e.g., Tameer bank
in Pakistan which partnered with Telenor; Telenor owns 51% of Tameer bank)
 Providing mobile banking solutions
 A SIM-integrated service, like the one implemented by mPesa requires active participation of the
MNO because the SIM card is pre-loaded with the application
 USSD solutions, supported by all phones and requires minimal involvement of the MNO in the
installation or implementation. A short‐code access must be negotiated with the MNO.
 Payment stream usages through mobile banking
 Bill: Payment of utilities (e.g. water and sanitation, electricity, gas) as well as school fees and
healthcare costs
 Merchant: Payment for goods and services acquired through merchants and retailers
 Loans: Re-payment of debts as through MFIs, banks, or other parties
 Payment Types
 B2G Transfers: Business-to-government payment
 B2P Transfers: Business-to-person payment
 G2P Transfers: Government-to-person payment
 P2P Transfers: Person-to-person payment
 Savings: Income retained; deferred consumption.
 Top-up: To replenish credit as to a mobile SIM card
 USSD: Unstructured Supplementary Service Data is a protocol used by GSM cellular telephones to
communication with the service provider’s computers.

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9. Annex B – The Client Protection Principles and Standards

1 - - Client Protection Principle 1: Appropriate Product Design and Delivery Channels

1 1 - The FI designs products that are appropriate to client needs and do no harm
1 2 - The FI seeks client feedback for product design and delivery
1 3 - The FI does not use aggressive sales techniques
2 - - Client Protection Principle 2: Prevention of Over-indebtedness
2 1 -
The FI conducts appropriate client repayment capacity analysis before disbursing a loan
2 2 -
The FI incentivizes quality loans
2 3 -
The FI uses credit bureau and competitor data, as feasible in local context
2 4 -
The FI Management and Board is aware of and concerned about the risk of over-indebtedness
2 5 -
The FI's internal audit department monitors that policies to prevent over-indebtedness are applied
The FI avoids dangerous commercial practices (i.e., avoids combining loan products to meet the same
2 6 - need, or restricting the loan use; sets prudent limits to allow for the renewal of a loan in case of early
repayment; sets guidelines for appropriate rescheduling policies)
3 - - Client Protection Principle 3: Transparency
3 1 - The FI fully discloses cost and non-cost information
3 2 - The FI communicates proactively with clients in a way that clients can easily understand
3 3 - The FI uses a variety of disclosure mechanisms
3 4 - The FI leaves adequate time for client review and discloses at multiple times
3 5 - The FI provides accurate and timely account information
4 - - Client Protection Principle 4: Responsible Pricing
4 1 - The FI offers market-based, non-discriminatory pricing
4 2 - The FI’s efficiency is in line with its peers
4 3 - The FI does not charge excessive fees
5 - - Client Protection Principle 5: Fair and Respectful Treatment of Clients
5 1 -
The FI culture raises awareness and concern about fair and responsible treatment of clients
5 2 -
The FI has defined in specific detail what it considers to be appropriate debt collection practices
5 3 -
The FI's HR policies (recruitment, training) are aligned around fair and responsible treatment of clients
5 4 -
The FI implements policies to promote ethics and prevent fraud
In selection and treatment of clients, the FI does not discriminate inappropriately against certain
5 5 -
categories of clients
5 6 - In-house and 3rd party collections staff are expected to follow the same practices as the FI staff
5 7 - The FI informs clients of their rights
6 - - Client Protection Principle 6: Privacy of Client Data
6 1 - The FI has a privacy policy and appropriate technology systems
6 2 - The FI informs clients about when and how their data is shared and gets their consent
7 - - Client Protection Principle 7: Mechanisms for Complaints Resolution
7 1 - The FI's clients are aware of how to submit complaints
7 2 - The FI's staff is trained to handle complaints
7 3 - The FI's complaints resolution system is active and effective
7 4 - The FI uses client feedback to improve practices and products

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10. Annex C – About the Authors

Smart Campaign

In response to a strongly recognized need to assure safe and responsible treatment of their clients, microfinance industry
leaders from around the world came together in 2008 to agree on a set of Client Protection Principles to guide the
microfinance industry. They recognized that when financial services are delivered in accord with the principles, clients are
enabled to use financial services well and providers build a foundation for healthy operation for years to come. Launched
in October 2009, the Smart Campaign was created to put the principles into action. Engaging the entire microfinance
industry, the Smart Campaign has become a global movement to embed client protection into the DNA of the
microfinance industry and the broader financial inclusion space. The Smart Campaign works with microfinance leaders
from around the world on a common goal: to keep clients as the driving force of the industry by providing microfinance
institutions with the tools and resources they need to deliver transparent, respectful, and prudent financial services to all
clients. The Smart Campaign believes that protecting clients is not only the right thing to do, its the smart thing to do.

Today, the Smart Campaign is truly a global effort with a wealth of tools and resources and an ambitious action agenda. It
is changing the way microfinance institutions protect their clients. Industry uptake has been overwhelmingly positive: it has
garnered over 4,000 endorsers from 139 countries, including over 1,200 MFIs. At present, 15 MFIs have achieved Client
Protection Certification, reaching close to 5 million clients. These institutions have met rigorous criteria for their treatment
of clients, as verified by third party certifiersThe Campaign is now recognized as the go-to place for client protection,
which gives it both enormous opportunity and enormous responsibility to carry its work forward.

Accion Channels and Technology Team

The Accion Channels and Technology Teams are responsible for supporting microfinance institutions and banks
implementing and managing their digital financial service channels. The expertise range from strategy development and
planning to project management and implementation of technological and channel innovations. The team has hands-on
experience increasing consumer adoption of digital financial services and enhancing its implementation. Accion has
worked closely with its partners in Colombia and Ecuador implementing channels such as ATM’s, minibranches, mobile
banking, and agent networks, and advised and supported these institutions during the stages of strategy planning,
defining objectives, market research, development, testing, and launching, as well as training management and field staff.
The Accion Marketing Team has led in-depth demand-side projects to understand constraints to adoption and usage of a
variety of technology-enabled products.

11. References

References used for this research are shown below. Worth noting is that there are few studies regarding how MFIs are
currently or planning to use branchless banking and the intersection of mobile and microfinance.

 CGAP, Microfinance and mobile banking: The Story so Far, No 62, http://www.cgap.org/sites/default/files/CGAP-
Focus-Note-Microfinance-and-Mobile-Banking-The-Story-So-Far-Jul-2010.pdf. CGAP studied in 2012 15 microfinance
organizations to understand their perspective and plans for m-banking
 CGAP, Microfinance and mobile banking: Blurring lines? No 88, http://www.cgap.org/sites/default/files/Focus-Note-
Microfinance-and-Mobile-Banking-August-2013.pdf
 Mobile banking study: Experiences and perspectives of MFIs by MFO and TripleJump
http://www.fgda.org/dati/ContentManager/files/Documenti_microfinanza/Mobile-Banking-Study.pdf TripleJump and
MFO interviewed 123 MFIs in 2013, 73 responded the mobile banking survey. Only 13 MFIs were providing mobile
banking services.
 Guideline Note, Mobile Financial Services: Technology Risks http://www.afi-
global.org/sites/default/files/pdfimages/AFI_MFSWG_guidelinenote_TechRisks.pdf

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