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TABLE OF CONTENTS

LIST OF FIGURES AND TABLES ................................................................................................................. 2

LIST OF ACRONYMS AND ABBREVIATIONS .............................................................................................. 3

SECTION 0.0: EXECUTIVE SUMMARY .................................................................................................... 4

0.1 INTRODUCTION ................................................................................................................................. 4

0.2 METHODOLOGY AND RESPONDENTS ...................................................................................................... 4

0.3 HIGHLIGHTS OF FINDINGS .................................................................................................................... 4

0.4 CONCLUSIONS AND RECOMMENDATIONS ................................................................................................. 5

SECTION 1.0: BACKGROUND, STUDY OBJECTIVES AND METHODOLOGY ................................................ 7

1.1 INTRODUCTION ................................................................................................................................. 7

1.2 BACKGROUND .................................................................................................................................. 7

1.3 PROBLEM STATEMENT AND STUDY OBJECTIVES ........................................................................................ 7

1.4 APPROACH AND METHODOLOGY TO THE STUDY ....................................................................................... 9

SECTION 2.0: OVERVIEW OF GHANA’S FINANCIAL SECTOR ................................................................... 11

2.1 INTRODUCTION ............................................................................................................................... 11

2.2 OVERVIEW OF GHANA’S FINANCIAL SECTOR .......................................................................................... 11

2.3 REGULATORY FRAMEWORK FOR THE BANKS AND NON-BANK FINANCIAL INSTITUTION ..................................... 13

SECTION 3.0: FINDINGS AND ANALYSIS OF RESULTS............................................................................ 15

3.1 INTRODUCTION ............................................................................................................................... 15

3.2 FINDINGS FROM DESK REVIEW ............................................................................................................ 15

3.3 FINDINGS FROM INTERVIEWS WITH SAVINGS AND LOANS COMPANIES .......................................................... 21

3.4 CLIENTS OF THE S&LS ....................................................................................................................... 26

3.5 NON-CLIENT RESPONDENTS ............................................................................................................... 41

SECTION 4.0: CONCLUSIONS AND RECOMMENDATIONS .................................................................... 49

4.1 INTRODUCTION ............................................................................................................................... 49

4.2 CONCLUSIONS ................................................................................................................................ 49

4.3 RECOMMENDATIONS FOR THE WAY FORWARD....................................................................................... 52

APPENDIX 1: RESPONDENTS PER INSTITUTION (MANAGERS) ................................................................. A

APPENDIX 2: INDIVIDUAL RESPONDENT DETAILS- NORTHERN REGION ................................................... B

APPENDIX 3: FOCUS GROUP RESPONDENT DETAILS- NORTHERN REGION ............................................... C

APPENDIX 4: FOCUS GROUP RESPONDENT DETAILS- GREATER ACCRA REGION ....................................... F

APPENDIX 5: INDIVIDUAL RESPONDENT DETAILS- GREATER ACCRA REGION ........................................... H

APPENDIX 6: FOCUS GROUP RESPONDENT DETAILS- ASHANTI REGION .................................................... I

APPENDIX 7: INDIVIDUAL RESPONDENT DETAILS- ASHANTI REGION ....................................................... K

APPENDIX 8: FOCUS GROUP RESPONDENT DETAILS- VOLTA REGION ...................................................... L

APPENDIX 9: FOCUS GROUP RESPONDENT DETAILS- EASTERN REGION .................................................. M

APPENDIX 10: QUESTIONNAIRE FOR CEOS AND MANAGERS OF S&LS ...................................................... N

APPENDIX 11: QUESTIONNAIRE FOR CLIENT FOCUS GROUPS AND INDIVIDUALS ....................................... P

APPENDIX 12: LITERATURE REVIEWED................................................................................................... S

LIST OF FIGURES AND TABLES

FIGURES

Figure 1: Financial Service Providers ............................................................................................................... 11

Figure 2: Growth in Loans & Advances and Deposits ...................................................................................... 19

Figure 3: Frequency in the Usage of Savings Mobilization Methodologies .................................................... 22

Figure 4: Confidence in FSPs ............................................................................................................................ 28

Figure 5: Respondent Willingness to do Business with Financial Service Providers ....................................... 29

Figure 6: Willingness to recommend FSPs to other clients ....................................................................... 30

Figure 7: Decision to stop doing business with FSPs ....................................................................................... 31

Figure 8: Differences between FSP Types ....................................................................................................... 33

Figure 9: Source of information on differences among various financial service provider types ................... 34

Figure 10: Awareness of Similarities between S&Ls and Other FSPs .............................................................. 35

Figure 11: Similarities between FSPs ............................................................................................................... 35

Figure 12: Confidence in FSPs (Individual Clients) ........................................................................................... 36

Figure 13: Willingness to do business with Service Providers (Individual Clients) .......................................... 37

Figure 14: Willingness to recommend Service Providers (Individual Clients) ................................................. 38

Figure 15: Decision to stop doing business with FSPs (Individual Clients) ...................................................... 40

Figure 16: Difference between FSP Types ....................................................................................................... 42

Figure 17: Effect on Choice of FSP ................................................................................................................... 42

Figure 18: Similarities between FSPs ............................................................................................................... 43

Figure 19: Non-client respondents’ confidence in FSPs .................................................................................. 43

Figure 20:Non-client willingness to do business with FSPs ............................................................................. 45

Figure 21: Non-client willingness to recommend FSPs ................................................................................... 46

Figure 22: Non-client decision to stop doing business with FSPs ................................................................... 47

TABLES

Table 1: Sample Size and Distribution of Savings and Loans Company Clients ............................................... 10

Table 2: Sample Size and Distribution of Non Savings and Loans Clients ....................................................... 10

Table 3: Savings and Loans Institutions vs. Microfinance Institutions ............................................................ 17

Table 4: Year-on-Year Growth ......................................................................................................................... 19

Table 5: Regional Distribution of Branches ..................................................................................................... 20

LIST OF ACRONYMS AND ABBREVIATIONS

BoG Bank of Ghana

FGD Focus Group Discussions

FSPs Financial Service Providers

GHASALC Ghana Association of Savings and Loans Companies

MFCs Microfinance Companies

MFIs Microfinance Institutions

NBFI Non- Bank Financial Institution

RCBs Rural and Community Banks

S&Ls Savings and Loans

SMEs Small and Medium Enterprises

SECTION 0.0: EXECUTIVE SUMMARY

0.1 Introduction

Savings and Loans Companies are financial institutions that specialize in accepting savings deposits and

giving out credit facilities to MSME and the low-income segments of the population. The Ghana Association

of Savings and Loans Companies is the umbrella association for all the Savings and Loans Companies. The

association exists to provide advocacy and other member services for savings and loans companies as well

as promote networking amongst them.

In order to understand the implications of the classification of savings and loans companies under the

Operating Rules and Guidelines for Microfinance Institutions issued in 2011, GHASALC commissioned a

survey that to provide more insight on the existing regulations and policies. The survey is also structured to

obtain insight into the perception of the public of Savings and Loans Companies; ascertain whether the

public regards Savings and Loans Companies as microfinance institutions as well as the degree to which

these perceptions affect the operations of the Savings and Loans Companies.

0.2 Methodology and Respondents

A mix of qualitative and quantitative methods was adopted for the study. Tool and techniques used

included desk review, individual in-depth interviews and focus group discussions. A total of four (4) savings

and loans companies were selected as case studies for the survey; five officials from Savings and Loans

Companies were interviewed to complement views already gathered from S&L CEO forum; thirty-six (36)

individual clients as well as eight (8) Focus groups comprising a total of one hundred and eleven (111)

respondents who are clients of Savings and Loans Companies were included in the survey. Non-client focus

group discussions covering a total of fifty-two (52) respondents were also carried out. Perceptions of clients

were rated using a six point scale from 0 -5 with ‘0’ indicating no idea and ‘5’ the highest rating.

0.3 Highlights of Findings

The study showed that majority of clients and non-clients of S&Ls do not know the differences between the

financial service provider types operating in the microfinance space. Respondents focused more on the

provider brand names such as “Opportunity”, “First Allied” and “Fidelity”, rather than provider categories

of “Microfinance Companies”, “Credit Union” and “Savings and Loans Companies.” Most of the

respondents do not even know the type of financial service provider they were transacting business with,

as they considered that, there are no real differences among the providers.

Clients of Savings and Loans Companies rated the Savings and Loans companies very high on confidence.

However, about 66% would be willing to change to a different provider category if made available, a

reflection of dissatisfaction with current offerings. The study also indicated that most clients are currently

dissatisfied with their financial services providers but have remained with these providers largely due to the

absence of better alternatives.

Respondents from the S&Ls do not consider the Microfinance Operating Rules and Guidelines as the cause

of the challenges faced by S&Ls in the microfinance arena. The concerns are rather towards the need for

the Regulator to bring microfinance companies to order; expand the range of services available to S&Ls and

need for S&Ls themselves to focus on improved product development and delivery.

0.4 Conclusions and Recommendations

0.4.1 Conclusions

The findings from the study indicate that by virtue of the target market served and delivery methodologies,

Savings and Loans Companies are microfinance providers offering a wide range of products which qualifies

them to be described as microfinance providers. However, the S&Ls also serve the SME segment which is

not the predominant market of microfinance institutions. The market served by Savings and Loans

Companies remain the same as those served by other microfinance institutions, further blurring the

differences between the S&Ls and other MFIs.

On the issue of whether the relevant laws and pronouncements lump Savings and Loans Companies

together with other microfinance institutions, the study did not find any direct evidence. Prior to the

introduction of the Operating Rules and Guidelines for Microfinance Institutions in 2011, S&Ls were

adequately regulated and supervised by the Central Bank and that has not changed to date. What the

guideline did is to recognise that, in addition to the microfinance institutions brought under the Operating

Rules and Guidelines there are other institutions that undertake microfinance activities which were already

regulated and therefore placed under Tier 1. Indeed the reference to Savings and Loans Companies and

Rural Banks as Tier 1 providers in the Operating Rules and Guidelines also did not change the mandate of

S&Ls in any way.

It is however obvious that although, the Savings and Loans Companies did not suffer any direct limitations

in terms of products and services offering as a result of the Operating Rules and Guidelines, the licensing of

deposit taking institutions as included in Tier 2, has resulted in increased number of microfinance

institutions that are aggressively operating in the same market as Savings and Loans Companies. The

concerns about unintended effects of the Operating Rules and Guidelines on the operations of the Savings

and Loans Companies are linked to the deposit mobilization mandate and how the deposits mobilized are

used by the microfinance institutions. The misapplication of deposits mobilised by some of the

microfinance companies has dented the image of Savings and Loans Companies and other actors in the

microfinance arena resulting in massive withdrawals and declining client confidence. These effects have to

be addressed through a combination of measures.

0.4.2 Recommendations

In response to the findings and conclusions, a number of recommendations are made:

There is need for continuous engagement between the various microfinance associations and Bank of

Ghana to work towards the sanitisation of the microfinance sector to ensure that their critical role in

enhancing financial inclusion is not compromised.

GHASALC and member Savings and Loans Companies need to work on carving a distinct image for

themselves in a rather competitive market. This can be achieved through the introduction of client

orientation and counselling programs that throw light on S&Ls; strong rebranding; commitment to

client needs and promises through strong research and innovative product development.

GHASALC needs to advocate for increased range of services offered by Savings and Loans Companies

through changes in regulation. GHASALC is encouraged to work with the Regulator to demand for

increased range of services to distinguish it from other MFIs; change in regulation to among other

things introduce ceilings on what Savings and Loans Companies can do under various scenarios of

capital requirements, so as to manage the differentiations between the microfinance institutions in Tier

2 (and below) on one hand and Savings and Loans Companies on the other hand.

Lobbying the Regulator for name change. This has come up a number of times and could be pursued by

the Association with the Regulator. This can be done by adding the name ‘Bank’ to the name Savings

and Loans as in ‘Savings and Loans Banks’ or ‘SME Bank’. It is however, important to state that a name

change alone will not change the market perception. A lot will be required on the part of the various

S&Ls in the areas of process improvement and responsiveness to client needs.

Other recommendations are on the need for GHASALC to work with the Regulator and other

stakeholders to among other things enforce microfinance industry code of conduct; create awareness

of industry trends and prioritise financial education for the general public to improve the level of

financial literacy. These combined actions will result in a more informed clientele and responsible

financial services providers in the microfinance space.

SECTION 1.0: BACKGROUND, STUDY OBJECTIVES AND METHODOLOGY

1.1 Introduction

The overall study focuses on assessing the effect of including Savings and Loans Companies among

microfinance institutions on client perception. Section 1 presents the background, goals and objectives of

the Ghana Association of Savings and Loans Companies (GHASALC) which is the promoter of the study; the

study problems and objectives; approach and methodology to the study.

1.2 Background

The Ghana Association of Savings and Loans Companies (GHASALC) is the umbrella body of savings and

loans companies in Ghana. Registered on September 5, 2008, under the Companies Code, 1963 (Act 179) as

a company limited by guarantee, the Association provides advocacy and other member services for Savings

and Loans Companies operating in Ghana. Over the past one year, GHASALC has organized a number of

events that brought CEOs of Savings and Loans Companies together to deliberate on their segment of the

industry. As part of its deliberations, the Board, Forum of CEOs and the Secretariat have identified a

number of constraints affecting the image and operations of savings and loans companies in Ghana which

has prompted a study as the current one.

1.2.1 Goals of GHASALC

The specific goals of GHASALC as provided in the documentations of the Secretariat are:

To promote networking amongst all Savings and Loans Companies.

To establish a common platform to ensure a sound business environment for effective and efficient

operations of Savings and Loans Companies.

To collaborate with government to formulate and implement industry friendly policies.

1.2.2 Objectives of GHASALC

GHASALC’s main objective is to initiate and support processes to address constraints faced by its members

in the promotion and financing of low-income and micro entrepreneurs, as well as provide assistance to its

members to develop the appropriate products for their respective clients.

GHASALC has outlined the following as its core strategic objectives:

To improve governance capacity of GHASALC to exercise strategic, supervisory and management development roles;

To contribute to the development and strengthening of the savings and loans sector to improve the livelihood of their clients;

To engage in advocacy and dialoguing on behalf of its members.

1.3 Problem Statement and Study Objectives

Savings and Loans Companies constitute a key segment of Ghana’s financial sector providing services to the

various sectors including micro and small businesses. Over the years, Savings and Loans (S&Ls) Companies

have come to be associated with the microfinance sector given that they provide critical services to micro

and small businesses especially in the urban and peri urban areas. The main actors in the Savings and Loans

arena are of the view that the lumping of Savings and Loans together with other microfinance providers is

affecting the image and fortunes of their businesses given reported cases of unethical practices by some of

the microfinance providers.

The study aims at providing insight into the effect of including Savings and Loans Companies among

microfinance institutions on client perception and operational performance of S&Ls. Together with other

providers such as Rural and Community Banks, the Savings and Loans Companies are categorized as part of

Tier 1 Microfinance Providers as per the Bank of Ghana’s Notice to Banks, Non-Bank Financial Institutions

and the General Public (Notice No. BG/GOV/SEC/2011/04). This categorization according to some actors on

the Savings and Loans landscape has created the impression that savings and loans companies are

microfinance institutions. As a result the S&Ls are seen by a section of the public purely as microfinance

providers and in some instances are equated to Microfinance Companies (Tier 2 Providers).

The above perception, according to GHASALC and its members, has not served the interest of Savings and

Loans Companies well and there are concerns that the challenges faced by some of the microfinance

institutions as observed in recent years is having adverse effect on the reputation and operations of Savings

and Loans Companies.

The specific objectives of the study are to:

Help the Savings and Loans Companies to understand the core problem through an in-depth analysis

into the existing regulation and policies.

Address the unintended effects of the existing ACT/ regulation on the operations of Savings and Loans

Companies and other industry / sector players in the microfinance sector who are not “microfinance

companies”.

Identify the effects or repercussions of such regulation on the government and the country as a whole

such as reduction in taxes paid due to shrinking profits of the microfinance sector as a result of loss in

client confidence in Microfinance Sector or Industry.

Identify the effects on the industry as a whole, mostly as in how many Savings and Loans companies

and their clients are being affected.

Indicate the breadth of the problem currently in the eyes of various stakeholders in order to know the

partners to include in our stakeholder dialogue stage.

Provide GHASALC with an effective tool/or basis to conduct a stakeholder campaign to sensitize

members and the general public of the advocacy initiative.

Provide an objective basis for the next steps to be taken with respect to the direction of the Savings

and Loans Companies and GHASALC as to whether to seek for an amendment in the regulation or other

alternative actions/options to pursue.

Facilitate the identification of complexities and misunderstanding of the microfinance sector (non-banking financial sector) within the regulation if any.

Provide insight into whether Savings and Loans companies are in fact among the Microfiance sector or not ( compared to the international best practices)

1.4 Approach and Methodology to the Study

The study was designed around a mix of qualitative and quantitative research methodologies. The

qualitative methodology was designed to obtain in-depth information from selected individuals, industry

stakeholders, clients and managers of sampled Savings and Loans Companies to serve as input for the

perception analyses. In pursuance of this, one-on-one in-depth interviews and focus group discussions

were held with clients and non-clients of savings and loans companies and staff of Savings and Loans

companies.

Desk review formed an important segment of the overall methodology to ensure that adequate and

relevant literature on the study is covered. Financial statistics obtained through secondary sources were

analysed to understand the extent to which the concerns that microfinance institutions are affecting the

operations of savings and loans companies can be verified.

The study was organised into three (3) main steps as follows:

1.4.1 Literature Review, Questionnaire Design and Sampling

Literature Review: Literature review entailed initial desk review of industry documentation on regulation,

publications on currents status of the industry, review of minutes and discussions at S&L CEO Forum. Other

documentations reviewed include the Operating Rules and Guidelines for Microfinance Institutions and

literature on savings and loans operations as a whole. The focus is to extract relevant information for

addressing the key issues and facilitate research instrument design.

Questionnaire Design: This entailed the design of structured and unstructured instruments to facilitate

conduct of the various interviews and focus group discussions.

Sampling: The main respondent categories were clients of savings and loans companies; non-clients of

savings and loans companies; staff of savings and loans companies. Using these respondent categories, the

study team used “convenience and judgement approaches” as the basis for selecting locations for the

interviews. To attain geographical spread, the team settled on three regions, Greater Accra Region, Ashanti

Region and Northern Region. The Association of Savings and Loans Companies’ secretariat was asked to

support the identification of one Savings and Loans Company from each of the locations. Through this

process, four (4) Savings and Loans Companies were selected. The locations and branches visited are

presented in Table 1.

In each of the selected institutions, interviews were held with managers and clients of the institutions.

Client interviews were held at two levels of individual in-depth interviews and engagement of clients

through focus group discussions. A total of eight (8) focus group discussions covering one hundred and

eleven (111) participants were held in the three regions. Table 1 depicts the sample size and distribution of

savings and loans clients interviewed.

Table 1: Sample Size and Distribution of Savings and Loans Company Clients

Institution Region Location of Branch

Sample Size

FGD Individual Clients

Opportunity International Greater Accra Region

Accra & Nungua

2 10

First Allied Savings and Loans

Ashanti Region Kumasi 2 7

UTRAK Savings and Loans Northern Region Tamale 2 10 SINABI ABA Savings and Loans

Ashanti Region Konongo 2 9

Non savings and loans company clients were selected from towns in the Northern, Eastern and Volta

Regions. Table 2 presents the towns and number of focus group discussions held. A total of 52 participants

were covered in the non-client focus groups.

Table 2: Sample Size and Distribution of Non Savings and Loans Clients

Region Town Sample Size

Number of FGDs Northern Region Tamale 2 Eastern Region Anum Apapam 1 Volta Region Anloga 1

1.4.2 Interviews and In-depth documentation review This entailed the conduct of interviews at all the locations as noted in tables 1&2 above. In all, a total of one hundred and forty-seven (147) clients and fifty-two (52) non clients were interviewed. A total of five officials from Savings and Loans Companies were included in the in-depth interviews to obtain additional insight on the perceptions relating to the current challenges of savings and loans companies. The study also took notice of the minutes on previous meetings held by the S&L CEOs forum to reflect the main issues that have been of concern to savings and loans companies. 1.4.3 Analyses and Report Writing Analyses and report writing focused on reviewing the interview notes and focus group discussion feedback

along the objectives of the study to ensure that responses and feedback are structured for inclusion in the

report.

SECTION 2.0: OVERVIEW OF GHANA’S FINANCIAL SECTOR

2.1 Introduction

Section 2 presents an overview of Ghana’s financial sector within which microfinance providers and savings

and loans companies operate. The overview provides a brief discussion on the key provider categories;

spread of providers; legal and regulatory framework. The section further discusses the role and

performance of savings and loans companies in the wider financial sector as well as their contribution to

the Ghanaian economy.

2.2 Overview of Ghana’s Financial Sector

Ghana’s financial services sector is classified into three main categories of banking and non-banking

financial institutions, insurance and capital markets. The sector has shown significant development over the

past decade with increased number of providers and wide array of products and services. The main

categories of providers under the banking and non-banking financial actors are banking, non-banking and

microfinance institutions. Figure 1 presents a graphical depiction of the providers, their members and

outlets.

Figure 1: Financial Service Providers

2.2.1 Banking and Non- Banking Financial Institutions

The Banking Institutions are classified into Universal Banks and the Rural and Community Banks. There are

currently thirty (30) universal banks and one hundred and forty-three (143) Rural and Community Banks

operating in Ghana.

Banking Institutions

Universal Banks: Ghana currently has a total of thirty (30) universal banks with an estimated nine hundred

and sixteen (916) branches operating in all 10 regions of Ghana. The Universal banks mobilize funds,

provide risk management services and serve as financiers of government, large enterprises, medium and

small scale enterprises as well as individuals. The main products and services include savings products;

investments; personal and business loans; money transfer and payment services. A limited number of

institutions offer mortgages for new home acquisition and others offer home improvement loans. With a

growing deficit in housing stock and increasing income level for a segment of the population, mortgages

and home improvement loans are becoming common products from universal banks.

Rural and Community Banks: The Rural and Community Banks (RCBs) are special small-scale banks

generally owned by members of the community and district in which they operate. Current statistics

indicate there are one hundred and forty-three (143) Rural and Community Banks with a total of six

hundred and fifty-one (651) agencies1 distributed countrywide. RCBs offer savings, credit, investment,

remittances and money transfers. The specifics include various types of savings products such as susu

savings, savings towards specific goals such as children’s education, trading and business asset acquisition.

Credit includes agricultural loans, business loans, consumer loans, education loans, microenterprise loans,

susu credit and other household microfinance loans. Some RCBs in collaboration with insurance companies

are providing microinsurance policies underwritten by the insurance companies. Many RCBs have also set

up separate departments or desks to focus on development and delivery of microfinance services and

products.

Non-Banking Financial Institutions

The Non-Bank Financial Institutions (NBFIs) category include financial service providers such as Savings and

Loans Companies, Leasing Companies, Finance Houses, Mortgage Companies, Credit Reference Bureaus

and a number of government sponsored development finance companies. Available statistics indicate that

there are 58 NBFIs operating in Ghana. Analyses of the number of institutions and their networks are

presented2:

Twenty-four (24) Savings and Loans Companies have over four hundred (404) branches country wide;

Twenty-five (25) Finance Houses mostly with head office in Accra, Tema and Kumasi with branches in selected regional capitals;

Three (3) Credit Reference Bureau;

Two (2) Leasing Companies;

Three (3) Finance and Leasing Companies and

One (1) Mortgage Finance Company.

NBFIs serve both the formal and informal sectors with savings, loans, asset financing, asset management

and investment products in accordance with individual provider mandate.

Savings and Loans Companies Ghana currently has twenty-four (24) savings and loans companies providing varieties of savings, investment and loan products. Savings products common to all the companies are mostly operated as current or savings accounts. Others operate hybrid (current and savings) accounts, susu deposits and investments accounts (fixed deposit). Savings Products are designed for all categories of clients which include children, women and individuals operating in various sectors of the economy.

2 Individual websites

Loan products are generally categorized as either business or personal loans. The products are targeted at

individuals and groups and businesses such as churches, schools (students) and agribusinesses. Services

include money transfers, internet banking, western union money transfers and TiGO cash among others.

Private individuals own the S&L Companies, which are registered and licensed under the NBFI Law and are

permitted to offer banking services limited mainly to loans, savings and fixed deposits.

2.2.2 Insurance

Ghana's insurance market has about 46 companies operating in the market, including branches of

international companies. The Insurance Companies under the auspices of the National Insurance

Commission (NIC) have experienced changes focused on improving ability to take on increased risk. The

Industry comprises 26 Non-Life Insurance Companies; 20 Life Companies; 4 Reinsurance Companies.

Insurance Companies (non-life) offer a range of products including Liability policies; Engineering policies;

Marine policies and Motor Insurance. Life Insurance Companies offer products targeted at both formal and

informal sectors. Insurance companies are partnering with other businesses such as mobile network

operators to provide micro insurance under paid for and loyalty arrangements.

2.2.3 Capital Market

Capital markets are markets for securities (debt and equity), where business enterprises such as companies

and governments can raise long-term funds. Ghana’s capital market, since its establishment has gone

through various stages of development. The capital market currently lists thirty-eight (38) equities

consisting of thirty-six (36) companies and two (2) bonds.

2.3 Regulatory Framework for the Banks and Non-Bank Financial Institution Discussions on the broad regulatory framework for the industry is presented in three (3) sections namely

the Banking regulations, the Non-Banking Financial Institutions regulations and Regulation of the Savings


2.3.1 Overview of the regulatory framework for banking institutions

Bank of Ghana regulates the universal banks in Ghana through the Banking (Amended) Act, 2007, Act 738;

the Banking Act 2004, Act 673; the Bank of Ghana Act 2002, Act 612; Banking and Financial Laws of Ghana.

These laws specify for operators in the banking sector, the terms and conditions of operating as a bank in

Ghana under the various categories; the mode of operations; mandatory activities and business

transactions that are permitted.

The Banking Supervision Department (BSD) of Bank of Ghana supervises RCBs and their Apex Bank directly,

notwithstanding the provision in the ARB Apex Bank Limited’s Regulation that, the ARB Apex Bank shall

inspect and supervise the management and operations of the RCBs for the purpose of complementing the

supervisory work of the BoG.

Bank of Ghana regulates the universal banks in Ghana through the Banking (Amended) Act, 2007,

Act 738; the Banking Act 2004, Act 673; the Bank of Ghana Act 2002, Act 612; Banking and

Financial Laws of Ghana.

Apex Bank has the power to examine and analyse the prudential returns, monitor capital adequacy ratios as

well as minimum capital requirements of the RCBs. ARB Apex Bank is also empowered to issue directives to

RCBs as a group or to particular RCBs where considered appropriate. These activities by the Apex Bank

contribute to ensuring that RCBs operate within stipulated guidelines that protect the interest of depositors

and shareholders.

2.3.2 Non-Banking Financial Institutions

The Bank of Ghana regulates the operations of the non-bank financial service providers through the rules

and guidelines for microfinance institutions under the Non-Bank Financial Institutions Act, 2008 (Act 774)

and the Banking Act, 2004 (Act 673) as amended by Act 738.

2.3.3 Overview of Microfinance Regulation The microfinance sector in Ghana up until 2011 was without specific guidelines for licensing and

supervision. The BoG in July 2011 issued Operating Rules and Guidelines for Microfinance institutions

including licensing requirements which provides the basis for microfinance sector regulation and

supervision. These rules and regulations were developed to:

bring sanity into the sector;

ensure the safety of depositors’ deposits;

maintain the solvency, good quality of assets, adequate liquidity and profitability of the financial sector

ensure the maintenance of an efficient payment system

bring clarity in the various operations of the different institutions and also properly define their

mandates and restrictions.

By virtue of the operating rules and guidelines for microfinance institutions issued through notice number

BG/GOV/SEC/2011/04, in pursuance of the provisions of the Non-Bank Financial Institutions Act, 2008 (Act

774) and the Banking Act, 2004 (Act 673) as amended by Act 738, RCBs, Savings and Loans Companies and

other financial intermediaries already regulated under the Banking Act are to remain so regulated. All other

intermediaries such as Susu Companies and Collectors, Money Lenders and Financial NGOs came under the

requirements of the notice.

The Bank of Ghana has established a Microfinance outfit with specific focus on supervision of microfinance

institutions especially those in Tiers 2, 3 and 4. The department with responsibility for the supervision of

the other microfinance institutions is “Other Financial Institutions Supervision Department”. The

department supervises the Tier 2 providers directly and has made arrangements with the respective

provider associations to coordinate and conduct monitoring of providers in Tiers 3 and 4.

SECTION 3.0: FINDINGS AND ANALYSIS OF RESULTS

3.1 Introduction

Section 3 presents the findings and analysis from the study. It is organised into four (4) subsections of:

Findings from desk review;

Findings from S&L interviews;

Findings from clients of S&Ls;

Findings from non-clients of S&Ls.

3.2 Findings from Desk Review 3.2.1 Definition of Microfinance Critical to the study is the question of definition of microfinance. This is central to the problem statement

which revolves around the effect of including savings and loans companies among microfinance institutions

in Ghana.

Institutions providing microfinance services have over the years provided their respective demarcation and

definition of what constitutes microfinance largely based on a combination of methodology adopted for

credit delivery and size of credit provided. The standard microfinance terminology within the United

Nations System states that Microfinance encompasses the provision of financial services and the

management of small amounts of money through a range of products and a system of intermediary

functions that are targeted at low income clients3. It includes loans, savings, insurance, transfer services

and other financial products and services. Microcredit is one of the critical dimensions of the broad range

of financial tools for the poor.

In Ghana, the Non-Bank Financial Institution (NBFI) Act, 2008 Act 774 states under its interpretation that

microfinance services means “financial services provided by institutions however organised whether as

companies limited by guarantee, limited by liability or unlimited, non-governmental organisations,

cooperatives or cooperative societies, rotating savings and credit associations or groups ……. providing

loans not exceeding an amount determined by the Bank to a single borrower….”4. The operating guidelines

issued in 2011 identified four tiers of providers who undertake microfinance activities.

The key determinants of whether an activity is a microfinance activity or not can therefore be explained

from various angles especially the target market, size of transactions, methodology. There are no specific

limits provided on transactions that qualify as microfinance.

3.2.2 Policy Focus

Government considers financial inclusion a major focus area that needs well defined, coordinated and

targeted effort to increase outreach. In determining who is a microfinance institution or provider, there will

be need to consider the target market and transactions involved so as not to exclude key actors. In

determining whether there are specific financial institutions classified as microfinance institutions, a

number of relevant documents were reviewed. The Ghana Microfinance Policy Document sighted has

3 United Nations, Concept Paper: Building Inclusive Financial Sectors to Achieve the Millennium Development Goals (International

Year of Microcredit, United Nations, 2005) 4 Section 46 of the Non- Bank Financial Institutions Act 2008, Act 774

included in its listing of microfinance institutions in Ghana “savings and loans companies”. The Financial

Sector Strategic Plan II (FINSSIP II) in its presentations on Savings and Loans Companies used a dual

approach. In the first instance it discusses the Savings and Loans Companies as a standalone group5 and in

the second instance, mentions savings and loans companies as one of the common microfinance

institutions under its discussion of Micro-Finance Institutions (MFIs). It is insightful to note that under its

listing of MFIs in Ghana, FINSSP II also listed “Microfinance units of the mainstream banks”. This is a

reflection of the wide array of providers on the microfinance landscape and the fact that an institution does

not need to be licensed directly as a microfinance institution to be recognised as undertaking microfinance

activities.

It is obvious that, the government considers savings and loans companies as critical partners in enhancing

financial inclusion. This is demonstrated through the various initiatives that have included savings and loans

companies. The Association of Savings and Loans Companies for example and some members of the

association have benefited from technical assistance interventions implemented under the Rural

Agricultural Finance Programme and other government bilateral interventions, a reflection of the role of

savings and loans companies in promoting rural and low income finance.

3.2.3 Modus Operandi of Savings and Loans versus Microfinance Institutions

In developing the foundation for identifying distinctions between savings and loans companies and other

microfinance institutions, the study team reviewed existing documentation on mode of operations adopted

by the key providers. Available literature indicate that Savings and loans companies operate almost as

universal banks do, but are restricted from carrying out services such as cheque clearing and foreign

transactions. Savings and loans companies however, provide other services that universal banks will

generally not offer such as financial literacy training.

When compared to the microfinance institutions, the difference however is minimal. The only visible

difference is the difference in interest rates for credit facilities. The Savings and loans institutions also

extend credit facilities to the microfinance institutions, and therefore the interest rates of the S&Ls are

lower as compared to the Microfinance institutions.

Table 3 presents the operations of both the savings and loans companies and the other main microfinance

providers. The obvious difference is in the minimum capital requirements pegged for each provider

category followed by permissible services. The savings and loans companies for example have a higher

minimum capital requirement than that of the microfinance institutions.

5 Section 2.9, page 30 FINSSP II

Table 3: Savings and Loans Institutions vs. Microfinance Institutions

Operations Savings and Loans

Institutions

Microfinance Institutions

Microfinance Companies

Credit Unions

Rural and Community Banks

Financial Non-Governmental Organizations

Money Lenders Susu Collectors

Minimum Capital requirement

6

GHC 15 million GHC 100,000 revised to GHC 500,000 for new registrants

GHC 100,000 revised to GHC 500,000 for new registrants

GHC 300,000 GHC 60,000 revised to GHC 300,000 for new registrants

GHC 60,000 revised to GHC 300,000 for new registrants

Contribution to an insurance Fund ( amount determined by the association)

Mandate Deposit collection

Credit

Investments

Clearing, direct foreign transfers and other forms of international trade through our partnering banks

In-house cheque clearing

Deposit collection

Credit

Investments

Deposit collection

Credit

investments

Deposit Collection

Credit

Investments

Credit Credit Deposit collection

Target market Traders

Small business

Individual businesses

Private and public workers

Artisans

Microfinance companies

Money lenders

Traders

Small and medium sized businesses

Private and public workers

Artisans

Community based members;

Faith based members;

Workplace based members- members however cut across formal and informal sectors.

P

ublic and

Private

workers in

rural

settings;

Micro and small

businesses;

Individual businesspersons.

Rural and urban poor economically active clients,

Market women,

Artisans, amongst other informal businesses.

Rural and urban clients;

Formal and informal businesses and individuals.

Rural and urban poor economically active clients,

Market women,

Artisans, amongst other informal business owners.

Products and Services

Savings

Loans

Investments

Savings

Loans

Fixed deposits

Microinsurance products

Asset Financing

Savings

Loan

Current Accounts

Savings Accounts

Credit / Overdraft

Money Transfers

Microfinance Program (Susu Loans)

Loan

Voluntary Savings

Training and Education

Youth savings

Deposit guarantee scheme

Field service

Savings

Delivery On-Site /Direct Service On-Site /Direct On-Site /Direct On-Site /Direct On field Group On-Site /Direct On-Site /Direct

6 Regulator Notices

Operations Savings and Loans

Institutions

Microfinance Institutions

Microfinance Companies

Credit Unions

Rural and Community Banks

Financial Non-Governmental Organizations

Money Lenders Susu Collectors

methods Delivery

Group Formation

Field Banking/ Agents

Point of Sale Devices for Savings Mobilization

Group loans

Individual loans

Service Delivery

Group Formation

Field Banking/Agents


Group loans

Individual loans

Service Delivery

Group Formation



Service Delivery

Group Formation



Formation and Service Delivery

Onsite delivery

Service Delivery

Service Delivery



Electronic services

ATM

SMS

Money Transfers

Internet Banking

POS Devices

SMS

POS Devices

POS Devices POS Devices N/A N/A POS devices

3.2.4 Operational Performance of Savings and Loans and Contribution to the Economy

In assessing the extent to which the activities of microfinance institutions might have impacted the

operations of Savings and Loans Companies, the study analysed changes in the loans and advances of

Savings and Loans Companies over the past five (5) years. The statistics derived from the BoG website was

adjusted using consultant estimate of the proportion of the NBFI asset base attributable to Savings and

Loans Companies7.

Deriving from the estimated statistics, Loans & Advances increased from GHS 311 million to GHS 1,318

million between 2010 and 2014. Deposits also increased from GHS 525 million to GHS 1,880 million within

the same period. Figure 2 presents the estimated growth in Loans & Advances and Deposits in the Savings

& Loans industry.

Figure 2: Growth in Loans & Advances and Deposits

*Based on consultant estimates

Although the balances with respect to loans and deposits have experienced growth, the percentage

changes have fluctuated and showed decline in some cases. The detailed analyses of the percentage

changes in Loans & Advances and Deposits between 2011 and 2014 are presented in Table 4.

Table 4: Year-on-Year Growth

Year-on-Year Growth (%)*

2011 2012 2013 2014

Loans & Advances 29% 72% 36% 40%

Deposits 58% 34% 22% 39%

*Based on consultant estimates

Contribution of Savings and Loans to the Economy

Contribution of savings and loans companies to the economy is indicative by the changes in loans and advances. Savings and Loans Companies are serving micro, small and medium sized enterprises as well as individuals with both loans and savings products through wide branch network of four hundred and four (404) branches. The geographical breakdown of the branches is presented in Table 5.

7 Consultant estimate using 2013 consolidated data on S&Ls, BoG Annual Report (2013) and the 2013 Ghana Banking Survey

Report. It was derived from these sources that S&Ls account for about 5% of the banking industry.

Table 5: Regional Distribution of Branches

Regional Distribution of Branches8

Greater Accra

Ashanti Western Eastern Central Volta Northern Brong Ahafo

Upper East

Upper West

192 85 34 20 31 4 6 25 4 3

The target market for Savings and Loans companies is mostly but not limited to the urban informal

sectors of the country. This is mostly made up of micro and small- scaled enterprises (producers,

wholesalers, retailers and consumers), petty traders, small business and individual businesses,

private and public workers. These clients, constitute about 85% of the workers in the country, and

are mostly made up of women. The informal sector even though seen as insignificant, together drives

the economy of the nation and can allow a large proportion of the population to escape extreme

poverty and earn an income that is satisfactory for survival. The institutions also give credit

facilities to the other financial service providers in the sector, such as the Money Lenders and

Microfinance Companies in order for them to serve their target markets and stay in operation.

3.2.5 Selected International Practices

Literature review indicates that in countries such as Uganda and Kenya, financial service providers’

equivalent to savings and loans companies in Ghana are regulated as microfinance institutions. Other

countries like Bolivia and countries in Asia regulate all financial service providers under Bank and Financial

entities Law and Banking Legislation Laws respectively.

In Uganda, microfinance institutions are classified as financial institutions and as such are regulated under

the financial institutions Act 2004. Unlike Ghana, these financial institutions are not classified as banking or

non-banking institutions. However, in comparison, regulations are also classified under 4 Tiers. The

regulation of savings and loans type of providers in Uganda is classified under the Tier2 category.

Institutions in this category are also classified as ‘Microfinance Institutions’. They operate like the Banks but

with a few restrictions on the operations they can perform. They offer both savings and loan products but

they can neither operate cheque/ current accounts nor be part of the BoU Clearing House. Like banks, they

are permitted to conduct microfinance business since they are already sufficiently capitalized and meet the

requirements for taking deposits provided for in the Act.

In Kenya, MFIs are regulated under the Microfinance (Deposit-taking Microfinance Institutions) Act (2006)

and are classified under two types: Deposit –taking and Non-deposit taking MFIs (otherwise known as

Credit only MFIs). In comparison with Ghana, deposit taking MFIs are equivalent to the savings and loans

institutions. These institutions are licensed to carry out deposit-taking microfinance business countrywide.

In Asia however, all financial institutions are generally regulated under the banking legislation and

supervised by central banks. In contrast to Ghana, microfinance and semiformal institutions like NGO-MFIs

(equivalent to savings and loans) are regulated by either an apex organisation or other government body.

8 Derived from the GHASALC website, BoG website and websites of various S&Ls

3.3 Findings from Interviews with Savings and Loans Companies

Interviews with sampled savings and loans companies focused on assessing the extent to which they

consider the lumping of savings and loans companies with microfinance institutions as having a toll on their

operations. The results of the interviews are presented along five (5) dimensions of:

1. Products and services

2. Delivery methodology

3. Assessment of the effect of other MFIs on the S&L operations

4. Client trends

5. Improving and Making Distinct the Image of Savings and Loans Companies.

3.3.1 Products and Services Products offered normally by savings and loans companies are savings, loans and investment. The names of

these products and services however, vary from company to company. These products are mostly tailored

to meet the needs of their clients. Specialised products such as incremental housing loans and institutional

loan products are offered by some of the savings and loans companies.

Features of Products and Services

Products and services of the S&Ls are designed to meet the needs of the specific target markets which

include women engaged in sectors such as trading, services (hairdressers, dressmakers, beauticians etc.),

small scale manufacturing, agriculture (animal husbandry, vegetable growers and sellers, etc.) and food

services. Loan products are also designed to meet the characteristics of targeted clients such as individuals,

small and medium sized enterprises. On whether there are differences between products and services

offered by the savings and loans companies and those offered by microfinance institutions, the

respondents noted the main differences as:

- S&Ls offer lower interest rates compared to microfinance institutions;

- S&L loans are designed to suit client needs. The S&L determines the purpose for which the money is

being borrowed after which the client is educated on how best to use the money;

- Institution of background checks before loans are disbursed;

Analyses of the products and services offered by the S&Ls compared to those offered by the other

microfinance providers especially by the microfinance companies (Tier2) indicate that product categories

are generally the same. However, product features such as interest rates, loan sizes and loan tenure differ

with savings and loans companies offering more generous product features.

3.3.2 Delivery Methodology

The delivery methodologies used by savings and loans companies comprise a broad range of methodologies

in reaching clients. These include onsite or direct service delivery, group lending methodologies, field

banking, point of sale devices for savings mobilization, ATMs, SMS, money transfers and internet banking.

Further analyses of delivery methodologies are presented along the following dimensions:

- Methodologies for savings mobilization;

- Client training methodology and contents;

- Credit Product delivery methodology.

Methodologies for Savings Mobilization

Methodologies used by savings and loans companies for savings mobilization include market raiding,

compulsory savings, walk-in clients, use of mobile bankers and media as well as fixed deposits. Figure 3

presents the methodologies reported by the sampled companies.

Figure 3: Frequency in the Usage of Savings Mobilization Methodologies

The results indicate that the most used methodologies for savings mobilization as reported by the sampled

companies are mobile bankers, market-raiding and walk-in clients.

For some savings and loans companies, group methodology is used to mobilise over 55% of savings.

Individual savings and investment instruments are the other methodologies adopted. The group

methodology is a well-known practice adopted by many microfinance institutions especially the Financial

NGOs. It is also popular with Rural and Community Banks. The use of the methodology is seen as defining

microfinance and institutions which use this methodology are more likely to be seen as microfinance

institutions. On the basis of methodology used for savings mobilization, there are no differences between

the practices of savings and loans companies and other microfinance institutions especially the Tier 2.

Client Training Methodology and Contents S&Ls use the group training methodology to train their respective clients. Respondents were asked whether

the training modules explain the differences between S&Ls and other types of Financial Service Providers.

Out of four (4) S&Ls who provided responses to this question, three (3) indicated they engage in the group

training methodology. Two (2) respondents said they organize sessions that focus on establishing the

difference between S&Ls and other financial service providers. One respondent said that the company

makes this distinction by informing clients during these sessions that while S&Ls undertake savings

mobilization, other financial providers do not carry out saving mobilizations. Another respondent added

that educational videos are played in the banking halls to educate clients on the difference between the

S&Ls and other providers.

Interviews established that although some field staff may make efforts to explain differences among the

providers to their clients, these are not well documented in the training modules used for client training

such as group based training. The focus for a number of institutions is on financial literacy, group formation

and group dynamics.

Credit Product Delivery methodologies

S&Ls adopt a range of methodologies for the delivery of credit products. These include individual and group

methodologies. Two (2) out of four (4) respondents indicated that they use both individual and group

lending methodologies to providing loans. Features that respondents believed differentiate their delivery

methodologies from microfinance institutions include:

Provision of advisory services to clients;

One S&L indicated that it ensures that groups that take loans have a constitution and separate

accounts for all members;

While other financial service providers offer group loans though group leaders, a respondent

indicated that his institution ensures that members of the group gather before money is disbursed.

In his view, this ensures safety and allows for effective monitoring of clients usage of money;

While other institutions give out cash to clients by hand, one S&L indicated that the institution

disburses group loans into client accounts.

There is a general consensus from the interviews that products offered by most savings and loans

companies on one hand and other microfinance institutions on the other hand are largely the same

except in limited cases where savings and loans companies offer institutional loans to other

microfinance institutions. With respect to product features, respondents from the savings and loans

companies indicated that product features constitute a key area of distinction. The typical microfinance

institutions that mobilize savings are said to quote unsustainable interest rates (averaging five times

what is offered by the savings and loans companies) on their deposit products and offer other rewards

which can simply not be sustained. Given that interest rates are not regulated, these “attractive

interest rates” resulted in reduction in deposits of Savings and Loans Companies as some clients even

withdraw their savings to place them with the microfinance companies. The respondents were of the

view that this practice has the potential of affecting financial sector stability. They also indicated that,

without regulation, there will not be any significant differences between products of savings and loans

companies and the other microfinance institutions. The current practices, coupled with limitation on

products and services is compelling savings and loans companies to transform into Universal Banks.

Respondents expressed the fear that this may also have adverse consequences for SMEs.

3.3.3 Effect of Other MFIs on Operations of S&Ls

The study sought to find out from the Managers of the selected S&Ls the specific ways in which their

operations have been impacted by the operations of microfinance institutions. Respondents indicated that

the operations of microfinance institutions have resulted in increased competition in the market and the

indebtedness of their clients. Respondents also noted that certain actions of other microfinance institutions

have also contributed to reduced client patronage of S&L products as well the reputation of S&Ls. Specific

issues listed by respondents as microfinance institution actions having effect on savings and loans

companies are presented:

High interest rates charged by other microfinance institutions discourage clients from accessing loans.

As a result, discouraged clients who do not know the differences among the various financial service

providers are discouraged from accessing loans entirely thus hindering efforts to increase client base.

Cases of longer repayment duration and high savings rates offered by some microfinance institutions

has led to customers shunning savings and loans companies to do business with microfinance

institutions.

Duration of client training prior to accessing loans in some of the microfinance institutions is very short

and sometimes non-existent compared to the training period by some of the savings and loans

companies. This relative longer training duration which is to ensure that clients have good

understanding of loans and borrowing that ensure effective utilisation of loans serves as a disincentive

for S&L clients who make this comparison and find it more convenient to access loans quickly from

other MFIs without having to go through training and orientation.

The collapse of some microfinance institutions has also affected clients’ confidence in all financial

institutions, including S&Ls.

Unprofessional activities of microfinance agents and the inability of certain microfinance institutions

to sustain their operations have led to the collapse of some microfinance institutions and decreased

confidence in the microfinance industry. According to a respondent, it is more difficult to attract bigger

investments because S&Ls are classified as microfinance institutions.

Proximity to Other MFIs

Interviews with sampled S&Ls revealed that there are other microfinance providers that operate in

proximity to branches of S&Ls. This in the view of respondents creates competition and conflict. In all, three

(3) out of four (4) respondents indicated that their branches are in proximity to other financial institutions.

Out of this number, two (2) respondents had experienced conflicts due to their proximity to other financial

service providers. One respondent related an instance where a conflict occurred between the S&L and

another financial institution that operated from the same premises. The other financial institution felt that

the S&L was poaching its clients and had to move out of the building to resolve the issue.

In another instance, close proximity of a financial institution created conflicts between the staff of the S&L

and that of the microfinance institution. The conflict occurred because the microfinance institution accused

staff of the S&L of discrediting their operations whenever they undertake client education. To resolve the

conflict, an inter-institutional meeting was held where both institutions (S&L and microfinance institution)

agreed on an approach to educating clients in a neutral way. It is however, worth noting that the

microfinance company eventually collapsed and the related reputational challenges resulted in a loss of

about 50% of the S&L clients.

3.3.4 Clients dealing with multiple providers

Respondents from the savings and loans companies were asked of the extent to which their clients also

transact business with other microfinance institutions. Out of the four (4) Managers interviewed, two (2)

indicated that between 5% and 50% of their respective client portfolios have dealings with other

microfinance institutions. S&Ls indicated that they enquire from clients during account opening and

orientation if they hold accounts with other service providers. Such information is used for purposes such

as research and product development; customer assessment; loan appraisals; Know Your Customer (KY)

purposes and to trace clients when the need arises.

In determining specific trends, the interviews with sampled S&Ls probed to understand the behavioural

trends of clients with single accounts as compared to clients who deal with multiple providers Two (2) out

of four (4) respondents indicated that they had noted savings and loan repayment patterns. Both noted

that clients saving with multiple providers are not consistent in making savings deposits while clients saving

with one service provider saved more frequently. One respondent indicated that clients who save

infrequently mostly miss payment dates for their periodic “susu” contributions and never meet the

individual or group savings targets.

Similarly, clients saving with different institutions are not consistent in repaying loans compared to clients

saving at only one institution. The main reason provided by respondents was that clients with multiple

savings accounts in different financial institutions usually have to pay back several loans and never have

enough money left to save leading to less savings balance from which to make periodic loan repayment

deductions.

3.3.5 Improving and Making Distinct the Image of Savings and Loans Companies

Respondents were asked to make suggestions on how to improve the image of savings and loans

companies and carve distinct image in the market place. The discussion was structured in three parts as:

the role of the individual savings and loans companies; the role of GHASALC and the role of the Regulator.

The Expected Role of the S&Ls

Savings and loans companies have a role to play in improving and contributing towards a more distinct

image for themselves. Proposals include the organization of activities or events that project the image of

S&Ls in a positive light; employment of competent staff; improvement of customer service; increase in

client education on the differences between savings and loans companies and other financial service

providers through the deployment of staff to engage with clients.

The Expected Role of GHASALC

GHASALC needs to be stronger and promote collaboration among savings and loans companies to ensure

that the companies have one voice. Respondents proposed that GHASALC should improve its marketing

strategies and expand advertisements using local languages to help clients understand the key messages.

One S&L was of the view that GHASALC should advocate for attachment of the word ‘bank’ to S&L company

names. Another proposed that GHASALC constantly monitor the activities of S&Ls to ensure that they

comply with the rules and regulations of the association. He added that regular auditing will improve

accountability and enable S&Ls to function effectively.

The Expected Role of the Regulator

The regulator has a critical role to play on the financial landscape to improve the image of the various

actors. Proposed actions to be taken by the regulator to improve the image of S&Ls are:

Allow S&Ls to issue cheques;

Classify S&Ls as banking institutions;

Closely monitor financial service providers without permission to mobilize savings from the public.

Specifically in relation to regulation and range of services, sampled S&Ls were of the view that the range of

services being offered by the S&Ls should be expanded to bring a clear distinction between savings and

loans companies and other microfinance institutions. S&Ls explained that services such as the clearing of

cheques and engaging in foreign currency transfers were examples of services that could be added to the

product offering of S&Ls. One respondent suggested that S&Ls be classified as banking institutions while

another was of the view that capacity building through training and workshops should be provided for S&Ls

to further train their staff. Another respondent was of the view that the minimum capital requirement to

operate an S&L should be raised and the regulations made stricter as a basis for carrying out expanded

services.

A respondent indicated that the regulator may not be in a position to effect any distinctions and it would

not be possible to make the distinctions. This is because, in his view, clients cannot tell the difference

between the tiers used to classify microfinance institutions and there is no differentiator in the eyes of the

average client. Moreover, the name of the institution is what matters to the clients. He therefore advised

that S&Ls would have to operate better than their competitors to create the distinction they desire.

3.4 Clients of the S&Ls

Interviews with clients of sampled savings and loans companies focused on assessing client knowledge and

experiences with the differences between savings and loans companies and the other microfinance service

providers. The results of the interviews are presented along two (2) dimensions of:

The client focus group discussions; and

Individual client In-depth Interviews.

In analysing the responses obtained from the survey, rating scales were used to measure respondent’s level

of confidence, willingness to do business with FSPs, willingness to recommend FSPs to other individuals and

the likelihood to stop doing business with FSPs if there are alternative providers. The Likert Scale9 was used

to rate financial service providers using six levels starting with ‘0’ representing ‘no idea’ and the continuum

of 1-5, where 5 is highest and 1 the lowest. This was explained to respondents before the administration of

the questionnaires.

3.4.1 Client Focus Group Discussions

Focus Group Discussions (FGDs) were held with clients to obtain various perspectives in order to determine

their knowledge on the distinction between financial service providers, especially savings and loans

companies and other microfinance institutions. Findings from the discussions are presented along the five

(5) perspectives of:

Knowledge of the differences among various provider types;

Awareness of similarities between S&Ls and other providers;

Awareness of similarities of all Financial Service Providers;

Scale of preference among various providers;

Suggestions on how to make S&Ls distinct.

Knowledge of the Differences among various Provider Types

The interview questions sought to ascertain client’s knowledge of the differences among the various

Financial Service Providers (FSPs). It also sought to enquire where and how they obtained the knowledge of

these differences and whether knowing or not knowing the differences among the various types has had

any effect on their decisions to deal with the respective provider categories.

The results indicate that most clients of the S&Ls had no knowledge of the various financial service provider

types and only knew the providers by name. The source of knowledge of the differences for respondents

who knew the differences came through media adverts while some said they deduced such knowledge

from the operations and services of some financial service providers. In reference to whether their knowing

9 A scale used to represent peoples attitude to a topic.

or not knowing the differences influences their decisions to deal with providers, respondents indicated that

knowing helps in deciding on who to save with. Respondents who did not know the difference said it did

not affect their decision, because they relate with those they are familiar with.

Awareness of Similarities between S&Ls and other Providers

The interview question sought to assess respondents’ awareness of the similarities between the S&Ls and

other FSPs. Respondents indicated that they do not consider S&Ls as being the same as the other FSPs. In

supporting their opinions, respondents made comments such as:

“Savings and Loans are like Banks so we are not afraid” “Savings and Loans are well established and would not run away with deposits”.

Awareness of Similarities of All Financial Service Providers

In assessing respondents’ awareness of the similarities among all FSPs, majority of the respondents said

there were differences and not similarities. Only a few of the respondents said there were similarities.

Comments from some respondents include:

“Legalities bring differences among providers.” “Attitudinal differences.” “Difference in grades, structures, building and trust level.” “Customer service brings distinction.”

Scale of Preference among various Providers

In determining their scale of preference of FSPs, the clients in the focus group discussions were asked to

rank microfinance service providers according to their confidence in the service providers; willingness to

do business with the respective financial services providers; which provider they would recommend to

others as well as which providers they would stop doing business with if they had the opportunity.

Figures 4, 5, 6 and 7 present the ranking that focus group respondents gave the various FSPs.

a) Confidence in Financial Service Provider

The objective of this perspective is to determine the extent to which the clients of savings and loans

companies have confidence in FSPs providing microfinance services. The results indicate that 79% of the

respondents gave the highest confidence rating of 5 to savings and loans companies. With respect to the

confidence level in other providers, only about 1%-5% of the respondents provided ratings for the other

FSPs.

Figure 4: Confidence in FSPs

It is also clear that most respondents do not have any idea of the operations and services of other six (6)

financial service provider categories. Between 88% and 95% of respondents indicated they would not be

able to rate the other FSPs because they had not had any past or present dealings with them. This is an

indication that the S&L clients may not necessarily migrate to other providers given that majority (over

80%) of the respondents do not know about other provider categories.

b) Willingness to do business with Financial Services Providers

Analyses of responses on willingness to do business with various financial providers indicate that 93% of

the respondents rated their willingness to do business with savings and loans companies as “5”. As

depicted in Figure 5, most of the financial services providers received a no idea rating (0) given that

respondents do not have knowledge and/or interactions with most of the other provider categories.

Respondents (1%+) who are familiar with the other FSPs rated their willingness to do business with these

providers relatively low.

Figure 5: Respondent Willingness to do Business with Financial Service Providers

It is important to note that some existing clients of savings and loans companies rated their confidence

level in savings and loans companies as low (2% of savings and loans clients rated their confidence level as

either 1 or 2), an indication that if they are familiar with other providers they may switch by dropping out

from the savings and loans companies.

c) Which will you recommend to other clients?

When asked which financial services providers the respondents will be willing to recommend to other

clients to do business with, 90% of the respondents gave the highest rating of 5 to savings and loans

companies. Although 40% to 50% of respondents were unable to rate the respective FSPs (due to lack of

knowledge of their operations), 48% to 53% of respondents assigned the lowest rating of ‘1’ to the

remaining FSPs (RCBs, MFCs, FNGOs, Money Lenders, Credit Unions and Susu enterprises). The distribution

of the results is presented in Figure 6.

Figure 6: Willingness to recommend FSPs to other clients

d) Opportunity to Stop Doing Business with Current FSP

Respondents were asked to indicate their preferences if they have another opportunity to choose financial

services providers to deal with. Given the lack of experience/knowledge of most of the providers, the

results were not informative enough. However, 66% of the respondents ranked S&Ls with the highest

rating of 5, which indicates that even though they are clients of the S&Ls, given the opportunity they would

seize to do business with S&Ls. Some respondents who provided this rating were of the view that S&Ls

delay second cycle disbursements and charge high interest rates. It is imperative that S&Ls review their

operations and intensify client education on products to reduce the potential of clients seizing to do

business with S&Ls. Figure 7 presents the ranking of respondents for this category.

Figure 7: Decision to stop doing business with FSPs

Again, between 85-97 % of respondents interviewed said they had no idea on how to rate the other FSPs

since they have not had any dealings with them. The high proportion (66%) of savings and loans clients who

are willing to stop doing business if they have the opportunity to do so is a reflection of clients that are not

happy with their services and products. S&Ls need to address this through improved client service.

Suggestions on making savings and loans companies distinct

The focus group discussants were asked to make suggestions on how savings and loans companies could

make themselves distinct from other financial services providers in the microfinance sector. A number of

suggestions were provided:

“The savings and loans companies should change their interest rates and make loans more affordable”

“S&Ls should look into offering property loans and taking small payments”

“They should reduce the time it takes to disburse loans, especially with the subsequent cycles”

“Branding, marketing should be used to educate clients at introduction as well as financial literacy”

“S&Ls should open more outlets or branches to make them easily accessible especially close to markets and in remote villages because people want their services but cannot due to the distance they have to cover before getting the service.”

“The insurance that S&Ls provide should be life time and not periodic with regular sensitization of new products and services introduced.”

“S&Ls should increase the grace period time before the repayment of loans starts and decrease their interest rate to make it more attractive to other clients.”

“Interest rates that S&Ls put on their loans should be on a reducing balance.”

It is obvious that the suggestions from the clients are geared towards improving product and service

delivery by the savings and loans companies.

3.4.2 Individual client In-depth Interviews

In-depth interviews with thirty-six (36) individual Savings and Loans Company clients were focused on

assessing knowledge and awareness level that facilitate the distinction among the various FSPs. Findings

from the interviews are presented along the following four (4) dimensions:



Awareness of similarities among all Financial Service Providers;

Assessment of Scale of preference.

Knowledge of the Differences Among Various Provider Types

Out of a total of thirty-six (36) individual respondents, thirty (30) respondents representing 83% stated that

they do not know the difference between the various provider types. Six (6) representing 17% said they

know the difference. Figure 8 illustrates the responses obtained.

Figure 8: Differences between FSP Types

Individual respondents provided explanations to indicate whether or not they know the differences.

Selected responses are presented:

“Yes, I know the difference. There are different types of institutions and they have been graded. Every grade

has what they are allowed to do.”

“No, I don’t know the difference between the financial providers. I only know they have different names.”

“I don’t know the difference between the various providers, but I can say some give loans and some don’t. I

also know some charge very high interest whilst some do not. Microfinance companies for example have

very high interest rates.”

Individual clients who indicated they know the difference were asked to provide the source of their

knowledge. The sources disclosed include deduction from the operations of the providers; educated by

agents of financial institutions; through the media or through friends and relatives. Figure 9 presents the

sources and respondents who indicated the respective sources.

Figure 9: Source of information on differences among various financial service provider types

As indicated in figure 9, friends and relatives constitute the main source of information on differences

among various financial services providers, and not the savings and loans companies. On whether knowing

the difference (or not knowing the difference) have any effect on their decisions, twenty-one (21) of the

respondents representing 58% said that their decisions to have dealings with financial service providers is

affected by this knowledge. The remaining fifteen (15) representing 42% said their decisions are not

affected in anyway.


Majority (72%) of individual client respondents indicated that savings and loans companies and the other

FSPs are not the same, an indication that they are not aware of the similarities. Although institutions are

different, at least there are similarities in products and delivery methodologies of S&Ls on one side and

other FSPs on the other. But the results of majority stating that they are not the same means they are not

likely to switch from their current Providers unless they consider that their needs cannot be met. The count

on the findings is presented in Figure 10.

Figure 10: Awareness of Similarities between S&Ls and Other FSPs

Awareness of Similarities among all Financial Service Providers

When individual clients were asked whether they are aware of similarities among all FSPs, twenty-one (21)

respondents, representing 58% stated that the financial services providers are different and ten (10)

respondents stated that they are all the same. One respondent explained that the financial service

providers are different in their services, and also that their mandates are different. Figure 11 presents the

responses.

Figure 11: Similarities between FSPs

Assessment of Scale of Preference

On the assumption that a full range of financial services providers who offer microfinance products are

available, individual clients were asked to select their preferred providers. A number of proxies were used

in assessing the individual scale of preference as conducted in the client focus group discussion. These are

confidence in the service providers; willingness to do business with providers; which provider they would

recommend to others as well as which providers they would stop doing business with if they had the

chance. Figures 12, 13, 14 and 15 present the ratings from the individual respondents.

a) Confidence in Financial Service Provider:

The interview question sought to establish the client’s confidence in financial service providers in the

microfinance sector. In relation to their confidence in S&Ls, 72% of respondents gave S&Ls the highest

rating of confidence. Meanwhile, only 8%, 6% and 3% provided a rating of ‘5’ to other FSPs. These ratings

were assigned to RCBs, Credit Unions and Susu Enterprises respectively. With 41% of respondents assigning

ratings of between ‘3’ and ‘5’, it is clear that respondents have above average confidence in RCBs relative

to the other FSPs under consideration. The analyses of the responses are presented in Figure 12.

Figure 12: Confidence in FSPs (Individual Clients)

b) Willingness to do business with FSP

In relation to client willingness to do business with FSPs, 78% of respondents ranked their willingness to do

business with the S&Ls with the highest rating of ‘5’. This indicates that respondents are willing to continue

transacting business with the S&Ls. Figure 13 presents the respective responses.

Figure 13: Willingness to do business with Service Providers (Individual Clients)


The interview question sought to establish which providers the clients would recommend to other

individuals. In all, 83% gave the S&Ls the highest rating of ‘5’. Eight percent (8%) of respondents gave Rural

& Community Banks and Microfinance Companies the highest rating of ‘5’. The results presented in figure

14 indicate that the clients of the S&Ls are more likely to recommend the services of the S&Ls to others

than any of the other service providers. This is an opportunity for savings and loans companies to work with

their existing clients in promoting S&L services and products.

Figure 14: Willingness to recommend Service Providers (Individual Clients)

d) Opportunity to Stop Doing Business with FSP

The interview question sought to establish which FSPs clients would seize doing business with if given the

opportunity. Even though respondents were all clients of the S&Ls, 66% ranked the S&Ls with the highest

rating, indicating the tendency for them to quit saving with the S&Ls. With a significant proportion of the

respondents rating their desire stop at ‘5’, S&Ls have to work on understanding what the issues are so as to

address them. This is critical because clients that expressed the desire to change provider categories if they

have the opportunity, will desert their S&Ls if other provider categories come along. Further analyses show

that 17%, 14%, 9%, 11%, 11% and 14% of respondents ranked the RCBs, MFCs, Money Lenders, Credit

Unions and Susu Enterprises with the highest rating, a reflection of their dissatisfaction with these

providers. Responses are presented in Figure 15.

Figure 15: Decision to stop doing business with FSPs (Individual Clients)

Suggestions from individual clients on making savings and loans companies distinct

Individual clients provided suggestions on how to make savings and loans companies distinct. Key

suggestions are presented:

“They should educate the public more on what they do.”

“The government should monitor the S&L companies and close down those who don’t have the appropriate

accreditations to operate because those ones ruin the good ones.”[this is an example of a client who

equates microfinance companies to savings and loans companies]

“S&L companies should recruit well educated staff instead of the SHS graduates who don’t even know

anything about the companies they are working at.”

‘’Savings and Loans companies should start providing ATMs at vantage points so that people can access

their accounts in case of any emergency or on weekends which most financial service providers do not have

so they can be the first to do it and make their services stand out’’.

Savings and Loans companies should adapt better marketing strategies to let the public know what they

do.”

“Expand mobile banking to rural areas for the rural people to also get access to it easily.”

They should get mobile baking vans like UT bank to take the services to the people in their work places; this

will make people attracted to their services”.

3.5 Non-Client Respondents

Interviews with non-savings and loans company clients sought to obtain the perspective of non-clients on

the key areas of:



Inquiry into non-dealings with S&Ls;

Awareness of Similarities of All Financial Service Providers;

Assessment of Scale of preference.

Knowledge of the Differences Among Various Provider Types The discussions sought to ascertain respondents’ knowledge of the differences among the various Financial

Service Providers (FSPs). It also sought to enquire where and how they obtained the knowledge on these

differences and whether knowing or not knowing the differences among the various types have any effect

on their decisions to deal with the various financial services provider categories.

Thirty-one (31) respondents out of the total of 35, representing 89% said they are aware of the differences

among the Financial Service Provider types, whilst four (4) indicated they did not know the difference.

Figure 16 presents the responses and counts.

Figure 16: Difference between FSP Types

When asked if their knowledge of the differences had any effect on their decisions to deal with providers,

fifteen (15) respondents (54%) out of twenty-eight (28) who provided responses to the question said their

decisions are not affected and the remaining thirteen (13) respondents said the knowledge affects their

decisions. Figure 17 presents the responses and counts.

Figure 17: Effect of Knowledge on Choice of FSP


On the question of awareness of similarities between savings and loans companies on one hand and other

providers on the other hand, majority of the respondents could not answer the question because they are

not very familiar savings and loans companies.

Inquiry into non-dealings with S&Ls

Participants were asked to provide reasons for not having any present dealing with Savings and Loans

Companies, whether they intend to deal with S&Ls and if not, why they do not have plans to do so. All the

thirty-five (35) participants said they do not have future plans to save with the S&Ls, mainly because they

do not have branches close to them.

Awareness of Similarities of All Financial Service Providers

Participants were further assessed on their awareness of similarities of all financial services providers and

the reasons for their responses. Thirty-one (31) respondents representing 88% said that all financial service

providers are the same, whilst four (4) of them representing 12% thought otherwise. Figure 18 presents

their responses and counts. Figure 18: Similarities between FSPs

Assessment of Scale of Preference

In assessing the respondents’ scale of preference of FSPs, respondents were asked to rate their

preferences of the providers according to their confidence in these service providers; willingness to do

business with providers; which provider they would be willing to recommend to others as well as which

providers they would stop doing business with if they had the chance. Figures 18, 19, 20 and 21 depict the

ratings that respondents gave the various FSPs.

a) Confidence in Financial Service Provider:

The interview question sought to establish the respondent’s confidence in financial service providers.

Credit Unions received the highest rating with 33% and 10% of respondents assigning ratings of ‘4’ and ‘5’

respectively. RCBs received the second highest rating with 46% and 10% assigning ratings of ‘3’ and ‘4’

respectively. S&Ls received the third highest rating with 10 of respondents assigning a rating of ‘3’ and ‘1’

respectively. Majority of respondents indicated that they have no idea about the operations of the FSPs

discussed. Up to 79% of respondents indicated that had no dealings with S&Ls. Presented in Figure 19 is the

representation of the responses.

Figure 19: Non-client respondents’ confidence in FSPs

b) Willingness to do business with FSPs

The interview question sought to establish the respondents’ willingness to conduct business with financial

service providers. Most respondents are more willing to do business with RCBs and Credit Unions as 50%

and 33% of respondents assigned these FSP with a rating of ‘4’(second highest). Credit Unions seem to be

relatively more attractive to deal with having received the highest rating of ‘5’ from 10% of respondents.

On the contrary, only 9% of respondents have a high degree of willingness to do business with S&Ls. This

could be attributed to the fact that respondents were not clients of the S&Ls and had no dealings with the

S&Ls. Again, 41-90% respondents could not rank the other FSPs due to the fact that they had no dealings

with them. Figure 20 presents the respective responses.

Figure 20:Non-client willingness to do business with FSPs


The interview question sought to establish which FSPs respondents would recommend to other individuals.

In all, 10% of respondents rated the S&Ls with the highest rating (‘5’) compared to 46% and 33% of

respondents rating RCBs and Credit Unions with a similar rating. The outcome of these responses indicates

that respondents are more likely to recommend the RCBs and Credit Unions compared to FSPs given that

they are familiar with these providers. Presented in Figure 21 are the ratings of the various FSPs.

Figure 21: Non-client willingness to recommend FSPs

d) Opportunity to Stop Doing Business with FSP

The interview question sought to establish FSPs with that respondents’ would seize doing business with if

they had the opportunity. Figure 22 shows that 56% and 15% of respondents indicated that they would

stop doing business with Susu Enterprises and Credit Unions respectively (both receiving the highest

ranking), which may be a reflection of their dissatisfaction. About 15% of respondents also indicated a

relatively high probability that they would seize doing business with RCBs by assigning the FSP category

with a rating of ‘4’. However, non-clients did not provide ratings indicative of any unattractiveness in doing

business with S&Ls. This is most likely because majority (69%) do not have dealings with S&Ls. However,

due to the possibility that some respondents may have had dealings with S&Ls in the past, ratings of ‘1’ and

‘3’ were provided by 15% of respondents.

Figure 22: Non-client decision to stop doing business with FSPs

SECTION 4.0: CONCLUSIONS AND RECOMMENDATIONS

4.1 Introduction

Section 4 discusses the conclusions from the study based on the findings from desk review and individual

interviews. The recommendations outline the main steps that savings and loans companies and their

association would have to pursue either singularly or in collaboration with other stakeholders such as the

regulator and other microfinance associations.

4.2 Conclusions

The objective of the study is to help the S&Ls understand the core problem posed by their inclusion among

microfinance institutions; address the unintended effects of the existing acts on the operations of the S&Ls;

identify effects on the industry as a whole, provide an objective basis for the next steps and provide insight

into whether S&Ls are in fact among the microfinance sector or not and compare this to international best

practices. The study further focuses on obtaining insight into the perception of the public on the savings

and loans institutions and the other financial service providers in the microfinance sector.

Deriving from the above, the study was designed to provide answers to specific questions that will address

the main objectives of the study. Critical among these questions are the following:

1. Are savings and loans companies microfinance providers? 2. Are there differences between the markets served by Savings and Loans Companies and Microfinance

Institutions? 3. Do the relevant laws and pronouncements lump savings and loans companies together with other

microfinance institutions? 4. What are the unintended effects of the existing Operating Rules and Guidelines on Savings and Loans

Companies? 5. Are current events in the microfinance sector affecting the image and operations of Savings and Loans

Companies? 6. What are the current and potential effects of client perception on regulation of Savings and Loans

Companies?

Are Savings and Loans Companies microfinance providers?

The findings of the study indicate that savings and loans companies provide microfinance services and

products comprising microcredit and micro savings. The methodologies adopted for the delivery of these

services and products are similar to those adopted by the various actors on the microfinance landscape.

Group lending methodology, Susu methodology and savings group concepts are practiced among various

savings and loans companies. The target clients served by savings and loans Companies also include low

income clients and informal sector actors which are the typical clients of microfinance providers. However,

it is important to note that savings and loans companies have the latitude and do offer services and

products that cannot be strictly interpreted as microfinance products. Examples include institutional loans

for on lending and loans to SMEs. In addition to business practices, savings and loans companies are

recognised by policy makers and the regulator as key actors in the extension of financial intermediation

services to the excluded.

Are there differences between the markets served by Savings and Loans Companies and Microfinance

Institutions?

Markets served by microfinance institutions are largely low income, poor and financially excluded

households as well as microenterprises. Savings and loans companies target low income and informal

sector actors in addition to Small and Medium Sized Enterprises (SMEs). The study showed that

microfinance institutions, in addition to their traditional target market of low income and informal sector

also serve SMEs and some actually serve only SMEs. In the same vein some savings and loans companies

and universal banks also serve the financially excluded, low income and poor households with targeted

products. The microfinance institutions and savings and loans companies therefore serve the same market.

As a result, the operations of both categories of providers have the potential to impact each other.

There are several similarities in the operations of the S&Ls and the other financial service providers in the

microfinance sector. The products, services, delivery methodologies and client management are mostly the

same. The only visible difference is in the interest rate on loans with the S&Ls offering lower rates

compared to the other microfinance institutes.

Do the relevant laws and pronouncements lump savings and loans companies together with other

microfinance institutions?

Prior to the issuance of operating guidelines for microfinance activities, Savings and Loans Companies were

already regulated under the relevant laws which are the Non-Bank Financial Institutions Act 2008, Act 774

and the Banking Act. Savings and Loans Companies were not necessarily the focus of the Operating Rules

and Guidelines for Microfinance Institutions issued in 2011 by the Bank of Ghana. What the Operating

Guidelines sought to do is to recognise that, there are existing providers such as Rural and Community

Banks as well as Savings and Loans Companies among others which undertake activities that fall within the

broad definition of microfinance. Indeed Savings and Loans Companies are not supervised directly by the

new department of the Bank of Ghana (Other Financial Institutions Supervision Department) which was

purposely created for the microfinance institutions that were the focus of the Operating Rules and

Guidelines. The supervision of Savings and Loans Companies remain under the main banking supervision

outfit. These observations show that from the provisions of the regulations and ongoing practices, Savings

and Loans Companies are not necessarily regarded by the regulator as microfinance institutions, but there

is the recognition that part of the business activities undertaken by Savings and Loans Companies fall under

microfinance activities. The government’s financial sector strategic plan (FINSSP II) also recognises savings

and loans companies as an independent non-bank financial institution that also provides microfinance. It is

important however, to recognise that the structures that explain the delineations are clear on paper but

practices on the ground are different.

What are the unintended effects of the existing Operating Rules and Guidelines on Savings and Loans

Companies?

From the study, the classification of Savings and Loans Companies under Tier 1 of the Operating Rules and

Guidelines of Microfinance Institutions has not had any direct effect on the operations of the Savings and

Loans Companies. This is due to the fact that the Savings and Loans Companies did not suffer any

limitations in terms of their products and services offering as a result of the Operating Rules and Guidelines.

It is obvious however, that the licensing of deposit taking institutions as included in Tier 2, has resulted in

increased number of microfinance institutions that are aggressively operating in the same market as

savings and loans companies. Any concerns about unintended effects are therefore linked to the deposit

mobilization mandate and how the deposits mobilized are used. The misapplication of deposits mobilised

by some of the microfinance companies to expand their businesses and other unrelated ventures could be

addressed through institution of stronger equity base.

It is also obvious that given the large number of institutions operating in the microfinance arena in Tier 2

and below, the regulator and indeed microfinance associations themselves are finding it difficult to ensure

full compliance with regulations. With a population that has low financial literacy levels, it is not surprising

that clients do not know the differences among all actors on the microfinance landscape and are attracted

to patronise institutions with offerings that are not sustainable. The net effect is increasing poor image of

the microfinance landscape with direct implication for the image of all the actors.

Are current events in the microfinance sector affecting the image and operations of Savings and Loans

Companies?

The study has indicated that current events in the microfinance sector such as unethical practices and

misuse of savings of depositors has dented the image of the microfinance industry and by extension Savings

and Loans Companies. Some S&Ls indicated that clients that have lost savings with other microfinance

institutions tend to think they will lose their savings with S&Ls and this has resulted in unplanned

withdrawals on the part of some S&L clients. This is largely because, as shown by the study, the public that

access services and products of S&Ls and other microfinance institutions do not know the differences

among the categories of providers.

Deriving from the results of client and non-client interviews, majority of respondents do not know the

differences among the various providers in the microfinance sector. To the majority of the respondents, all

financial service providers in the microfinance arena are similar because they perform the same functions

such as give loans, collect deposits, collect Susu savings from clients as well as invest client deposits. With

the specific case of Savings and Loans Companies, most respondents were of the view that S&Ls are the

same as the other microfinance institutions especially those that are mandated to take deposits and give

out loans. The study also showed that clients will save with institutions that come to them and in the

absence of other providers, will stick with their current providers even if they are dissatisfied with the

products and services.

What are the current and potential effects of client perception on regulation of Savings and Loans

Companies?

The differences between the savings and loans companies and the microfinance institutions especially the

Tier 2 Operators are few and it is difficult for most of the clients and general public to distinguish between

the operations of these two categories of providers unless conscious branding and sustained education are

undertaken. The potential effects of the perception of the public on the operations of the Savings and

Loans Companies cannot be overemphasized. Since MFI failures and problems tend to be contagious and

affect other FSPs regardless of their soundness, this perception of the S&Ls being the same as the other

financial service providers in the microfinance arena, if not corrected, could affect the operations of the

S&Ls and their willingness of S&Ls to remain in this important market as is already seen by the desire of

some S&Ls to become universal banks.

It is important to state that current client perception is however, not triggered by the approach to

regulating savings and loans companies. It is rather a combination of inadequate client financial education

on the part of all stakeholders including the regulator, financial services providers and microfinance

associations; lack of compliance with regulations by microfinance institutions and enforcement

inadequacies; unethical conduct on the part of MFIs and poor governance.

4.3 Recommendations for the Way Forward The main issues confronting the Savings and Loans Companies as gathered from the study are a

combination of regulatory, operational, market perceptions and state of financial awareness. The

recommendations are made to provide the Savings and Loans Companies the opportunity to address the

current challenges in the context of the wider microfinance sector. It is important to note that majority of

savings and loans companies play critical role in the promotion of financial inclusion and their stability is

essential for the stability of the wider financial sector.

Microfinance Associations to work with Regulator on sanitizing the microfinance sector

The need for the regulator to sanitise the microfinance sector is already known to the regulator and efforts

are on-going in this direction. The introduction of the Operating Rules and Guidelines; increase in minimum

capital requirements, the establishment of Other Financial Institutions Supervision Department, are

examples of on-going efforts to address the challenges in the sector. Microfinance associations and the

wider financial sector actors need to partner with the regulator to introduce innovative means of improving

the image and credibility of the microfinance landscape. Examples of specific steps include reporting of

unlicensed providers to Bank of Ghana for sanctioning and closure; establishment of key informant reward

pool to serve as incentive for people to report unlicensed providers; intensification of naming and shaming

of institutions involved in unethical practices.

Savings and Loans Companies to carve distinct image for their subsector

The findings provide opportunities for savings and loans companies to carve a distinct image for the Savings

and Loans Companies segment of the financial industry to address the current market perceptions that

considers all actors as one. The primary responsibility for creating a distinct image remains that of the

Savings and Loans Companies. There are various options available to individual savings and loans

companies and the association of savings and loans companies to work at creating the distinct image. For

the individual savings and loans companies, the options include:

Introduction of client orientation and counselling programs that throw light on the various categories

of financial services providers and the position of Savings and Loans Companies;

Continuous engagement with clients to understand their interactions with financial services providers

as a basis for providing innovative and responsive services and products;

Strong rebranding has to be undertaken by savings and loans companies as a primary responsibility.

However, it has to be noted that not all of the savings and loans companies have the financial capacity

to undertake the desired level of branding.

The association of savings and loans companies is encouraged to undertake the following:

Create a distinct image of the association and its members through well designed and targeted

programs;

Partner with development agencies and other industry stakeholders to undertake awareness creation

among the public on various categories of financial services providers and the savings and loans

companies segment.

Savings and Loans Companies to intensify Staff Education

Staff of the Savings and Loans Companies especially field staff should be trained on their interactions with

clients. Since they are the first point of contact for the institutions, there is the need to increase the training

to ensure expected results. Most of the clients perceive the field staff as ‘susu collectors’ and in the bid to

correct that perception, the field staff themselves describe the Savings and Loans Companies as ‘Banks’ or

‘Microfinance’. GHASALC and its members need to invest in the training of their staff in client education

and interaction.

Client Financial Education as part of broader financial inclusion

The role of the State through the Ministry of Finance in promoting financial education as part of the

financial inclusion agenda is critical. A financially literate public will know the differences among the various

providers and be well placed to be responsible clients. Previous efforts in this area include the annual

financial literacy weeks that were focused on increasing awareness of the key financial literacy themes and

providers. On-going efforts to develop a financial inclusion strategy for the country will be critical in

promoting financial education that will greatly facilitate resolution of some of the challenges brought about

by the increased number of microfinance providers. GHASLAC is encouraged to fully participate in the

efforts towards the development of financial inclusion strategy to ensure that its interest is served.

Advocate for increased range of services offered by Savings and Loans Companies through changes in

regulation

The demand for increased range of services has remained a major concern for Savings and Loans

Companies. The research has shown that the services and products offered by Savings and Loans

Companies and other microfinance providers especially the Deposit Taking Tier 2 providers (known as the

Microfinance Companies) are the same. Given that the Savings and Loans Companies have higher capital

requirements, they are able to deal with larger loan sizes and increased permissible activities compared to

the mainstream microfinance companies. Such changes will serve as incentives for savings and loans

companies that are dedicated to the SME market to remain as Savings and Loans Companies and operate

their businesses profitably.

Alternatively, the Association should advocate for a change in regulation to among other things introduce

ceilings on what savings and loans companies can do, so as to manage the differentiations between the

microfinance institutions in Tier 2 (and below) on one hand and Savings and Loans Companies on the other.

The Bank of Ghana has increased the minimum capital requirement of microfinance institutions to ensure

that some market related challenges are addressed. This has to be monitored on a continuous basis to

ensure that reductions in equity and liquidity constraints due to consistent losses made by some of the

MFIs for example are addressed.

In considering the various options to focus advocacy on, caution has to be exercised in advocating to

become Banks as a tier below the Universal Banks. Such an approach may lead to increase capital

requirement from the Bank of Ghana that some S&Ls cannot meet and also make competition with the

universal banks a difficult task.

Regulator to strengthen supervision of microfinance institutions

There are concerns that the Central Bank does not have adequate capacity to supervise all the licensed

microfinance institutions, thus creating the opportunity for unscrupulous actors to continue with their

unethical practices. Whereas it may be true that Bank of Ghana may have capacity challenges, it is also

important to state that the challenge goes beyond the Central Bank. Microfinance associations, the

respective providers and general public have the responsibility to contribute to the strengthening effort by

educating and drawing attention to unethical practices. There is an urgent need to strengthen the

governance structures of the microfinance institutions in particular as guarantee for some basic good

practices such as deposit management. Most Savings and Loans Companies have stronger governance

structures.

Continuous engagement with the regulator and other microfinance associations

The Savings and Loans Companies, led by the association would have to adopt a posture of continuous

engagement with the regulator on the key areas in which regulation can help improve the operations of

savings and loans companies. Challenges encountered in product and service delivery by savings and loans

companies should be brought to periodic “round table conference” with the regulator to be discussed and

solutions found for them. It is important for the association of savings and loans companies to work with

other microfinance associations to address the challenges posed by the various operators on the field as

means to finding lasting solutions.

Lobbying Regulator on Name Change

Given the strong opinion among some S&L Executives as expressed in various meetings and interactions on

the need for name change, the industry association should lobby the regulator to agree with the Savings

and Loans companies to differentiate themselves from the other microfinance institutions. This can be

done by adding the name ‘Bank’ to the name Savings and loans as “Savings and Loans Banks” or “SME

Bank”. It is important to sate however that there is still a lot of work to be done in the area of general

operations and market responsiveness and name change alone will not work to improve the lot of Savings


Page A

APPENDIX 1: RESPONDENTS PER INSTITUTION (MANAGERS)

Name of Respondent Institution Designation Contact

Patrick Kyei Opportunity International Manager 0544330026/0277814412

Charles Owusu First Allied Savings and Loans Manager 0246627000/020433266

Iddrisu Ayatulaah UTRAK Manager 02043452313

Aaron Rex Opoku-Ahene SINAPI ABA Savings and Loans COO

Michael Debrah SINAPI ABA Savings and Loans Manager 0201850006

Page B

APPENDIX 2: INDIVIDUAL RESPONDENT DETAILS- NORTHERN REGION

No. Name of Respondent Business Background Financial Provider (RCBs, S&Ls, Micro.Fi, CU, FNGOs, Money Lenders, Susu Collectors

Contact

RCBs S&Ls MFCs CU FNGOs ML Susu

1. Mohameed Muniru Trader and Baker 0206666710

2. Abdulla Abubakari Car repairer 0277799833

3. Abdulai Fusheini Trader

4. Adam J Nayi Carpenter 0201232403/0240045245

5. Amina Iddrisu Trader 0202174281

6. Jabiru Tahiru Taxi driver

7. Yakubu Sanatu Trader 0243801888

8. Ziblim Jemila Trader 0542999406

9. Dauda Fati Trader

10. Abdulrahman Kadija Trader

Page C

APPENDIX 3: FOCUS GROUP RESPONDENT DETAILS- NORTHERN REGION


Contact


1. Abiba Yakubu Sell plastic materials √ 028284905

2. Rukaya Mohammed Sells clothing √ 0245818186

3. Meimuna Alhassan Provisions √ 0269765804

4. Alhassan Wasila Sell clothing √ 0546813584

5. Sanatu Alhassan Soap √ 0203498304

6. Alhassan Sadia Food stuff 0245123288

7. Adamu Sofo Sells honey √ 0504128791

8. Aliya Yakubu Provisions √ 026200343

9. Yakubu Maria Porridge √ 0246007709

10. Fuseina Yakubu Sell plastic materials √ 024986428

11. Fatima Iddrisu Sell honey √ 0266231883

12. Amina Nabila Trader √ 0203498304

13. Azara Salifu Seamstress √ 0271956400

14. Abdulai Jemila trader √ 0203498304

15. Yakubu Zainab Trader /teacher √ 0503405586

16. Kpema Tawa Sells food stuff √

Page D


Contact


17. Sanatu Fusheini Groundnut paste √

18. Damata Fusheini Food vender √

19. Ngu Fatimata Shea butter √ 0247133112

20. Issah Arhanatu Shea butter √

21. Awabu Alhassan Shea butter √

22. Nimatu sayibu Sells “kose” √

23. Sanatu Alhassan Shea butter √

24. Memunatu Munkaila Yam trader √ 0540218145

25. Adisah Yakubu Rice trader √

26. Adamu Musah Rice trader √ 0549602002

27. Sanatu Isshaku Groundnut paste √ 0549602002

28. Mary Mohammed Trader √ 0547599055

29. Adisa Wumbei Trader √

30. Mary Yakubu Rice trader √

31. Amina Issah Rice trader √

32. Zeliya Yakubu Sells grains √

33. Damata Ibrahim Trader √

34. Katumi Bawa Trader √

35. Mariam issah Sells bread √

36. Barikisu Mohammed Trader √

Page E


Contact


37. Mariama Munkaila Trader √ 02479622171

38. Fatima Alhassan Sells Groundnut paste √

39. Ayi Alhassan Trader √

40. Iddi Sanatu Trader 0273596765

41. Sanatu Yakubu Pomade √ 0547312147

42. Zulfawu Alhassan Trader √

43. Ayatu Memunatu Trader √ 0247599055

44. Sukena Yakubu Sells Jewellery √

45. Amina Fusheini Shea butter √

46. Inusah Adisah Shea butter √

47. Abdulrahman Aziz Nil

48. Iddrisu Sumani Trader

49. Fusheini Alhassan Trader

50. Muniru Iddrisu Trader

51. Abdul Aziz Trader 0266537826

Page F

APPENDIX 4: FOCUS GROUP RESPONDENT DETAILS- GREATER ACCRA REGION


Contact


1. Godfred Awusi Drivers 0279914880

2. Comfort Runs Spot 0275426500

3. Patience Boadu Beautician 0242542564

4. Comfort Adae Ashaley Cooks Kenkey 0242236137

5. Israel Driver 0507298721

6. Clement Adjei Driver 0201945870

7. Baah Driver Not disclosed

8. Cynthia Aboagyewaa Trader 0275885518

9. Rejoice Avoryi Trader 0242548355

10. Eunice Nortey Trader 0243682155

11. Margaret Trader -

12. Jacob Asante Driver 0244669536

13. Akoirtey Aikins Driver 0209893555

14. Patience Mmaa Trader 0579267574

15. Ebenezer Aryee Photographer 0275788893

16. Emmanuel Anku Photographer 0242618046

17. Joseph Tetteh Laryea Driver 0577475556

Page G


Contact

RCBs S&Ls MFCs CU FNGOs ML Susu 18. Susana Trader 0541174824

19. Faustina Anim Trader 0244772860

20. Yaw Nicholas Driver 0243534295

21. Robert Agyefan Driver 0543601904

Page H

APPENDIX 5: INDIVIDUAL RESPONDENT DETAILS- GREATER ACCRA REGION


Contact


1. Christian Asante Trader 0244460017

2. Daniel Asiedu Trader 0548280137

3. Alexander Coffie Phone Dealer 0266646144

4. Abedu Amponsah Book Binder 0209351869

5. Alfred Trader 0243766909

6. Benard Agyapong Business Development

Manager

0541752733

7. Cecilia Décor specialist

8. Collins Yeboah Driver 0278001204

9. Cornelia Trader 0248683791

10. Michael Ofosu Trader 0242722015

Page I

APPENDIX 6: FOCUS GROUP RESPONDENT DETAILS- ASHANTI REGION


Contact


1. Elizabeth Abare Trader-Earrings 0248660819

2. Portia Yeboah Asumah Service-Proprietor 0548822337

3. Rebecca Gyanfi Trader-Cold Store 0243161334

4. Akua Adwubi Trader- Cassava, Plantain 0248936141

5. Confort Frimpong Trader-Proprietor 0244670706

6. Philip Owusu Kwame Service-Printing Press 0543636278

7. Adwoa Serwae Food Fried Plantain 0246064121

8. Yaa Amoabeng Trader-Petty trader 0243425240

9. Abena Amankuah Food –Rice 0276522138

10. Emelia Yeboah Food –Rice 0247453750

11. Akosua Kesewaa Trade-Rice 0249617085

12. Abena Achiana Service-Hairdresser 0554971687

13. Cecilia Tannoh Hairdresser 0275985044

14. Felicia Frimponmaa Trader 0548505416

15. Afin Nimah Trader 0240641065

Page J


Contact

RCBs S&Ls MFCs CU FNGOs ML Susu 16. Agnes Manu Trader 0261634539

17. Felicia Addi Hairdresser 0249380226

18. Emmamuel Acheapong Wood Seller 0242529882

19. Rashidatu Saddat Trader 0548764533

20. Augustina Amponsah Trader 0243959377

21. Gifty Kaweh Trader 0246048035

22. Micheal Nii Tetteh Teacher 0243016870

23. Josephine Boateng Duah Trader 0277744480

24. Abena Aseiduaa Trader 0546228840

Page K

APPENDIX 7: INDIVIDUAL RESPONDENT DETAILS- ASHANTI REGION


Contact


1. Lydia Adu Trader-Soaps 0273537291

2. Adama Salifu Food-KoKo -

3. Charles Osei Cornmill Operator 0542178748

4. Kate Manu Trader -

5. Ama Naa Takyiwaa Trader 0240399951

6. Faustina Sefa Trader -

7. Christiana Turkson Trader 0261446063

8. Faustina Kodua Trader -

9. Comfort Akumia Food 0543571282

10. Adusei Oware Philip Student 0247844217

11. Edmond Enoch Student 0233361552

12. Francis Manteau Goldsmith 0243420480

13. Augustine Asare Fabricator (Glass) 0244595008

14. Paul Eshum Rubber Stamp Maker 0241139119

15. Stephen Nyarko Henderson Student 0545569586

16. Hajia Barakisu Trader -

Page L

APPENDIX 8: FOCUS GROUP RESPONDENT DETAILS- VOLTA REGION


Contact


1. Deborah Tetteh Trader

0245786852

2. Abigail Nutsi Trader 0541604193

3. Charity Dzaka Trader 0242926896

4. Gladys Tetteh Trader 0554589771

5. Francisca Todjo Trader 0241448237

6. Gladys Amedofu Trader -

7. Esther Hlorwu Trader 0246819945

8. Baby Adzigodzi Trader -

9. Felicia Keteni Trader -

10. Edith Sabblah Trader 0240929637

11. Dzigbodi Goza Trader 0249687018

12. Dzifa Adikah Trader & Teacher 0245837730

13. Genevivie Gerke Trader 0243377147

14. Dina Atiku Trader 0245492903

15. Christina Dzekle Trader 0240704611

16. Elizabeth Ahamah Trader 0545393249

Page M

APPENDIX 9: FOCUS GROUP RESPONDENT DETAILS- EASTERN REGION


Contact


1. Esther Owusuwaa Trader 0206056707

2. Victoria Nortey Farmer 0548032339

3. Juliana Ofosua Trader 0248027823

4. Esther Abey Trader -

5. Aako Nortey Trader -

6. Patience Serwaa Farmer -

7. Mercy Otubea Farmer -

8. Nackey Mercy Farmer -

9. Felicia Asabea Trader 0246226943

10. Margaret Amoabea Farmer 0248451998

11. Gladys Fianko Farmer -

12. Samuel Gyadu Farmer 0205201962

13. Lydia Amoaniwaa Farmer -

Page N

APPENDIX 10: QUESTIONNAIRE FOR CEOs AND MANAGERS OF S&Ls

GHASALC QUESTIONNAIRE CEOs and Managers of S&Ls

Objective: To obtain from selected Savings and Loans Managers first-hand information on the extent to which their operations is blurred with those of other microfinance institutions and the effect on their overall operations.

What methodologies are used by savings and loans for saving mobilization?

Are there sections of the group training methodology that focuses on explaining the difference between Savings and Loans Companies and other types of Financial Service Providers?

What will you consider as the main differences between your products and services on one hand and those of other microfinance institutions?

What are your main delivery methodologies and how distinct are these from those offered by other microfinance institutions? - Please provide further clarification on how the delivery methodology differ or

remain the same.

In what specific ways have the operators of other microfinance institutions affected your operations? - For each of the specific ways mentioned, please state how this has affected your

operations.

Do you have branches located in close proximity with microfinance institutions? Has this brought any conflict between providers or your clients? - In what ways? And how did you resolve the conflict?

What proportion of your clients would you say have dealings with other microfinance institutions? - Can you provide specific examples to support the assertion?

- Do you find out from your clients if they hold accounts with microfinance

institutions when they are opening account with you or obtain general information on other Financial Services Providers?

- What do you use the client data for?

Have you noted any specific trends with clients who deal with your institution alone and those who deal with your institution and other microfinance institution? - Do you see changes in savings trends? Please explain.

- Do you see changes in loan repayment trends? Please explain.

Page O

In what ways do you think we can improve and make distinct the image of savings and loans companies?

- What can the Savings and Loans Companies themselves do?

- What can the Savings and Loans Associations do?

- What can the regulator do to improve the situation?

In the specific area of regulation and range of services that Savings and Loans Companies are permitted to carry out, what in your view should be done?

- Regulation

- Range of services and products

Page P

APPENDIX 11: QUESTIONNAIRE FOR CLIENT FOCUS GROUPS AND INDIVIDUALS

CLIENT FOCUS GROUPS DISCUSSION (FGD) GUIDE

(Group Clients and Non-Clients of Savings and Loans)

Objective: Obtain from clients their perception with respect to the differences that affect their decisions in dealing with savings and loans companies.

Step 1: Welcome members and assure them of the purpose confidentiality of the discussion.

Step 2: Obtain and record background of focus group members. Specifically obtain records on the various categories of Financial Services Provides (Banks, Savings and Loans Companies, Rural and Community Banks, Microfinance Companies, Credit Union, Financial NGOs, Money Lenders, Susu Collectors) that the discussants deal with and obtain qualitative data.

Step 3: Ask participants if any of them, knows the differences between the various Financial Provider types and record their answers and counts. - Probe to understand where they got the difference from, whether somebody

taught them, media or other providers.

- Probe whether knowing or not knowing the differences among the various types have any effect on their decisions to deal with their provider categories.

Step 4a: Ask, participants specifically those who deal with Savings and Loans Companies, if they see the Savings and Loans Companies to be the same as other providers. Probe to understand and document whether actions of other microfinance providers (such as inability to pay back deposits to customers) can influence their decision to enter transactions with Savings and Loans Companies.

Step 4b: Ask participants who have no present dealing with Savings and Loans Companies, why this is so? Probe to obtain perception on whether they have any future plans to deal with Savings and Loans Companies. - If they have plans, ask why? and - If they do not have plans, ask why?.

Step 5: Ask discussants whether they consider that all financial service providers are the same?

- Obtain general answers and probe to understand the reasons provided for each question.

Step 6: Using a modified Likert Scale, obtain from participants the following using the scale of 0-5 with 5 representing the changes and “0” indicating “no idea”.

Page Q



Confidence (that providers will keep their word and effect their promises) Provider Category Rating

0 1 2 3 4 5

1. Savings and Loans Company

2. Rural and Community Banks

3. Microfinance Companies

4. Financial NGOs

5. Money Lender

6. Credit Union

7. Susu Enterprise

Willingness to do business with provider Provider Category Rating

0 1 2 3 4 5




4. Financial NGOs

5. Money Lender

6. Credit Union

7. Susu Enterprise

Which will you recommend to other clients Provider Category Rating

0 1 2 3 4 5




4. Financial NGOs

5. Money Lender

6. Credit Union

7. Susu Enterprise

Which will you stop doing business with if you have the chance? Provider Category Rating

0 1 2 3 4 5




4. Financial NGOs

5. Money Lender

6. Credit Union

7. Susu Enterprise

Step 7: Ask participants if they have suggestions on how savings and loans companies can make themselves distinct from other providers on the microfinance sector.

Page R



Step 8: Ask if there are any questions or clarifications and close the session.

Page S

APPENDIX 12: LITERATURE REVIEWED

1. Financial Sector Strategic Plan II (FINSPII), April 2012.

2. Non-Bank Financial Institutions Act 2008, Act 774.

3. Bank of Ghana Reports 2010-2014.

4. Bank of Ghana Requirements for Non-Bank Financial Institutions Licences.

5. United Nations, Concept Paper: Building Inclusive Financial Sectors to Achieve the Millennium

Development Goals (International Year of Microcredit, United Nations, 2005).

6. Ghana Association of Savings and Loans website [Online] Available from: www.ghasalc.com.

7. Bank of Ghana website [online] Available from: www.bog.gov.gh.

8. Ministry of Finance, Report: Mapping of Financial Inclusion Landscape In Ghana 2013.

http://www.ghasalc.com/

http://www.bog.gov.gh/

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