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Credit regulation and policy

Revision of Policy for Consumer credit and the National Credit Act (2012)

Some five years after implementation of the NCA, the dti required a revision of its policy. Feasibility worked in partnership with the University of Pretoria Law Clinic to research and advise on a revised policy and produced a new draft policy document.  The dti has subsequently published the Draft National Credit Act Policy Review Framework, 2013 and the Draft National Credit Amendment Bill, 2013 for public comment which was due the end of June 2013. Client:  Department of Trade & Industry
Download the first document pdf here 500KB.
Download the second document pdf here 250KB.

The cost of credit, access to credit and associated market practices (2008 & 2011)

The NCR came into operation in 2007 and one year later (2008) a survey was conducted by Feasibility to study the trends in the credit market, the research was published as The Pricing of and access to consumer credit.  In keeping with its mandate to report regularly to the dti, the NCR commissioned Feasibility to update this research and gain an in-depth understanding of market practices in 2010.  The NCR specified the need to examine market practices with a view to probing the consumer experience in obtaining and repaying credit. As a consequence, both mystery shopping and focus groups with indebted consumers formed part of the research method. The different life-cycle stages of the credit relationship – beginning with advertising and ending with the termination of the contract was a useful point of departure in understanding consumer behaviour. Client: The National Credit Regulator of South Africa
Download the document pdf here 800KB.

The case for change – imperatives to moving to the NCA and assessing the impact of the NCA

The sub-prime crisis in the US stimulated debate, discussion and policy change regarding the protection of consumers in credit transactions. South Africa’s National Credit Act was a seen as international best practice and Dr. Hawkins was among the knowledge specialists invited to present at the Consumer credit symposium hosted by one of the US advocates for the matter, Patricia McCoy, at the University of Connecticut.
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Consumer protection

Emid/Nomad/Bankserv matter before the Competition Tribunal South Africa (2013-2014)

Feasibility was appointed by the Competition Commissioner to compile an expert report and to appear as expert witness for the Commission in the matter before the Tribunal. BankservAfrica is currently South Africa’s only Payment System Operator. In August 2010, the Competition Commission approved the Bankserv/Emid and Bankserv/Nomad mergers, with conditions (the 2010 conditions) and an understanding that the National Payment System Department of the SA Reserve Bank would implement the “hold separate” conditions. As a consequence of these mergers, BankservAfrica began operating as a System Operator, which had competition implications. On the basis of a review application by ASO (Association of System Operators), the Tribunal remitted the conditions back to the Commission for reconsideration, which were published in August 2013 (the 2013 conditions). Dr Hawkins reviewed the extensive record on the matter and prepared an expert report. The matter was settled, shortly before the Tribunal hearing, on 1st April 2014. Client: Competition Commissioner South Africa, Mr Bakhe Majenge, Principal Legal Counsel

Treating Customers Fairly (2009 –2013)

The regulatory authority in the non-banking financial services, the Financial Service Board is pursuing a Treating Customers Fairly programme similar to that currently being implemented in the UK. The project has evolved into a multi-year project. Feasibility produced the discussion paper that examines the elements of the TCF-programme and considered its application in South Africa. Subsequently Feasibility produced a roadmap for implementation and designed and conducted the self-assessment industry pilot. The final phase of the project involved a process of embedding TCF within the regulator. Client: Financial Service Board
Download the document pdf here 700KB.

Payment experience of social grant recipients (2011)

This was research undertaken during the 8 month period where Dr. Hawkins facilitated the Policy and Consumer Protection themes for Finmark Trust, an NGO interested in formal financial inclusion. The research focused on how grant recipients made and received payments and their use of formal financial services. Dr Hawkins managed the consultant and evaluated the final research outcomes.  FinMark Trust launched the The experience of Social Grant recipients – a demand side study  in June 2012.  This report was undertaken for the National Treasury. Client : FinMark Trust
Download the document pdf here 2MB.

Competition in the banking and MFI sectors in Kosovo (2012)

Conducted research and submitted report on the competition and outreach of banks and MFIs in providing appropriately priced financial services and credit to the citizens of Kosovo. The report formed part of the broad analysis of Kosovo’s financial sector as part of the World Bank’s FSAP Mission in October 2012. Client: World Bank

Enquiry into Competition in Banking (2008-2009)

Dr Hawkins was the Advisor to the Enquiry Panel which provided a forum for consumers, banks, payment providers and other stakeholders to submit information and concerns regarding bank charges. Two series of public hearings were conducted around the country.  She designed and evaluated a detailed costing survey for the banks, as well as other information sheets, which formed the quantitative base of the analysis. In excess of 100 individual engagements and consultations with stakeholders were held. A 600-page report was produced which included 28 recommendations. Visit website:  www.compcom.co.za

National Payment System and Competition in Banking (2006)

This report was a sequel to the Competition in Banking Report (2004), for the National Treasury and the SA Reserve Bank - aimed at researching aspects of competition and the role of the national payment systems in underpinning the current structures of the industry. Its recommendations led directly to the Banking Enquiry into bank charges and the national payment systems by a panel appointed by the Commissioner.  Read the article The National Payment System and Competition in Banking published in FinWeek Magazine, June 2006.
Client: Competition Commission
Download the document pdf here 45KB.

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Financial sector structure, inclusion and and regulation

Twin Peaks of Financial Regulation

Feasibility was commissioned to undertake a study into the appropriate regulatory framework for the South African financial sector in 2004. The research was presented to the then Minister of Finance and the Governor of the South African Reserve Bank in December 2004. The debate was around the relative benefits and weaknesses of the Twin Peaks regulatory framework versus a Single mega regulator. At the time, the SA Reserve Bank strongly supported a Twin Peaks framework, although policy opinion was divided and no decision was taken.

The sub-prime crisis revealed the weaknesses of a single mega-regulator, such as the Financial Services Authority (FSA) in the UK. In the light of this, the National Treasury released a policy paper on a Twin Peaks framework for financial regulation in 2011. Following this a seminar was hosted by the Financial Regulatory Reform Steering Committee, SA Reserve Bank, Pretoria. Dr Hawkins was invited to present on the topic: Market Conduct Supervision for the Twin Peaks Regime
Download the document pdf here 200KB.

The role of agency banking report in financial inclusion (2011)

Following the announcement by the Minister of Finance that 70% of adults should have access to a bank account by 2013, the National Treasury requested research into agency banking to further improve financial inclusion.  The report set out what is meant by agency and branchless banking, both internationally and locally and identifies reasons for barriers to the success of agency banking in South Africa, and provides recommendations for improving access. Client:  FinMark Trust / National Treasury
Download the document pdf here.

Financial access: what has the crisis changed? (BIS Papers 56/2011)

Presented a paper for the Central banking in Africa: prospects in a changing world roundtable discussion hosted by the Bank for International Settlements. The global financial crisis and the recession have provided an opportunity to reflect on the role of firms, markets and central banks. As the crisis has shown, while access to inappropriate credit may undermine financial stability, the view put forward here is that provision of appropriate products to consumers in general is a necessary condition for successful implementation of financial stability measures. The paper identifies approaches that may promote appropriate access by central banks and highlights some African success stories.
Download the document pdf here 150KB.

Financial Access and Financial Stability (2006)

The Bank for International Settlements hosted an informal meeting among governors where several key policy issues were analysed: the challenges of increased financial inflows; the interaction between central bank and government; the choice of anchors of monetary policy; financial access and financial stability; the implementation of Basel II and the management of the exchange rate.  Feasibility was invited to deliver a paper at this meeting exploring financial access and financial stability.  An issue that must be considered is whether wider access to formal financial services will jeopardise financial stability. Feasibility’s paper takes the view that the promotion of access will enhance financial stability in both the long and the short run. The paper also identifies those areas where central bank involvement can promote such a mutually reinforcing process.  Papers delivered at the meeting have been published in a special conference volume, Central banks and the challenge of development. www.bis.org Client:  Bank for Internal Settlement
Download the document pdf here 70KB.

An analysis of access standards to financial services in SA (2004)

In the light of the Financial Sector Charter process, it was necessary to define the standards by which financial institutions would be evaluated in terms of their commitments to provide for the majority of consumers. Feasibility conducted a study into international best practice and evaluated proposed standards presented by the Industry Associations. Feasibility worked on the principle that the standards had to make sense for both consumers and the industry, as well as facilitate ‘betterment’ of the individuals served. The standards were accepted by the Financial Sector Charter Council as a mechanism to evaluate outreach by reporting firms. Client:  Access and Standards Committee of Financial Sector Charter Council

The measurement of consumer access to financial services in South Africa (2009)

Invited paper, International Statistical Institute Conference, Durban.
A panel on measuring financial access included presentations from Mexico and Chile and included mechanisms set in place by the Central banks of these countries. Dr Hawkins presented the South African perspective on the matter.
Download the document pdf here.

A review of the functioning of the Cooperative Banks Development Agency (2010)

Feasibility conducted a review of the functioning of the Cooperative Banks Development Agency, its outreach and role and recommendations to improve its functioning. Client:  National Treasury

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Southern Africa

Enhancement of transparency of fees/charges in the commercial banking sector in Namibia (January – June 2015).

The Namibian Payment Systems Management Amendment Act, 2010 provides for the Bank of Namibia to put in place regulations for fees and charges related to payment services by commercial banks. In order for them to set well-informed and accurate guidelines they need to gather accurate data/information. Feasibility was appointed to develop a Dynamic Competition Scheme tool that would enable the BON to collect and analyse relevant data and information. The methodology includes desktop review, interviews and survey based data collection. Client:  Bank of Namibia sponsored by GIZ (German Development Cooperation)

The impact of interest rate caps and implications for credit market regulation in Zambia (2014)

The Zambian government imposed credit caps on all lending by banks and non-banks in January 2013. This research report is an analysis for the Bank of Zambia to examine the market outcomes since the imposition of the caps and the extent to which the caps have furthered the policy aims of lower effective interest rates, improved access to credit for small enterprises and reduced over-indebtedness. The paper makes several policy recommendations regarding future credit regulation in the country. Client:  World Bank

MFI Landscape Mapping Report and the MFI Policy Framework (2014)

The ultimate objective of the (temporary) Microfinance Unit was to develop a policy framework that would meet the needs of the sector and micro enterprise in Swaziland. Feasibility developed a comprehensive MFI Landscape Mapping Report detailing the definition and characterization, current concentration and potential contribution of the sector to economic development & growth, and used this analysis to create the draft Microfinance Policy Framework. Client:  Microfinance Unit, Ministry of Finance, Kingdom of Swaziland.

Development and Technical assistance for the Drafting of the Swazi Consumer Credit Bill (2012)

The brief was to bring the law on credit into conformity with the Swazi Constitution, the Financial Services Regulatory Authority Act, 2010 and other laws so as to promote a fair and equal access to credit products in the Kingdom. Feasibility produced the first credit landscape report for the Kingdom, a legal overview report and a draft Policy Document. Client:  Ministry of Finance, Kingdom of Swaziland / FinMark Trust

Fees and charges for financial services in Namibia and their effect on the access of the poor and the MSME to these services (2010-2011)

Some policymakers within Namibia were of the view that the pricing of financial services in Namibia was a serious impediment to the ability of low income individuals in particular to access such services.  A study was conducted into the pricing and availability of financial services, and an evaluation of the role of market structures and regulations in perpetuating the disparity in the provision of financial services in the country.  The views of a representative sample of industry stakeholders were obtained and interrogated through the survey and interview processes.  The consumer focus groups were aimed at capturing the views of consumers within the target income range.  Towards the end of the project, a workshop was held with representatives of various stakeholder groups to present the results of the study and its recommendations and obtain feedback.  The study was funded by GIZ. Client:  Ministry of Finance (Namibia), Namfisa and Bank of Namibia
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Employment, growth and development

Economic impact of the National Credit Act (2012-2013)

The National Credit Act (NCA) of 2005 aims to promote and advance the social and economic welfare of South Africans, and can be seen as one of the most ambitious socio-economic experiments since democracy. This research evaluated in what way the NCA had an impact on the economy and South African consumers. The report concluded on a number of areas as to how the NCA affected the economy directly and indirectly and made a number of recommendations to the NCR. Client:  National Credit Regulator
Download the document pdf here 1.5MB

Estimation of the impact of the Global Economic Crisis on the South African Consumer Credit Market (2009)

This study entailed analysing trade trends and estimating, on the basis of scenarios, the possible impact of the GEC on employment levels.  This impact was then assessed on the basis of its likely impact on different consumer groups and the possible implications for different types of credit providers.  The implications for consumer credit policy were also examined. Client:  National Credit Regulator

Exchange rates, growth and employment (2007)

As part of its research into the impact of exchange rates on growth and employment, the Employment, Growth & Development Initiative of the HSRC, commissioned this research into the management of exchange rate risk by firms. Each of 40 firms from four sector clusters were individually interviewed in order to better understand how they manage the risk and influences associated with the exchange rate. Moreover, ten financial service providers were interviewed so as to better understand the range of services and uptake associated with financial instrument risk management of the currency. The clusters were Steel and steel products and household appliances; Wood and wood products, including furniture; Construction; and Tourism.  Full report available on http://www.hsrc.ac.za/en/research-data/view/3199 Client:  Human Science Research Council
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Hawkins, P. 2014 The visible hand: shaping stability and inclusion in the South African financial sector. The Oxford companion to the Economics of South Africa, ed H Bhorat, A Hirsch, R Kanbur & M Ncube. ISBN 978-0-19-968924-8. Oxford University Press, United Kingdom.
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Hawkins, P and Torr C. 2015. The South African banking sector. Understanding South African Financial Markets, Fifth Edition. ed K van Wyk, Z Botha & I Goodspeed. Van Schaik.

Hawkins, P and Torr C. 2011. The South African banking sector. Understanding South African Financial Markets, ed K van Wyk. Struik.

Hawkins, P. 2011. Financial access: what has the crisis changed? A note for a BIS meeting of African governors on “Central banking in Africa: prospects in a changing world” on Saturday 7 and Sunday 8 May 2011.
Download Hawkins BIS 2011

Hawkins, P and Torr C. 2008. The South African banking sector. Understanding South African Financial Markets, ed C van Zyl. Struik.

Hawkins, P. 2006.  Financial Access and Financial Stability.  Central banks and the challenge of development.  Bank for International Settlements.  May. 
Download Hawkins BIS 2006

Hawkins, P. 2006.  Tiered banking: a solution to exclusion.  CHF Occasional Papers Volume I. November. 

Hawkins, P. 2006. The National Payment System and Competition in Banking.  FinWeek Magazine. June.

Hawkins, P. 2006.  Competition and the National Payment System.  Bank charges.  The Big Issue Magazine, June. 

Hawkins, P. 2004. Savings and the Poor: Banking for all need not be a mirage. Business Day, 23 August.

Hawkins, P. 2004. Banking the unbanked: Extending access will pay off. Business Day, 13 August.

Hawkins, P. 2004. South Africa’s financial sector ten years on: Performance since democracy. Development Southern Africa.  March Vol 21 No. 1.

Hawkins, P. 2003. The Open Economy and its Financial Constraints. Cheltenham: Elgar.
Download Hawkins 2003

Hawkins, P. 2002. Banks and Small Business. South African Journal of Economics. March.

Hawkins, P and Torr, C. 2002. Unemployment in a small open economy, in Money, macroeconomic and Keynes, edited by P. Arestis, M Desai and S. C. Dow.  London: Routledge.

Hawkins, P. 2002. Liberalisation, Regulation and Provision: The implications of compliance with international norms for the South African Financial Sector.  TIPS Occasional Paper, Johannesburg.

Hawkins, P. 2001. Regulatory Pressures on the South African Financial Sector. Trade and Industry Monitor. March. Volume 17.

Hawkins, P. 2001. Banks’ liquidity preference and financial provision, in A Post Keynesian Perspective on Twenty First Century Economic Problems, edited by P Davidson. Cheltenham: Elgar

Hawkins, P. 1997. Imported capital goods and the small open economy, in Improving the Global Economy: Keynesianism and Growth in Output and Employment, edited by P. Davidson and J. A. Kregel. Cheltenham: Elgar: 265-282.

Hawkins, P. 1996. The dual role of investment in a small open economy. South African Journal of Economics, 64 (3): 193-215.

Mohr, P., Botha, M. & Hawkins, P. 1994. South Africa’s balance of payments in the 1980s, in The South African Economy in the 1980’s, edited by S. Jones and J. Inggs.Special issue of the South African Journal of Economic History, 9(2): 127-144.

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Growing awareness of the challenge that environmental degradation poses for societies and economies has led to the financial sector being challenged as to the role it can play in contributing to economic sustainability.  The United Nations has recently led and supported an Inquiry into a sustainable financial sector (2014-2015). The very title of the inquiry suggests that the financial sector can and ought to enable economic sustainability, and that this is what is expected of a well-functioning financial sector. This suggests a broad view of the role of a financial sector that goes beyond efficiency (in the sense of the lowest intermediation costs between saver and investor) and looks at the allocation of real resources. Moreover, it suggests that sustainability goes beyond financial stability, and includes social objectives around the protection, rather than degradation, of the environment. It is precisely the ability of banks and other financial intermediaries to influence the rate of investment that gives the financial sector a key role in society (Keynes, 1971, p. 327). But the question that the inquiry and other fora have recently raised is whether or not investment contributes to the sustainability of the planet.

But how does the financial sector enable sustainability? In particular, is it appropriate for policy and regulation to guide this role, or can we rely on the market forces of the financial sector (through the invisible hand) to deliver what is required? These questions were some of those recently tackled in a conference entitled Global Sustainability, Climate Change and Finance Policy, organized by the Centre for International Governance Innovation and the South African Institute for International Affairs and held in Johannesburg from July 1 to July 3. The discussion and debate that followed with a range of economists, social scientists, regulators, academics and practitioners, was summarised in a policy note.

Further reading:
A sustainable financial sector

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“The ideas of economists and political philosophers, both when they are right and when they are wrong are more powerful than is commonly understood. Indeed, the world is ruled by little else. Practical men, who believe themselves to be quite exempt from any intellectual influences, are usually slaves of some defunct economist.”
- John Maynard Keynes
“If only one person were perfectly informed there could never be a general crisis. But the only perfectly informed person is God, and he does not play the stock market.”
- Robert Skidelsky,
Keynes: The Return of the Master

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