Financial Access 2010

Financial
Access
2010
The State of
Financial Inclusion
Through the Crisis

FINANCIAL ACCESS 2010 i
THE WORLD BANK GROUP
Financial
Access
2010
The State of
Financial Inclusion
Through the Crisis

© 2010 by the Consultative Group to Assist the Poor/The World Bank Group
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FINANCIAL ACCESS 2010
Contents
Acknowledgments iv
Overview 1
Changes in access to financial services 5
Deposit services 5
Access to credit services 9
Physical outreach 11
Financial inclusion mandates 16
Consumer protection 23
Legal framework 24
Institutional structure 28
Dispute resolution mechanisms 31
Regional trends in consumer protection 33
SME finance: Supply-side data availability 35
Data availability 43
Methodology 45
References 47
Regional profiles 49
Statistical and policy tables 55
Consumer protection legislation 88

iv FINANCIAL ACCESS 2010
Acknowledgments
Financial Access 2010 was made possible by the generous contribution of
time and expertise by central bank and financial regulatory authority officials
in the 142 economies who responded to this year’s survey.
The report was researched and written by a team led by Nataliya Mylenko
and comprising Hédia Arbi, Oya Pinar Ardic, Kristine Cronin, Maximilien
Heimann, Joyce Ibrahim, and Valentina Saltane.
The report benefited from review by a panel of experts including Thorsten
Beck, Asli Demirgüç-Kunt, Gregory Chen, Susanne Dorasil, Erik Feyen,
Michael J. Fuchs, Michael Goldberg, Neil Gregory, Jake Kendall, Alexia
Latortue, Samuel Maimbo, Maria Soledad Martinez Peria, Ignacio Mas,
Atsushi Oshima, Douglas Pearce, S. Rajcoomar, Xavier Reille, Roberto
Rocha, Richard Rosenberg, Peer Stein, Jeanette Thomas, Marilou Uy, and
Kim Nguyen Van. Juan Carlos Izaguirre, Katharine McKee, and Sue Rutledge
provided guidance on the topic of consumer protection. The section on small
and medium enterprise finance data benefited from inputs from Joshua
Wimpey and Rita Ramalho.
World Bank regional staff assisted in the data collection process and provided
valuable guidance in the drafting of the report. Gerry Quinn designed the
report and the graphs. Anna Nunan proofread the report.

FINANCIAL ACCESS 2010 1
Overview
Financial Access 2010 is the second in a series of annu-al
reports by CGAP (Consultative Group to Assist the
Poor) and the World Bank Group to monitor statistics
for financial access around the world and to inform
the policy debate. The series was launched in response
to the increasing interest in financial inclusion among
policy makers and the development community. The
first report, Financial Access 2009, introduced statis-tics
on the use of financial services in 139 economies
and mapped a broad range of policies and initiatives
supporting financial inclusion.
Building on last year’s data, Financial Access 2010 reviews
survey responses from 142 economies, updates statistics
on the use of financial services, and analyzes changes that
took place in 2009—a turbulent year for the financial sec-tor
in most economies. In addition, Financial Access 2010
expands on last year’s work by reviewing three policy ar-eas
relevant to the current financial access debate: finan-cial
inclusion mandates, consumer protection in finan-cial
services, and access to finance by small and medium
enterprises (SMEs). The report does not intend to suggest
that these three topics are the most important ones for fi-nancial
inclusion. Rather, these topics are timely because
much of the discussion in the aftermath of the financial
crisis centered on the role of the government in finan-cial
services, financial consumer protection regimes, and
the urgent need for jobs. Consequently, the report seeks
to clarify the role of financial regulators in implement-ing
policies to support the financial inclusion agenda.
For the first time, it provides a detailed overview of the
main features of financial consumer protection regimes,
a topic of great interest to policy makers in the aftermath
of the financial crisis. Financial Access 2010 also surveys
availability of data on SME financing to contribute to the
global effort to improve the measurement of SME financ-ing
led by the G-20.1
Financial Access 2010 aims to contribute to the efforts
to measure financial access at the country level world-wide,
to develop a consistent database, and to present
the data in a coherent manner for future analyses. At
the same time, the report recognizes that not all institu-tions
that serve low-income and poor people report to
the financial regulators. However, evaluation of specific
policy interventions is beyond the scope of this report.
The positive relationship between financial develop-ment
and economic growth is well documented in the
literature.2 In more recent years, the debate has ex-panded
to include the notion of financial “exclusion”
as a barrier to economic development and the need for
building inclusive financial systems.3 Recent empirical
evidence using household data indicates that access
to basic financial services such as savings, payments,
and credit can make a substantial positive difference in
poor people’s lives.4 For firms, especially SMEs, lack of
access to finance is often the main obstacle to growth.5
Access to basic financial services continued
to improve, albeit at a slower rate, as the
financial crisis took its toll
Nearly 60 percent of the economies experienced a con-traction
in real per capita income in 2009 as a result of
the deepening of the global financial crisis. Worldwide
volume of deposits and loans shrank, with a median
decrease of 12 percent in the ratio of deposit value to
gross domestic product (GDP) and a median decrease
of 15 percent in the ratio of value of loans to GDP. De-spite
this fact, Financial Access 2010 finds that use of
basic deposit services expanded, showing a 4 percent
median growth rate in the number of deposit accounts
per 1,000 adults. Use of credit services suffered more
from the crisis, and on average, the number of loans
per 1,000 adults remained broadly unchanged between
2008 and 2009.
A simultaneous increase in the number of accounts
and decrease in the value of deposits support the view
that access to savings and payment services is a basic
need. The use of these services is inelastic with respect
to the macroeconomic conditions. This finding under-scores
the need to promote access to basic payments
and savings services as essential tools in an increas-ingly
digitized and globalized world.
Physical outreach of the financial system, consist-ing
of branch networks, automated teller machines
(ATMs), and point-of-sale (POS) terminals, expanded
in 2009. ATM and POS networks expanded faster than
bank branches. The macroeconomic situation strong-ly
influenced changes in retail infrastructure, and
economies hit by the crisis saw bank branches close.

2 FINANCIAL ACCESS 2010
Low- and middle-income countries lag behind
high-income countries in terms of the number of
bank branches, ATMs, and POS terminals. How-ever,
the number of ATMs exceeded the number
of bank branches for the first time in low-income
countries. New technological developments and
the expansion of electronic payments through
mobile and Internet banking offer hope for
bringing financial services closer to clients.
Even though access to deposit services continued
to expand, data analysis points to the importance
of macroeconomic and financial stability for ac-cess.
Further research is needed to better under-stand
the transmission channels and potential
feedback loops between financial stability and
access and to identify policy solutions aiming to
balance both objectives in a sustainable manner.
Financial inclusion mandates are on the
agenda of many financial regulators
and reform efforts are widespread, but
implementation capacity is often limited
Over the past year, government interest in finan-cial
inclusion has heightened in many countries.
This interest spans from promotional activities
to encourage savings or access to financial ser-vices
in rural areas to the establishment of new
regulations or financial capability programs.
Data from the Financial Access 2010 survey
show that in 90 percent of economies, at least
some aspect of the financial inclusion agenda is
under the purview of the main financial regula-tor.
Consumer protection and financial literacy
issues, often as a part of standard conduct of
business regulations and supervision mandates,
are the most common areas of focus across all
income groups and regions. Financial regulators
in low- and middle-income countries are more
likely to focus on promoting access to deposit
and credit services.
But financial regulators do not always have suf-ficient
authority and resources to implement a
broad financial access agenda. The survey uses
the existence of an allocated team or unit as a
proxy for implementation capacity. On average,
across the financial inclusion topics surveyed,
only about 80 percent of economies with re-sponsibility
for a financial access area have an
allocated team or unit implementing the policy.
The capacity gap is larger in low-income coun-tries,
with the paradox that it is precisely in these
economies that the agenda is broader. Taking a
systematic approach and having a clear financial
access strategy as an organizing principle for im-plementing
financial access reforms may help in
planning resources better. The Financial Access
2010 data indicate that economies with financial
inclusion strategies are more likely to cover more
topics and have allocated resources.
Consumer protection: Legislation
is in place, but implementation and
enforcement are often lacking
One key message that can be taken from the
global financial crisis has been the lack of sound
financial regulations, including consumer pro-tection.
The number of legislative and institu-tional
reforms introduced in recent years show
that consumer protection has garnered the atten-tion
of policy makers worldwide. Many econo-mies
are introducing new regulations requiring
information disclosure on financial products to
the consumer and curtailing abusive practices
against consumers. Financial Access 2010 finds
that in 118 out of 142 economies responding to
the survey, some form of financial consumer pro-tection
legislation is in place.
But legislation is often broad and does not cover
issues specific to the financial industry. Only half
of the economies have legal provisions restrict-ing
unfair and high-pressure selling practices
and abusive collection practices. The require-ment
to periodically disclose account informa-tion
is present in half of the economies that have
a requirement for account opening. In most
cases, regulations do not apply to unregulated
financial service providers.

Lack of resources, institutional capacity, and enforce-ment
powers obstruct the effective implementation
of consumer protection legislation. The data provided
by financial regulators via the Financial Access 2010
survey show a stark discrepancy between the stated
requirements and the available enforcement powers,
capacity, and mechanisms. Regulators in only about
half of the economies are empowered to issue warn-ings
or impose fines on financial institutions violating
consumer protection regulations. A public notice of
violation—one of the most effective deterrence tools—
can be used in only about a third of economies. Regu-lation
and supervision of consumer protection issues
are often part of broader business conduct regulations
and supervision mandates, with neither resources nor
teams specifically dedicated to the issues of financial
consumer protection. Among regulators with an over-sight
responsibility in consumer protection, only about
two-thirds have an allocated unit or team working on
consumer protection.
The success of enforcement also depends on active con-sumers
who are willing to seek recourse when they feel
they have been treated unfairly by financial institutions.
Therefore, effective dispute resolution mechanisms are
essential to implementation of the law. Yet such mecha-nisms
are not very common: Only 58 percent of econo-mies
reported the existence of a third-party dispute
resolution mechanism. Where available, the effective-ness
of such mechanisms is hard to evaluate because
not many economies keep track of the number of com-plaints
received and disputes resolved.
SME finance: Many regulators collect
statistics on SME finance volumes, but lack of
a consistent definition makes global estimates
challenging
Ensuring that households have access to a broad range
of financial services is a critical objective of the financial
inclusion agenda. Expanding access to financial services
to SMEs is another. For the first time, Financial Access
2010 asked financial regulators whether they collect in-formation
on SME finance and how they define SMEs.
Financial regulators in two-thirds of economies re-port
collecting SME finance data. In many countries,
financial regulators are well placed to collect SME
lending data as part of regular reporting by financial
institutions. This year 50 economies provided data
on the volume of SME finance using their national
definition. Data analysis indicates that further efforts
are necessary to define the criteria and processes for
the collection of data on SME financing to facilitate
cross-country comparison. The SME finance subgroup
under the G-20 Financial Inclusion Experts Group,6
bringing together international experts, development
agencies, and governments to establish a comprehen-sive,
consistent, and scalable framework to measure
and track the progress over time of SME access to fi-nancial
services in the developing world, is promising
in this regard.
Based on the data provided by regulators this year,
global volume of SME finance is an estimated $10 tril-lion.
To put this number into perspective, it is roughly
two-thirds of the current size of the U.S. economy.
The bulk of this estimated SME lending volume—70
percent—is concentrated in high-income OECD (Or-ganisation
for Economic Co-operation and Develop-ment)
countries. The SME finance segment is small in
relation to the size of the GDP in low- and middle-income
countries compared with that of high-income
countries. The median ratio of SME loans to GDP in
high-income countries is 13 percent, compared with
only 3 percent in developing countries.
notes
1. The Pittsburgh G-20 Summit (2009).
2. See, for example, Beck, Levine, and Loayza (2000), Beck,
Demirgüç-Kunt, and Levine (2004), Demirgüç-Kunt and Mak-simovic
(1998), King and Levine (1993), and Klapper, Laeven,
and Rajan (2006).
3. Beck, Demirgüç-Kunt, and Martinez Peria (2008b).
4. Caskey, Durán, and Solo (2006); Dupas and Robinson (2009).
5. Schiffer and Weder (2001); Cressy (2002); IADB (2004); Beck,
Demirgüç-Kunt, and Levine (2005); Beck and Demirgüç-Kunt
(2006); Beck, Demirgüç-Kunt, and Martinez Peria (2008a).
6. See the Pittsburgh G-20 Summit (2009), “Leaders’ Statement,”
paragraph 41.

MAP 1.1
Percentage of banked households, 2009
% of households with a deposit account
in a formal nancial institution
0–25
25–50
50–75
75–100
NO DATA
Europe
Central Asia
50%
High-Income OECD
and Non OECD 91% East Asia
Pacic 42%
Middle
East
North
Africa
42%
Latin America
Caribbean 40%
South
Sub-Saharan Asia 22%
Africa 12%
Note: OECD = Organisation for Economic Co-operation and Development
The map uses data from household surveys including Living Standard Measurement Surveys where available, as well as
regional sources: for the EU, the European Commission’s Eurobarometer, Special Barometer 260 (2007); for Africa,
FinMark Trust’s FinScope; for Latin America, Tejerina and Westley (2007) and the MECOVI database and Barr et al. (2007);
and Nenova et al. (2009). For countries for which these data are unavailable, predictions based on an econometric model
with number of deposit accounts per 1,000 adults and number of branches per km2 from the Financial Access database
are used. See the section on Methodology for more details. Data for Taiwan (China), Hong Kong SAR (China), and Puerto
Rico (US) have been broken out from the national dataset.

Changes in access
to financial services
Deposit services
Access to deposit services varies greatly across differ-ent
parts of the world. Financial Access 2010 estimates
that about half of the households in the world have
no access to a bank account. The immediate—and
obvious—consequence of this situation is that the
poor have to rely on informal financial services that
may be more costly and less reliable. This inequality
robs people, especially the poor and most vulnerable,
of important options to manage their irregular cash
flows and smooth consumption.1 At the more macro
level, low levels of financial inclusion represent an
obstacle to economic development.2 Consequently,
financial inclusion has become an important topic in
the development agenda.
How many people use deposit services offered
by commercial banks?
Map 1.1 gives a broad view of access to deposit ser-vices
around the world. The map plots the percentage
of households that have a deposit account in a formal
financial institution using information from various
household surveys and estimates based on the data
from the Financial Access 2010 survey.3 To identify
gaps in access, one would ideally evaluate information
on the number of individuals using various types of
financial services, preferably disaggregated into socio-economic
groups. Though household surveys some-times
provide this information, it is not available for
a large enough number of economies to enable us to
assess the global picture.4 Nonetheless, data collected
through the Financial Access 2010 survey combined
with the information from existing household surveys
allow us to estimate that 49 percent of households—
or about half of the world—have deposit accounts in
formal financial institutions.
Almost all economies in Sub-Saharan Africa are below
this world average, whereas high-income countries are
above it. Sub-Saharan Africa and South Asia are the
regions with the lowest share of banked households.
The percentage of households having deposit accounts
in a formal financial institution varies greatly across
countries, from below 1 percent in the Democratic
Republic of Congo and Afghanistan to close to 100
percent in Japan.
The number of deposit accounts continued
to expand despite the crisis, though deposit
volume declined significantly
In 2009 as the global financial crisis unfolded, about
60 percent of economies experienced a decline in real
per capita GDP, and for those that went through ex-pansions,
median growth was only 2.1 percent.5 Dete-riorating
macroeconomic conditions affected the de-posit
volume around the globe as individuals and firms
had to tap into their savings. Seventy-seven percent
of economies in the Financial Access 2010 database
experienced a decline in deposit-to-GDP ratio, with
an average decline of 11.8 percent. The overall world
deposit-to-GDP ratio decreased from 72 percent at the
end of 2008 to 66 percent at the end of 2009.6
FIGURE 1.1
More accounts, less money in commercial banks
% change, 2008–09
Number of
deposit accounts
per 1,000 adults
2008
Commercial
bank deposits / GDP
4.3
–11.8
Source: Financial Access database.

FIGURE 1.2
Lower deposit values, more deposit accounts in most regions
–22
ECA
–12
HI
–10
LAC
Region
–18
MENA
2
SA
–12
SSA
Yet even in the midst of the crisis, the use of financial
services continued to expand. The number of deposit
accounts per 1,000 adults increased in 69 percent of
the economies reporting data. The world as a whole
added 65 accounts per 1,000 adults in 2009, which is
roughly a 10 percent increase in the median number
of accounts per 1,000 adults. Growth has been uneven
across countries, however, and the median change was
only 4.3 percent (figure 1.1).7
Changes in volume of deposits and number of deposit
accounts differ substantially across regions (figure 1.2).
Economies in Eastern Europe and Central Asia, where
the financial system was severely affected by the crisis,
show the largest median drop in deposit-to-GDP ratio
at 22 percent. At the same time, South Asia experienced
a marginal increase in the median deposit-to-GDP
ratio. Sub-Saharan Africa, the region with the lowest
level of deposit account penetration, experienced the
second largest median increase in the number of de-posit
accounts per 1,000 adults, surpassed only by Latin
America and the Caribbean. The number of accounts
per 1,000 adults on average increased in all regions
8
SSA
–3
EAP
–1
ECA
4
HI
8
LAC
Region
except for East Asia and the Pacific and Europe and
Central Asia. Note that these regional averages should
be interpreted with caution because of differences in
intraregional variation, as figure 1.2 displays.
The variation in changes in the number of deposit
accounts and the volume of deposits exhibit simi-lar
patterns across income groups. Middle-income
and high-income countries on average experienced a
larger decline in volume of deposits as a percentage of
GDP than did the low end of the world income dis-tribution,
mostly because of the effect of the financial
crisis. Though the largest median increase in deposit
account penetration is observed in the poorest 20 per-cent
of countries, the richest 20 percent have seen only
a slight expansion.
Expansion of access to deposit services
Because of endogeneity issues involved with the cross-country
regression framework and data limitations
(especially in terms of time dimension), uncovering
statistically significant causal effects in the current
20
0
–20
–40
20
0
–20
–40
–8
EAP
Note: EAP=East Asia and the Pacic region, ECA=Europe and Central Asia region, HI=High-Income OECD, LAC=Latin America and the Caribbean region,
MENA=Middle East and North Africa region, SA=South Asia region, and SSA=Sub-Saharan Africa region
3
MENA
1
SA
Number of deposit accounts per 1,000 adults
% change, 2008–09
Commercial bank deposits / GDP
% change, 2008–09

context is not possible. Hence, rather than drawing
conclusions about causal relationships, Financial Ac-cess
2010 focuses on investigating correlations and
partial associations between country-level variables.
The analysis of the changes in the number of depos-it
accounts per 1,000 adults between 2008 and 2009
highlights the importance of macroeconomic stability
and growth for improving financial access. The change
in the number of accounts per 1,000 adults is strongly
positively correlated with macroeconomic outlook,
measured by short-run forecasts of real per capita
GDP growth.8 In addition, lower deposit penetra-tion
at the end of 2008 is positively associated with a
greater change in the number of deposit accounts per
1,000 adults. Figure 1.3 plots this negative association
between deposit penetration at the end of 2008 and
the change in the number of accounts in 2009 after
controlling for expected real per capita GDP growth.
The results indicate that access to basic deposit servic-es
continues to improve, but macroeconomic stability
and growth are essential for sustainable improvement
in financial access.
Macroeconomic factors, physical
infrastructure, and the structure of financial
markets play an important role in deposit
penetration
Consistent with previous research, cross-country anal-ysis
using Financial Access 2010 data indicates that a
number of macroeconomic factors are correlated with
the level of deposit account penetration.9 Income per
capita is strongly correlated with the number of de-posit
accounts. A 1 percent change in GDP per capita
is associated with a change of around 0.3 to 0.6 percent
in the number of deposit accounts per 1,000 adults.
Branch penetration and the existence of explicit de-posit
insurance are also positively related to deposit
account penetration.
Physical infrastructure indicators, including elec-tricity
consumption, phone lines, and the number of
landline and cell phone users, are all positively related
to the number of branches and to deposit penetration,
indicating that a better developed infrastructure and a
higher degree of deposit penetration go hand in hand.
The legal environment, measured by the index of the
strength of legal rights for borrowers and lenders, is
also closely related to deposit penetration. A favorable
legal environment for lending may enable banks to
operate more profitably through lending and to grow,
eventually leading to expansion of deposit services.10
A greater degree of competition, proxied by the con-centration
ratio in the banking sector, is associated
with greater deposit penetration. This is in line with
earlier studies arguing that competition in the bank-ing
sector would increase efficiency and, in turn,
would lead to a larger variety of products and services
offered to a larger depositor base.11 The analysis of the
correlation between interest rate spread (lending rate
minus deposit rate) and deposit account penetration
lends support to this argument. Economies with lower
interest rate spreads also show a higher number of de-posit
accounts per 1,000 adults.
FIGURE 1.3
Financial inclusion: Change in deposit penetration is larger
for economies with fewer initial deposit accounts
% change, deposit accounts per 1,000 adults, 2008–09
Higher
Lower
Fewer Greater
Number of deposit accounts per 1,000 adults
Note: Correlation controls for expected real GDP growth in 2009–10. The relationship is signicant
at the 5 percent level.

Analysis of the volume of deposits normalized by GDP
offers further insight into the factors affecting finan-cial
access. Although inflation, as a proxy of macro-economic
stability, is not significantly correlated with
the number of deposit accounts, it is negatively related
to deposit volume. In other words, macroeconomic
stability seems to matter for the decision of how much
money to put in the bank account, but not for hav-ing
an account at all. This result is consistent with the
evidence of a simultaneous decrease in deposit vol-ume
and increase in number of accounts despite the
financial crisis. It also supports the view that a deposit
account is a basic service, and having one is inelastic
with respect to macroeconomic disturbances.
Banks versus nonbanks
and access to deposit services
Not surprisingly, central banks and financial regulators
have the most complete information on commercial
banks as they are often the institutional type most di-rectly,
and for the longest time, under the purview of
the regulators. However, many nonbank institutions
also provide financial services and some even have spe-cific
financial inclusion mandates. These include coop-eratives,
specialized state financial institutions, and mi-crofinance
institutions. Robust analysis of the changes
in the number and volume of deposits between banks
and nonbanks is challenging because of data limita-tions
for nonbanks. The challenge is threefold. First,
in a number of economies information on nonbanks is
not available. Second, financial institutions in a number
of economies changed their status or new institution
types were introduced contributing to breaks in a time
series. Third, only partial data on each nonbank group
may be available, distorting comparison of banks and
nonbanks within the system. Once economies with
data inconsistencies are excluded, the resulting subset
of economies with comparable data for each institu-tional
category is small. For example, for cooperatives
only 20 economies have comparable data for a change
in the number of deposit accounts; for specialized state
financial institutions it is 22; and for microfinance insti-tutions
only 8 economies have comparable data. Statis-tical
FIGURE 1.4
Commercial banks hold most deposits by volume
% of total volume by type of institution and depositor
Deposits in nonbank
institutions
Deposits in
commercial
banks 85%
Individual
deposits
62%
Individual
deposits
13%
Business
deposits
2%
Business
deposits
23%
analysis shows that among nonbanks, the change
in the number of accounts is different from zero only
for state specialized financial institutions. Moreover,
the changes in the number of accounts in commercial
banks and in state specialized financial institutions are
not different from one another.
The majority of the deposits by number and volume are
held in commercial banks: 85 percent of total deposit
volume and 96 percent of all deposit accounts (figure
1.4). Often a country’s legal framework does not allow
any other institutions to take deposits. But in a num-ber
of economies nonbanks play an important role in
providing basic deposit services. For example, in Bu-rundi,
Chile, Spain, and France, cooperatives or spe-cialized
state financial institutions hold more deposit
accounts than do commercial banks. And in a num-ber
of West African countries—Benin, Burkina Faso,
Côte d’Ivoire, and Niger—deposit-taking microfinance
institutions have more depositors than do commercial
banks, which suggests that nonbanks can be an impor-tant
player in providing basic deposit services.
Individual deposits account for 75 percent of the total
volume and 96 percent of the number of accounts. Indi-vidual
deposits represent a greater share of deposit vol-ume
than do firm deposits in banks (73 percent) and in
nonbank financial institutions combined (86 percent).

Access to credit services
Number of loan accounts broadly stayed
unchanged, but lending volumes declined
significantly
Credit services fared much worse than deposits in 2009.
Indeed, the global financial crisis took its toll on access
to credit services, with the value of loans as a percent-age
of world GDP declining from 74 percent to 65 per-cent.
12 In about 85 percent of economies, loan volume
as a share of GDP declined in 2009. At the same time
throughout the year, the number of outstanding loans
per 1,000 adults remained more or less unchanged.
Figure 1.5 plots changes in loan volume and number of
outstanding loans in commercial banks.
These averages conceal a substantial degree of variation
across economies and regions (figure 1.6). The number
of outstanding loans per 1,000 adults decreased in 57
percent of the economies. While the changes are posi-tive
on average in the Middle East and North Africa,
declines are observed, on average, in Europe and Cen-tral
Asia and South Asia. All economies in the Middle
East and North Africa, except for Israel, have under-gone
expansions in the number of outstanding loans.
Conversely, all economies in Europe and Central Asia,
except for Albania and Turkey, have had contractions
in the number of outstanding loans.
FIGURE 1.5
Loan volume of commercial banks fell by 15% in 2009
% change, 2008–09
Number of
loan accounts
per 1,000 adults
2008
Loan volume / GDP
–1.4
–15.2
FIGURE 1.6
Changes in volume and number of loans vary widely
across regions
Commercial bank loans / GDP
% change, 2008–09
40
30
20
10
0
–10
–20
–30
–40
–50
–11
–9
–27
–9
–18 –18
EAP ECA HI LAC MENA SA SSA
Region
Number of loan accounts per 1,000 adults
% change, 2008–09
50
40
30
20
10
0
–10
–20
–30
10
–1 –1
–6
EAP ECA HI LAC
Region
–13
–2
–10
12
MENA SA SSA
Note: EAP=East Asia and the Pacic region, ECA=Europe and Central Asia region,
HI=High-Income OECD, LAC=Latin America and the Caribbean region,
MENA=Middle East and North Africa region, SA=South Asia region,
and SSA=Sub-Saharan Africa region

FIGURE 1.7
Higher growth in loan accounts is associated with fewer accounts and with expectations of economic growth
% change, loan accounts per 1,000 adults, 2008–09
The differences in median changes in commercial
bank loan volume (as a percentage of GDP) show less
variation across economies than median changes in
the number of loans. Loan volume as a percentage of
GDP dropped in all regions. Europe and Central Asia,
heavily affected by the financial crisis, suffered a sharp
decline in loan volume, with all the economies in the
region for which data are available experiencing drops
in loans-to-GDP ratios ranging between 19 percent
and 52 percent. The hardest hit country in the region
is Tajikistan, where loans declined from 18 percent of
GDP to less than 9 percent. Even in Belarus, where the
decline seems more modest, the loans-to-GDP ratio
fell from 47 percent to 38 percent.
Macroeconomic stability and economic growth
are critical for the expansion of credit
What factors are associated with changes in credit ser-vices
in 2009? Economies with higher expected GDP
levels are more likely to experience an increase in the
number of loans per 1,000 adults.13 This also means
that economies where macroeconomic expectations
are negative are more likely to experience decreases in
loan numbers as demand shrinks and banks tighten
% change, loan accounts per 1,000 adults, 2008–09
supply as credit quality deteriorates. Increase in loan
penetration is larger for economies with a smaller
number of outstanding loans to start with, indicat-ing
that even after controlling for expected GDP—a
proxy for macroeconomic stability—access to credit
continues to expand. The implications of these results
are twofold. First, similar to deposit services, there is
evidence that access to financial services is improving.
Second, macroeconomic stability is fundamental for
access to credit services (figure 1.7).
Macroeconomic factors, physical
infrastructure, and the structure of financial
markets are correlated with loan penetration
level
Cross-country analysis using the data on the level of
credit indicators in Financial Access 2010 is broadly
consistent with earlier research.14 Loan penetration,
measured by the number of loan accounts per 1,000
adults, is positively associated with GDP per capita;
population density; branch penetration; physical in-frastructure
indicators, such as phone lines per capita;
and financial infrastructure, such as credit information
and creditor rights.
Higher
Lower
Fewer Greater
Number of loan accounts per 1,000 adults*
Higher
Lower
Low High
Expected GDP**
* Correlation controls for expected GDP in 2009. The relationship is statistically signicant at the 5 percent level.
** Correlation controls for number of outstanding loans per 1,000 adults in commercial banks. The relationship is statistically signicant at the 5 percent level.

The link between loan penetration and banking sector
concentration is negative, indicating that more com-petitive
banking markets have higher levels of credit
access. Better creditor rights and comprehensive credit
information systems are associated with greater access
to financial services. There is also a positive link be-tween
the existence of explicit deposit insurance and
loan penetration. Similar to the effect of credit rights
on deposits, this indicates that to improve access to
financial services, a favorable business climate that
supports both deposit and loan services is essential.
Sustainable improvement in access to credit is possible
only if sustainable financial institutions are able to ef-fectively
manage both the asset and liability sides of
their balance sheets.
in access to credit services
Credit services are typically less regulated than deposit
services, with unregulated credit grantors providing a
substantial but often unaccounted-for portion of the
credit volume in many economies. As a result, it is
more difficult to estimate overall number of credit us-ers
than the number of depositors.
Comparison of the data provided by regulators on
loans granted by banks and nonbanks is difficult for
the same reasons highlighted earlier with regard to
deposit services. The subset of economies with com-parable
data on the number of loans includes only 19
economies.15 The numbers are even smaller for spe-cialized
state financial institutions and microfinance
institutions: 15 and 7 economies, respectively. In all
cases, average percentage change in the number of
loans is not statistically significantly different from
zero, similar to commercial banks.
Physical outreach
Physical outreach of the financial system
expanded in 2009
Global retail networks, consisting of financial institu-tion
branches, ATMs, and POS terminals, expanded
last year. In 2009 the world on average added about
one bank branch, five ATMs, and 167 POS terminals
per 100,000 adults.16 This growth was not universal,
however. The number of bank branches decreased in
43 percent of economies, about half of which are high-income
and Eastern European economies. The number
of ATMs decreased in 16 out of 104 economies, and the
number of POS terminals decreased in 13 out of 77.
Growth in the retail network varied across regions and
income groups. Low-income countries show the highest
rates of growth in the number of bank branches, ATMs,
and POS terminals, which is another sign of improved
access to financial services. Africa, South Asia, and the
Middle East, the regions with the lowest levels of retail
network outreach, show higher rates of growth in the
number of bank branches and ATMs (figure 1.8).17
FIGURE 1.8
Retail networks grew fastest in low-income countries
and in regions with limited retail network coverage
% change in the number of commercial bank branches,
ATMs, and POS terminals, 2008–09
0 10 20 30
%
40 50
Low-income
Middle-income
High-income
High-Income OECD
Latin America Caribbean
Europe Central Asia
East Asia Pacic
Sub-Saharan Africa
Middle East North Africa
South Asia
Commercial bank branches
ATMs
POS terminals

FIGURE 1.9
Bank branches increased most in less developed networks and where new banks entered the market
% change, commercial bank branches per 100,000 adults, 2008–09
% change, commercial bank branches per 100,000 adults, 2008–09
Higher
The growth in low-income countries starts from a low
base, especially for ATM and POS numbers, and the
increase in coverage is less pronounced. For example, a
27 percent increase in the number of ATMs in Malaysia
translates into an increase in coverage by more than 10
ATMs per 100,000 adults, but an equivalent percent-age
change in Kenya adds only 1.6 ATMs per 100,000
adults. At the extreme, Burundi doubled the number of
ATMs but still has only about 0.08 ATMs per 100,000
adults—a total of four ATMs in the entire country. Less
dramatic examples are Syria (with 366 ATMs) and Ma-lawi
(with 203 ATMs)—both doubled the number of
ATMs, resulting in coverage of 2.6 ATMs per 100,000
adults. Overall, patterns of retail network outreach are
broadly unchanged.18
More banks and higher expected economic
growth are associated with more retail
locations
Overall, the growth rate in the number of bank branch-es,
ATMs, and POS terminals in 2009 was negatively
correlated with income levels. Poorer economies add-ed
branches, ATMs, and POS terminals at a faster rate.
For the most part, this meant that the economies with
less developed retail networks were able to improve
Higher
Lower
outreach (figure 1.9). This relationship is particularly
strong in cases of POS terminal growth.
The expected rate of economic growth and the change
in the number of banks are strongly correlated with the
change in the number of bank branches and ATMs.
This indicates that the entry of new institutions may
significantly improve geographical outreach of the sys-tem.
Of course this also means that when banks close,
branches close, too. Economies experiencing a decrease
in economic growth as a result of the financial crisis are
also the ones showing large decreases in the number
of bank branches. The number of bank branches de-creased
by 218, or 0.54 per 100,000 adults, in Ukraine;
292, or 0.24 per 100,000 adults, in the Russian Federa-tion;
and 41, or 3.5 per 100,000 adults, in Estonia.
New technologies enable expansion in
outreach through nonbranch retail locations
Despite the fast growth, the numbers of ATM and POS
networks remain small relative to branch networks
in low- and middle-income countries (figure 1.10).
In 2009 the average number of ATMs exceeded the
number of bank branches in low-income countries for
the first time, but just barely. There are two ATMs per
Fewer Greater
Number of commercial bank branches
per 100,000 adults, 2008*
% change, number of commercial banks, 2008–09**
Lower
Low High
* Correlation controls for number of commercial banks in 2008. The relationship is statistically signicant at the 5 percent level.
** Correlation controls for number of commercial bank branches per 100,000 adults in 2008. The relationship is statistically signicant at the 5 percent level.

bank branch in middle-income countries and three
per bank branch in high-income countries. In South
Asia the ratio is the lowest—on average there is one
ATM for two bank branches. It is important to note
that a greater number of ATMs does not automatically
translate into better access. Lack of interoperability in
the system, for example, requiring each bank to build
its own ATM network, raises overall cost.19
As new technologies evolve, the trends in the use of
ATMs and POS terminals are changing. Data from the
Financial Access 2010 survey show that the number
of ATMs relative to the number of branches slightly
declined in high-income countries. At the same time,
the number of POS terminals increased, reflecting a
growing reliance on noncash payments. A greater use
of electronic transactions through Internet and cell
phones may also reduce the need for ATMs going
forward. For now, though, as cash remains the main
medium of exchange for retail transactions in most
economies, cash-in-cash-out points, whether in the
form of branches, ATMs, or POS terminals allowing
cash-back, are essential elements of financial access.
Worldwide, commercial banks have the largest
branch network, representing more than two-thirds
of all branches. Cooperatives are the second largest
with 23 percent of branches worldwide (figure 1.11).
In 60 percent of economies with available data (54
out of 90), nonbanks had less than half the number
of branches of commercial banks. According to the
Financial Access 2010 data, the number of coopera-tive
branches exceeds the number of bank branches
in only a few countries, namely Austria, Burundi,
Germany, Hungary, Korea, and Spain. Figure 1.11
likely underestimates the size of the nonbank branch
network because of data limitations for nonbanks,
though this year’s survey indicates improvements in a
number of economies on data availability.
Commercial banks mainly target urban areas. Most
bank branches are located in urban areas, representing
88 percent of all financial institutions in urban areas.
On average, only 26 percent of all bank branches are
in rural areas, compared with 45 percent for coopera-tives,
38 percent for specialized state financial insti-
FIGURE 1.10
Low- and middle-income countries have fewer ATMs and
smaller POS networks in relation to the number of branches
Number of ATMs per bank branch, 2009–10
0 1
2 3
Number of POS terminals per bank branch, 2009–10
1 20 40 60 80
Low-income
Middle-income
High-income
2009 2010
Low-income
Middle-income
High-income
High-Income OECD
South Asia
Sub-Saharan Africa
Europe Central Asia
East Asia Pacic
FIGURE 1.11
Commercial banks operate two-thirds of all bank branches
% of total branches by type of institution
Other 4%
Micronance institutions 2%
Specialized state nancial institutions 5%
Commercial
banks
66%
Cooperatives
23%

tutions, and 42 percent for microfinance institutions
(figure 1.12). Even though a smaller share of commer-cial
bank branches is located in rural areas, they still
provide the bulk of rural coverage.
Data limitations discussed earlier do not allow for a
robust analysis of changes in bank versus nonbank
branch networks. For a small subset of economies with
comparable data for banks and nonbanks (61 econo-mies),
there is no statistically significant difference in
the growth rate of bank and nonbank branches.
notes
1. Collins et al. (2009).
2. For example, Beck, Demirgüç-Kunt, and Levine (2007), using
cross-country data, find a positive relationship between finan-cial
depth and the change in the income share of the poorest.
They also report evidence for finance reducing inequality. An
ideal experiment in analyzing the impact of reducing the in-equalities
in household access to finance on poverty would re-quire
household-level panel data collected over a period, which
is yet unavailable.
3. For details of the methodology, see the Methodology section
and Beck, Demirgüç-Kunt, and Martinez Peria (2007). See
Ardic, Heimann, and Mylenko (forthcoming) for estimation
results. Also see Honohan (2008) for the difficulties involved.
Household survey data on access to financial services comes
from recent Living Standard Measurement Surveys (various
years) where available, as well as regional sources: for the
European Union, the European Commission’s Eurobarometer,
Special Barometer 260 (2007); for Africa, FinMark Trust’s
FinScope; for Latin America, Tejerina and Westley (2007) and
the MECOVI database and Barr et al. (2007); and Nenova et al.
(2009). These data are referenced and expanded upon in Claes-sens
(2006), Honohan (2008), Gasparini et al. (2005), and Beck,
Demirgüç-Kunt, and Martinez Peria (2007). Note that predic-tions
may not perform well in the high end and low end of the
distribution.
4. See Financial Access 2009 for a discussion and literature re-view
on various approaches to measurement of financial access.
5. Expected growth in real per capita GDP. Source: IMF (2010).
6. The calculations are done for 97 economies for which data
are available in both the Financial Access 2009 and 2010
databases. For example, China is not among these economies
because Chinese data are not available in the Financial Access
2009 database.
7. Access to deposit and credit services in this report is measured
by the number of deposit accounts per 1,000 adults and the
number of outstanding loans per 1,000 adults, respectively. The
report defines an expansion in financial access as more individ-uals
and firms using more financial services and products. An
increase in the number of accounts could be due to more indi-viduals/
firms opening accounts or to the same or even a smaller
number of account holders opening more accounts. The data
do not allow one to distinguish between these two dimensions
because of lack of information on the number of unique deposit
account holders. See Kendall, Mylenko, and Ponce (2010) for
further details. Reported statistics are calculated for a subset of
economies with comparable data in 2009 and 2010, excluding
economies with data inconsistencies resulting from institutional
reclassifications or improved data availability.
FIGURE 1.12
Nonbanks are more focused on rural areas…
% of branches in urban and rural areas
Specialized state nancial institutions
Micronance institutions
…but commercial banks are still the most prevalent
nancial institution in rural areas
% of rural branches by type of institution
Other 1%
Micronance institutions 3%
Specialized state nancial institutions 5%
Cooperatives 15%
Commercial banks
Cooperatives
26%
38%
42%
45%
Urban branches
Rural
branches
Commercial
banks
78%

8. Source of forecasts: IMF (2010). Expected real growth is an in-dicator
variable for positive real per capita GDP growth in 2010.
A number of other macro and policy environment variables
were tested and showed weak correlations after controlling for
income per capita. See Ardic, Heimann, and Mylenko (forth-coming)
for estimation results and further details.
9. For a comprehensive account of the literature, see Demirgüç-
Kunt, Beck, and Honohan� (2008); for recent analysis see Kend-all,
Mylenko, and Ponce (2010).
10. The strength of legal rights for borrowers may also proxy for
more general legal protections in the system, including those of
depositors’ rights.
11. See, for example, Demirgüç-Kunt and Huizinga (1999). Note
also that a higher degree of competition and lower concentra-tion
are not necessarily the same; concentration is only one
dimension of competition and hence used as a proxy for com-petition.
12. Source: Financial Access database. Figures are calculated for
those economies for which data are available for the two con-secutive
years in the database. For example, China, Japan, and
the United States were excluded in calculations because of a
lack of data on the number of outstanding loans.
13. Source of expected GDP: IMF (2010). See Ardic, Heimann, and
Mylenko (forthcoming) for estimation results and further details.
14. See Financial Access 2009 or Kendall, Mylenko, and Ponce
(2010).
15. The subset excludes economies with structural data breaks be-cause
of substantial institutional reclassifications or additional
data provided in 2010 that was not available in Financial Ac-cess
2009.
16. Estimates exclude China because of lack of data on the number
of branches, ATMs, and POS terminals. The POS estimate is
based on a smaller number of economies.
17. A smaller number of observations is available for POS termi-nals,
making regional comparison difficult.
18. This analysis does not tell whether the new branches, ATMs,
and POS terminals are in locations where they did not exist
earlier. Ideally, to measure the outreach of the financial system,
one would use data on the geographic location of these new
branches, ATMs, and POS terminals.
19. See, for example, Saloner and Shepard (1995) and Prager (1999).

Financial inclusion mandates
A broad array of actions can contribute to increasing
financial inclusion, from establishing a credit facility
for indigenous farmers in rural areas to introducing
broad consumer protection legislation. Some actions
are more narrowly focused on regulators’ traditional
roles of regulation and supervision, while others are
more promotional in nature. A number of govern-ment
agencies are usually involved in efforts to deepen
financial inclusion, each with its own mandate.
Historically, the main role of the financial regulator
has been to ensure the stability of the financial system,
focusing on regulation and supervision for the safety
and soundness of financial institutions. With many
economies embracing financial inclusion as a reform
objective and putting in place programs to expand
financial access, some regulators are playing a more
promotional role as well. However, recent financial
crises underscored the dilemma of choice between
encouraging financial sector growth, especially credit,
and maintaining the stability of the financial system.
Several important questions arise. To what extent, if
at all, should financial regulators be tasked to improve
access to financial services? Are the goals of financial
sector stability and financial inclusion compatible?
Which government agency should be responsible for
implementing financial inclusion reforms?
Answering all these questions is beyond the scope of
this report. Instead, Financial Access 2010 aims to in-form
the debate by presenting the results of the survey
of financial regulators on their role in financial inclu-sion
reform and the resources allocated to it.
The Financial Access 2010 survey asked financial
regulators which of the following topics relevant for
a financial inclusion agenda were under the pur-view
of their agency: consumer protection, financial
capability,1 regulation of microfinance, promotion of
savings, promotion of access to finance for SMEs, and
promotion of rural finance.2
FIGURE 2.1
In most economies regulators are responsible for at least
one topic related to nancial inclusion
62 economies
22
economies
86 economies
In 88 percent of economies, regulators responded that
at least one element of financial inclusion comes under
their responsibility, 71 percent stated that they have
at least two topics covered, and about half had three
topics (figure 2.1). In 18 percent of the economies, all
these elements of financial inclusion are within the fi-nancial
regulator’s mandate.
Clearly, at least some aspects of the financial inclusion
agenda are under the purview of the financial regu-lators
in most economies. But the focus is different
in high-income countries versus low- and middle-income
countries. In high-income countries, where fi-nancial
systems already cover most of the population,
regulators tend to focus on consumer protection and
financial literacy. In low- and middle-income coun-tries,
the agenda is much broader and includes pro-motion
of financial access, in addition to consumer
protection and financial literacy.
14
economies
50 economies
All
6 topics
Any
5 topics
Any
4 topics
Any
3 topics
Any
2 topics
Any
1 topic
None
106 economies
39 economies
Topics:
Consumer protection
Financial literacy
Regulation of micronance
Savings promotion
SME nance promotion
Rural nance promotion

Which areas of financial inclusion fall under
the responsibility of the financial regulator?
Consumer protection and financial literacy are the
two areas most frequently reported to be under the
financial regulator’s set of responsibilities. Sixty-eight
percent and 58 percent of regulators, respectively, re-ported
that these areas are within their mandate (fig-ure
2.2). Often consumer protection falls within the
broader mandate of ensuring soundness and stability
of the financial system through business regulation
and supervision. Consumer protection and financial
literacy are equally relevant in both developed and de-veloping
markets, as available products become more
complex and affect more people.
Financial education is closely related to consumer pro-tection
in that it also aims to protect the consumer from
abusive practices, but from a different angle. Financial
literacy refers to the need to inform the public about
the basics of financial services and ensure individuals’
ability to make informed judgments and effective deci-sions
about the use and management of their finances.
However, financial capability has different operational
implications for the financial regulator than consumer
protection. Consumer protection is often implemented
through market conduct regulation and supervision as
part of traditional regulatory and supervisory activities
FIGURE 2.3
Where are regulators responsible for consumer
protection and nancial literacy?
the financial regulator undertakes on a regular basis for
other topical areas. Promoting financial capability, on
the other hand, requires different skill sets and opera-tions.
Consequently, although many economies report
interventions in financial capability as part of the regu-lator’s
priorities, there is a great deal of diversity among
the types of activities carried out. Approximately half
of the economies in Financial Access 2010 report hav-ing
a team allocated to financial literacy, although in
many cases, such teams are not allocated full-time to
advancing this topic. In Sweden, for example, the fi-nancial
education team is part of the communications
team within the financial regulator. In fact, only a third
of the teams are stand-alone financial literacy units.
Seldom is the full design and implementation of finan-cial
literacy programs conducted entirely by the finan-cial
regulator. Peru is one of the few economies where
the regulator is fully committed to financial education
programs. Within the framework of Peru’s financial
education plan, the Division of Products and Customer
Care has implemented a wide array of activities, from
information campaigns to education of schoolteachers
and creation of virtual classrooms on its Web site. The
United Kingdom stands out as well with an entire divi-sion
allocated to financial capability.
FIGURE 2.2
Which areas of nancial inclusion are most frequently
the regulators’ responsibility?
% of economies
where Agency
is responsible
% of economies
where Agency
has a dedicated team
Financial inclusion topic
Consumer protection
Financial literacy
Savings promotion
SME nance promotion
51
48
43
18
33
29
68
58
54
39
44
40
64
56
East Asia Pacic
High-Income OECD
Europe Central Asia
Sub-Saharan Africa
South Asia
Low-income
Middle-income
High-income
68
56
77
55
50
73
67
67
45
45
100
100
81
47
85
48
63
63
% of economies
Consumer
protection
Financial
literacy

FIGURE 2.4
Developing countries are more likely to focus
on a broad range of nancial access issues
Consumer protection
Financial literacy
Savings promotion
SME nance promotion
Financial literacy programs are more commonly
cross-cutting initiatives, spanning several depart-ments
within the financial regulator, as in Brazil, or
several government agencies, including ministries of
finance, superintendents, or deposit insurance agen-cies,
as in El Salvador. The role of the regulator can
therefore be one of coordination, consultation with
private partners and financial institutions, or, less fre-quently,
implementation. Regulators in low-income
countries, where the need is probably the greatest, are
generally less likely to include financial literacy as one
of their areas of responsibility (figure 2.3).
Promotion activities and regulation of
microfinance are the priority for regulators
in developing countries
Regulators in low- and middle-income countries,
where financial access remains limited, are more likely
than high-income countries to have the responsibility
for promotional activities linked to financial inclusion,
such as creating incentives for savings or outreach to
rural areas. These activities are in addition to roles
found among high-income countries of putting in
place measures for consumer protection and financial
capability (figure 2.4).
Regulation of microfinance, promotion of savings, and
improvement of access to finance for SMEs and in ru-ral
areas are topics that are closely linked to develop-ing
countries’ policy objectives. Of these, regulation of
microfinance is the next most frequent item after con-sumer
protection on a financial regulator’s list. As the
microfinance industry has matured, professionalized,
and experienced sustained growth, it is increasingly
becoming an important part of the financial sector in
many economies. In 65 percent of developing coun-tries,
the main financial regulator reported regulation
of microfinance to be within its mandate.
Promotion of savings, SME finance, and rural finance
are more frequently reported as areas of responsibility
of the financial regulator in developing countries than
in high-income countries. About half of regulators in
developing countries say that these issues are part of
their agenda, compared with less than 20 percent in
high-income countries.
East Asia and the Pacific, South Asia, and Sub-Saharan
Africa place the most financial inclusion topics under
the responsibility of the financial regulator (figure
2.5). This is also true for savings, rural finance, and
SME finance promotion. In East and South Asia, the
role of financial regulators is more focused on promo-tion
of economic growth. In some economies such as
% of economies where nancial regulator
is responsible for:
Developing countries
High-income countries
71
64
58
56
65
26
48
15
52
18
51
12
FIGURE 2.5
South Asian economies give regulators a greater mandate
over nancial inclusion topics
Average share of topics under the mandate of nancial regulators (%)
34
39
40
41
65
71
92
High-Income OECD
Europe Central Asia
East Asia Pacic
Sub-Saharan Africa
South Asia

the Philippines, entire units are allocated to financial
inclusion, and financial inclusion is at the core of their
agenda. Other central banks take financial inclusion
one step further and formally recognize it in their
charters. Bank Negara Malaysia’s role in promoting
inclusive financial systems is explicitly articulated in
the legislation as one of the primary functions of the
central bank.
What resources are allocated to implementing
the financial inclusion agenda?
More often than not, financial regulators are mandated
by their governments to tackle one or more aspects of
financial inclusion. To implement this broad agenda,
the regulator requires staff and resources. Financial
Access 2010 surveyed regulators on whether they had
specific teams, units, or departments allocated to each
of the financial inclusion topics they had under their
purview. Figure 2.6 summarizes this information. It
appears that the commitment to reform is not always
matched by allocated staff. For example, for savings
promotion and rural finance promotion, for which 49
and 52 economies, respectively, reported these areas as
being under their responsibility, only 47 and 71 percent,
respectively, had teams assigned for those areas. Low-income
countries have more resources allocated to the
work on financial inclusion, but given the breadth of
their agenda, they also have a larger resource gap.
2000 2005 2009
Strategy document for financial inclusion
One approach to the implementation of financial ac-cess
reforms is through a comprehensive financial
inclusion strategy. Forty-five percent of economies in
Financial Access 2010 report having a strategy docu-ment
for the promotion of financial inclusion, with 91
percent of them dating from 2004 or later (figure 2.7).
Not surprisingly, regulators with a financial inclusion
strategy are more likely to have more financial inclu-sion
topics under their purview and more resources
and staff allocated to working on these matters. They
also have a relatively lower resource gap (figure 2.8).
FIGURE 2.6
Resource gap is greater in low-income
countries
Average number of topics
Topics mandated
Topics with dedicated teams
2.0
High-income
2.7
Middle-income
4.6
Low-income
1.2
2.1
3.3
FIGURE 2.7
Financial inclusion is gaining ground
in the policy arena
Number of economies with a strategy document
15
10
5
FIGURE 2.8
Strategic approach translates into a broader agenda
and more resources
Average number of topics
Topics mandated
Topics with dedicated teams
1.9
Economies
with no
strategy document
Economies with
strategy document
4.3
1.3
3.5

Financial inclusion reforms
What were the main areas of reform in financial in-clusion
in 2009? Reported reforms vary greatly, from
setting up task forces and working groups to drafting
strategies or legal text, to enacting them into legislation
and to final implementation and enforcement. Despite
this great variance in the nature of reforms, reforms
reported were weighted equally for the purposes of
analysis and comparison in Financial Access 2010.
Consumer protection is the most prevalent area of re-form
across all regions (figure 2.9). Sixty-five econo-mies
reported reforms in this area. It is also the only
reform area in which high-income countries lead,
highlighting the importance of consumer protection
beyond the specific issue of access, especially in the
past year when financial supervisors were implement-ing
reforms to deal with the effects of the global finan-cial
crisis and to ensure the soundness and stability of
the financial sector. The most common reform within
consumer protection is disclosure requirements, cited
by 10 economies. Next are reforms linked to putting in
place recourse mechanisms, complaint handling, and
dispute resolution systems, reported by nine econo-mies.
Three countries—Austria, New Zealand, and
Australia—list the extension of deposit insurance as
a reform under consumer protection; another three
countries—the Czech Republic, Finland, and Alge-ria—
focus their reform energies on fraud protection.
Many economies are in the early stages of preparing
strategy documents on consumer protection reform.
For consumer protection to be effective, clients need to
understand the basic characteristics and functions of
the products offered to them. Yet according to the Fi-nancial
Access 2010 survey, financial literacy is a much
less common area of reform. Only 40 percent of econ-omies
enacted reforms in this area last year. Reforms
range from creating or updating financial education
school programs, as in Argentina and New Zealand, to
establishing financial literacy weeks and launching fi-nancial
learning centers. Some economies are just start-ing
FIGURE 2.9
What do economies reform?
% of economies that reformed by area of reform
Consumer protection
Revising “Know Your Customer“ requirements
SME nance promotion
56
48
47
45
42
40
36
32
24
17
to tackle this issue by drafting strategy and national
programs to be implemented at a later stage. Some
regulators post a variety of learning materials on their
Web sites. In Peru and Lesotho, regulators chose to do
broad advertising campaigns informing the population
at large of the benefits and risks of financial products.
Thirty-eight economies report specific reforms related
to consumer overindebtedness in 2009. Overindebt-edness
is the result of both demand and supply forces.
Reducing the number of consumers who borrow be-yond
their means can partly be addressed by enhanced
disclosure requirements and consumer education.
On the supply side, regulators may choose to require
stricter risk management and to improve transparen-cy
in credit markets. Survey respondents indicate that
the most frequent measure taken to combat excessive
lending and overindebtedness is related to credit bu-reaus
and credit registries. More than 15 economies
report modernizing or establishing credit bureaus as
a way to monitor and prevent excessive lending. Some
economies, such as Portugal, have passed legislation
to make credit bureau consultation mandatory; other
economies, such as Rwanda, now require financial in-stitutions
to report information to the credit bureau.
Micronance
Financial literacy
Enabling branchless banking
Over-indebtedness
Government to person transfers (G2P)
Basic accounts

Panama, Syria, and Liberia report establishing quan-titative
restrictions limiting loan sizes with respect to
a borrower’s income. The practice of quantitative re-strictions
on consumer credit was reviewed in Finan-cial
Access 2009. To date, there is no robust assessment
of the effectiveness of this measure, although experi-ence
with other quantitative caps indicates that these
policies are hard to enforce and are rarely effective.
In recent years many economies have put in place
strict “know your customer” (KYC) requirements.
These rules are designed to ensure that the financial
system is not used for illicit purposes, such as money
laundering and terrorist financing. These rules often
have the unintended consequence of limiting access
to financial services for the poor, who may not have
the required documentation available to open an ac-count.
3 In the Financial Access 2010 survey, 48 per-cent
of economies report revising their KYC require-ments.
However, few economies actually did so with
a financial inclusion focus. In most cases, countries’
efforts have been geared toward updating, improving,
or amending their anti-money-laundering/combat-ing
the financing of terrorism legislations and proce-dures.
But three economies reformed in this area with
financial access concerns in mind, to achieve higher
participation rates: Afghanistan reformed with regard
to branchless banking KYC requirements; Colombia
High-Income OECD
Europe Central Asia
Sub-Saharan Africa
East Asia Pacic
relaxed its KYC requirements for opening electronic
savings accounts; and Ghana reduced its requirements
for low-value transactions (figure 2.10).
In times of economic slowdown, governments tend
to focus on policies that can help create jobs. Reforms
aimed at improving access to finance for SMEs consti-tute
the third most popular area of reform after con-sumer
protection and KYC requirements. Forty-seven
percent of economies indicate that they implemented
reforms in this area in 2009. Fifteen of those econo-mies
focused on the set-up or expansion of credit
guarantee schemes. Other countries, such as Oman
and Zimbabwe, have taken softer approaches, includ-ing
encouraging banks to increase their lending to
the SME sector. Some regulators, such as those in Sri
Lanka, require banks to direct a designated minimum
amount of their portfolios to SMEs.
Across regions, South Asia and East Asia and the Pa-cific
introduced the most reforms, followed by Sub-
Saharan Africa. Europe and Central Asia and high-in-come
countries had fewer reforms in financial access
(figure 2.11). Not surprisingly, regions that include
financial access in their strategies and mandate their
financial regulators to carry out such agendas are also
the regions that reformed the most. Pakistan and India
lead the way for South Asia with six and seven differ-ent
areas of reform, respectively. The three economies
FIGURE 2.10
Many reformed KYC regulations
but few reforms improved nancial access
Number of economies that reformed
55 KYC requirements
3 KYC requirements for improving access
FIGURE 2.11
Where are economies reforming the most?
Average number of reforms, 2008–09
3.3
2.4
4.2
4.5
4.8
4.9
South Asia 6.2

Low-income
Middle-income
High-income
.44 .19 .19
.47 .29 .43
.37 .45 .75
0.0 0.5 1.0 1.5 2.0 2.5 3.0
reporting the highest number of reforms, with 10 dif-ferent
areas of reform each, are the Philippines, Ma-laysia,
and Nigeria. Once again, all their central banks
have special access to finance units.
Overall, low-income countries, where needs are the
greatest, reformed more actively and focused more
on promoting deposit and credit services than high-income
countries (figure 2.12). High-income countries,
where access to basic financial services is nearly univer-sal,
focused more on enhancing consumer protection.
notes
1. Throughout the report, financial literacy, financial education,
and financial capability are used interchangeably to maintain
a broader focus and facilitate cross-country comparison of re-forms.
2. These broad categories of topics relevant for the financial inclu-sion
agenda were identified for the purposes of the Financial
Access 2010 survey to enable cross-country comparison. This
list does not include the full universe of issues covered by the
concept of financial inclusion. The focus on these topics by a
financial regulator does not necessarily imply an explicit finan-cial
inclusion mandate but may reflect the importance of these
issues for implementing financial stability and macroeconomic
policy mandates. For example, improvements in financial lit-eracy
and consumer protection are expected to improve loan
performance, and SME dependence on bank financing can be
an important transmission channel for monetary policy.
3. See Genesis Analytics (2008) and Isern and Porteous (2005).
FIGURE 2.12
Reform priorities dier by income group
Extent of reform in:
Credit promotion (0–1)
Savings promotion (0–1)
Consumer protection (0–1)
Broad range
of reforms
No reforms

Consumer protection
Consumer protection and financial literacy can con-tribute
to improved efficiency, transparency, competi-tion,
and access in retail financial markets by reducing
information asymmetries and power imbalances be-tween
providers and users of financial services.1 When
customers are better informed about the terms and
conditions of financial services, they can shop around,
thereby stimulating competition. Informed clients can
choose products that best fit their needs and therefore
incentivize competing financial service providers to
design better products. Knowing that their rights are
protected may bring in new customers, especially in
markets where financial systems are not trusted for
historical reasons.
The recent financial crisis highlighted the importance
of effective consumer protection and adequate levels
of financial literacy for the sustainability of the entire
financial system, particularly in an environment of
increasingly complex financial products and services.
Lack of effective disclosure and deceptive advertising
on the part of providers and failure to understand fi-nancial
products on the part of consumers contributed
to the collapse of the subprime mortgage market in the
United States. But the problem is not limited to devel-oped
markets with highly complex products. Bosnia
and Herzegovina, India, and Morocco saw indebted-ness
rise to unsustainable levels at times among mi-crofinance
borrowers in 2009.2 Policy makers around
the world have responded by introducing financial lit-eracy
programs and strengthening financial consumer
protection.
The need for consumer protection in the financial in-dustry
is not a new concept. Until recently, though, the
focus has been on credit transactions, with the basic
objective of limiting “harmful” borrowing.3 Through-out
history debt forgiveness, interest rate caps, and
outright bans on usury were used to prevent abuse
by lenders. This paternalistic approach proved to be
unsustainable and difficult to enforce, with consistent
evidence of violations of the rules over time.4 Funda-mental
changes in thinking in the early 20th century
shifted the debate toward the need to empower finan-cial
service users, to inform them, and to give them
tools to protect their rights. Present-day financial
consumer protection frameworks in most economies
reflect this approach and rely on fairness and transpar-ency
as their core principles.
To inform the ongoing debate on the state of financial
consumer protection, the Financial Access 2010 survey
asked financial regulators around the world about the
status of financial consumer protection in their juris-dictions.
Empirical analysis of the relationship between
financial consumer protection, access to financial ser-vices,
and stability is limited, in large part because of a
lack of consistent data on outcomes as well as policies.
Statistical analysis conducted for this report indicates
a strong correlation between comprehensiveness of
consumer protection regulations and the overall level
of economic development.5 Once regressions control
for income per capita, no stable statistically significant
correlations between various aspects of consumer
protection regulation and access outcomes are found.
Data limitations and endogeneity issues are inherent
in a cross-country regression framework and make it
impossible to draw conclusions at this stage. Further
research at the micro level is essential to understand-ing
the impact of various consumer protection poli-cies.
At the cross-country level, consistent data collec-tion
on outcomes and policies over time, including on
effective regulation rather than just legislation on the
books, should shed light on the long-term relationship
among consumer protection, access, and stability.
Financial Access 2010 presents a first-ever overview of
a range of consumer protection policies in more than
140 economies and builds a basis for future research.
It is a first step to understanding the existing land-scape
in consumer protection by answering some of
the following questions: Do economies have financial
consumer protection legislation in place? What are the
powers of agencies that are responsible for consumer
protection to enforce regulations? And what forms of
recourse exist?6

Legal framework
Most economies have consumer protection
legislation in place, and reforms are
widespread
More than 80 percent of economies (118) responding
to the Financial Access 2010 survey have laws and reg-ulations
addressing at least some aspects of financial
consumer protection. This topic is at the intersection
of consumer protection and financial services regu-lation.
Not surprisingly, relevant legal provisions are
most often found in broad consumer protection legis-lation
and in financial sector regulations (figure 3.1).
Sixty-seven economies are a step further and report
having issued consumer protection legislation with
specific references to financial services.
Financial consumer protection provisions are diffused
in multiple laws. Of the 118 economies that have some
type of consumer protection legislation, 48 percent
have both consumer protection legislation and regu-lations
under the financial sector legal framework. In
addition, other legal acts on payment systems, credit
bureaus, insurance, pensions, and securities may in-clude
financial consumer protection provisions. These
laws often contain conflicting provisions and create
complex oversight and regulatory structures, posing
challenges to implementation.7
Most of the financial consumer protection legisla-tion
were passed in the previous two decades. Rapid
expansion of retail financial services and increasing
complexity of products mean that financial consumer
protection legislation is constantly evolving.
As discussed in the previous section, consumer pro-tection
was a popular area of reform in 2009. A num-ber
of economies introduced or are about to introduce
consumer protection legislation for the first time.
At the time of writing, Madagascar’s parliament was
about to adopt a consumer protection law. In Georgia,
a number of projects are under consideration, includ-ing
disclosure rules, development of a deposit insur-ance
FIGURE 3.1
Most economies have laws and regulations
addressing nancial consumer protection
Number of economies
77 77
General
consumer
protection law
Consumer
protection law
referencing
nancial services
67
42
Consumer
protection
under nancial
services law
Other legal
framework for
consumer
protection
scheme, and credit bureau regulation. Moldova
has plans to amend its Law on Consumer Protection
to include specific provisions on financial services.
Other economies enhanced existing frameworks and
mechanisms. Economies such as Portugal and Bangla-desh
introduced restrictions on rates and fees. France
passed an ordinance establishing a new single regula-tor
for the financial services and insurance industries.
The United States and United Kingdom are both mov-ing
to create a consolidated financial consumer pro-tection
agency.
An effective financial consumer protection framework
covers three broad dimensions. First, it protects con-sumers
against unfair or deceptive practices by finan-cial
service providers, including in advertising and
collections. Second, it improves transparency through
a requirement to disclose full, plain, adequate, and
comparable information about prices, terms, and con-ditions
of financial products and services. Third, it es-tablishes
a recourse mechanism to address complaints
and resolve disputes quickly and inexpensively. What
consumer protection legal provisions are in place in
economies around the world?

123
Basic consumer protection requirements are on
the books in most economies, but enforcement
mechanisms are lacking
Most economies have basic legal and regulatory frame-works
for financial consumer protection. In 123 econo-mies
(87 percent), at least some fair treatment provi-sions
are covered by the existing legal and regulatory
framework, including restrictions on deceptive adver-tisement,
abusive collections, unfair or high-pressure
selling practices, and breach of client confidentiality. At
least some form of disclosure requirement regarding fi-nancial
products and services is on the books in 115
economies (81 percent). A much smaller number of
economies—only 82 economies or about 60 percent—
have a third-party dispute resolution mechanism, such
as an ombudsman or a mediation center. And most
important, only two-thirds of the 99 financial regula-tors
who said that they are responsible for at least some
aspect of financial consumer protection have a desig-nated
unit or team to work on these issues (figure 3.2).
13
48
Broad fair treatment provisions are in place,
but they may not address specific issues in the
financial service industry
Among the elements of fair treatment regulations that
economies have, the most common are provisions re-stricting
deceptive advertising (76 percent) and breach
of client confidentiality (80 percent) (figure 3.3). These
provisions are often part of broader legislation. For
example, client confidentiality is protected by bank
secrecy provisions in most civil law countries and is
implied in contractual law in common law countries.
Restrictions on deceptive advertisement are often part
of general commercial law and basic consumer protec-tion
legislation.
But only about half of the economies reporting have
provisions restricting unfair and high-pressure selling
practices and abusive collection practices. These are
important issues, especially given the potential rein-forcing
link between the two. Customers enticed into
borrowing beyond their means are more likely to be
the subjects of a collections process.
Regulations in high- and upper-middle-income coun-tries
are more likely to include restrictions on all four
unfair practices surveyed in Financial Access 2010,
FIGURE 3.2
Laws protect consumers in most economies,
but enforcement mechanisms are lacking in many
Number of economies
82
115
68
Fair treatment
option
Disclosure
at opening
Dispute
resolution
Dedicated unit
for consumer
protection
FIGURE 3.3
Few economies have legal protections against
unfair practices specic to nancial services
% of economies
76
50
80
No
protections
Abusive
collection
practices
Unfair
selling
practices
Deceptive
advertising
Legal protections
Breach of
condentiality

with an average of 3.4 out of 4 areas included. Low-income
countries on average cover only two of the un-fair
practices surveyed.
The legal framework should provide sufficient protec-tion
to ensure fair treatment of financial service cus-tomers.
Yet 13 percent of economies reported that their
legislation does not include any specific fair treatment
provisions. And in at least half of the countries, the
legislation does not go beyond restricting deceptive
advertising and protecting confidentiality. As many
economies review their consumer protection legisla-tion
and consider revisions, fair treatment provisions
relating to collections and high-pressure selling prac-tices
deserve consideration.
Banks are more likely to be subject to
disclosure requirements than other financial
institutions, and most disclosure requirements
apply at the account opening stage
Disclosure is the cornerstone of the modern approach
to consumer protection, focusing on empowering cus-tomers.
At least in theory, informed consumers should
be able to compare offers, make sound financial deci-sions,
and demand recourse when wronged. Thus far,
though, empirical evidence suggests that disclosure
requirements improve transparency in credit markets
more than the financial decisions of borrowers.8 At the
same time, there are indications that disclosure is most
effective when financial literacy is high and consumers
can understand what is being disclosed—for example,
how the interest rates are calculated.9 Though research
on the most effective forms of disclosure is ongoing,
there is no question as to whether consumers have the
right to know the terms and conditions of the prod-ucts
and services offered.
The Financial Access 2010 survey covers two broad
types of disclosure. The first, known as disclosure
upon opening, refers to the requirement to notify con-sumers
in writing of pricing, terms, and conditions
of a financial product prior to signing an agreement.
The second, periodic disclosure, refers to the require-ment
FIGURE 3.4
Most disclosure requirements focus on opening an account,
and seldom apply to nonbanks
Banks
Regulated
nancial
institutions
Unregulated
nancial
institutions
% of economies
4
47
73
Requirement:
81
Disclosure upon opening
Periodic statement
34
25
to disclose information periodically through an
account statement. This second type of disclosure is
especially important for products for which the cost of
the product depends on the use—for example, credit
cards and overdrafts. The survey also asked whether
the rules apply to banks, other regulated financial in-stitutions,
and unregulated financial institutions.
Two striking results emerge from the survey (figure
3.4). First, most of the disclosure requirements ap-ply
only to account opening. Eighty-one percent of
economies require commercial banks to disclose in-formation
upon account opening, while only about
half of them require periodic disclosure. The trend is
even more pronounced for other types of financial in-stitutions.
In more than half of the countries, clients
are not entitled to be updated about the state of their
financial accounts. The decision on what and how to
disclose to a customer once a product is sold is left up
to the financial service provider.
Second, commercial banks are more likely to be sub-ject
to disclosure requirements than are other financial
institutions, and unregulated financial service provid-ers
are rarely subject to disclosure requirements. The
survey, however, asked regulators to identify whether
disclosure requirements exist at all, not whether it is
the central banks or financial regulators’ responsibil-ity
to implement them. It is possible that respondents
were not aware of regulations affecting unregulated

institutions. A comprehensive assessment of overall
financial consumer protection is needed to evalu-ate
the degree to which disclosure requirements ap-ply
to unregulated financial institutions. This finding
does confirm the fact that even in economies where
financial regulators are involved in financial consumer
protection matters, they rarely are tasked to focus on
unregulated financial institutions.
Guidelines for disclosure requirements at
account opening are focused on rates and fees
What information must be disclosed upon account
opening? According to the Financial Access 2010 sur-vey,
disclosure requirements in most economies are
focused on quantitative information, such as rates
and fees, and not on explaining to customers how
these rates and fees are calculated (figure 3.5). On the
deposit side, 65 percent of economies require disclo-sure
of annual percentage yield and interest on de-posit
products, while 42 percent require an explana-tion
of how it is compounded. On the credit side, 66
percent of economies require disclosure of rates and
fees, and 53 percent require an explanation of how the
rate is computed.
Disclosing rates and fees alone may not be sufficient
to enable customers to make informed decisions.10 To
facilitate comparison of financial product terms across
institutions, some economies have introduced a stan-dardized
disclosure format for general financial prod-ucts,
such as a one-page “Key Facts” document summa-rizing
terms and conditions in a clear and transparent
manner. Forty-one percent of economies reporting to
Financial Access 2010 have such a requirement.
And most important, only 35 percent of economies
have a requirement to provide information on dispute
resolution, raising a question as to the effectiveness of
such disclosure.
Periodic disclosure guidelines rarely require
information on disputing content of the
statements
What information is required to be disclosed in pe-riodic
statements? According to the Financial Access
2010 survey, fewer economies have detailed guidelines
on the content of periodic statements than disclosure
requirements upon opening. The four most com-mon
requirements are focused on purely numerical
information: annual percentage rate (applied during
the period of the statement); interest charged for the
period; fees charged for the period; and outstanding
balance of credit. One-third of economies require fi-nancial
institutions to provide information on how to
dispute the accuracy of transactions (figure 3.6).
The frequency of periodic disclosure differs across
economies. Almost half of the economies reporting
require some sort of periodic disclosure. Of those
economies, 64 percent require that statements be is-sued
monthly. In 20 percent of economies there is a
requirement to issue a statement at least once a year,
though the financial service provider may choose to
disclose information more frequently.
FIGURE 3.5
Most disclosure requirements for opening an account
focus mainly on rates and fees
% of economies with disclosure requirements for opening an account
General
Recourse mechanism
Standardized format
Local language
Plain language
Deposit
Early withdrawal
Fees penalties
Minimum balance
Compounding method
Annual percentage yield interest rate
Credit
Required insurance
Computation method (average balance, interest)
Fees
APR
30 40 50 60

FIGURE 3.6
Requirements for periodic statements focus mainly
on rates and fees
General
Info on dispute
Deposit
Account balance
Fees
Annual percentage yield
Interest earned
Credit
Outstanding balance
Required method
Date due
Computation method
Minimum amount due
Fees
Fees for period
APR
Interest charged
APR for period
Different types of products may need different fre-quencies
of disclosure. For example, in Malaysia, loan
statements have to be provided to customers at least
once a year, whereas for deposit accounts, a statement
has to be provided at least once a quarter. In Greece,
monthly statements must be provided to credit card
holders only. In Norway, the law specifies that state-ments
must be provided annually, but the institution
is required to provide the customer with a statement
more frequently if the account has been in use (cred-ited
or debited). As a result, the periodic statement is
usually provided monthly.
With modern technology, it is possible to disclose
statements via the Internet, which helps to reduce the
cost of compliance with disclosure requirements. It
is important, though, to ensure that customers have
a choice regarding how they receive their statements,
whether on paper or electronically.
In addition to requiring disclosure by financial insti-tutions,
regulators themselves increasingly take steps
to improve transparency in the markets. A number
of economies regularly post fees and rates for deposit
and credit products on the regulators’ Web sites. For
example, Bank of Uganda publishes bank charges.
There is no one-size-fits-all solution to the design of a
legal framework for financial consumer protection. It
should reflect the structure of the financial system and
the nature of each economy’s overall legal framework.
But, in all cases, the process of designing an effective
financial consumer protection framework requires
a comprehensive approach and consultation among
various stakeholders to ensure consistency within laws
and regulations. Close coordination is also essential to
develop effective oversight and regulatory structures.
Institutional structure
Multiple regulators are involved in consumer
protection, and financial supervisors are
engaged in a majority of economies
Reflecting the variation in legal frameworks on con-sumer
protection, supervisory and enforcement struc-tures
differ among economies. In most cases multiple
government agencies are involved in the regulation, su-pervision,
and enforcement of laws related to financial
consumer protection. On the one hand, consumer pro-tection
agencies, competition authorities, ministries of
justice, or ministries of economy may be responsible for
implementing broad consumer protection legislation.
On the other hand, central banks, bank supervisory
authorities, securities commissions, and other financial
service regulators are involved in implementing finan-cial
consumer protection regulations that apply to the
institutions they oversee. Central banks or bank super-visors
are responsible for at least some aspect of finan-cial
consumer protection in 99 economies (70 percent)
reporting to the Financial Access 2010 survey.
Consumer protection regulators are more likely to take
a functional approach with a focus on products and
services, regardless of which institutions provide these
services. A functional approach applies consumer pro-tection
to all financial service providers irrespective
% of economies with disclosure requirements for periodic statement
30 40 50 60
Transactions

FIGURE 3.7
Agencies responsible for consumer protection often lack
a dedicated unit or team
of their institutional type (i.e., bank or nonbank), en-suring
a level playing field. But consumer protection
agencies often face a challenge taking on financial con-sumer
protection responsibility because they lack both
knowledge of the financial sector and capacity.
Financial regulators, on the other hand, have a solid un-derstanding
of the financial sector but are empowered
to implement consumer protection provisions only as
they relate to the financial institutions they regulate,
not to a broad range of financial service providers. This
approach fragments responsibilities among many regu-lators
and, more important, excludes unregulated insti-tutions,
creating distortions in the market.11 To address
this challenge, some economies have created a single
agency responsible for consumer protection issues for
retail financial services, such as the Financial Consum-er
Agency of Canada or the National Credit Regulator
in South Africa, which is solely responsible for retail
credit. The United States and United Kingdom are also
moving in this direction following the recent crisis.
Whichever institutional structure is chosen, effective
implementation of the law requires that the respon-sibilities
of the respective agencies are clearly defined
and a single entity is assigned to receive and direct
customer complaints and inquiries.12
Effective implementation also requires assigned staff
and resources in the agency responsible. Yet Financial
Access 2010 finds that this is not always the case. Out
of 99 economies where financial regulators are respon-sible
for at least some aspect of consumer protection,
68 economies (69 percent) had assigned this work to a
specific department or unit (figure 3.7). Most of these
consumer protection departments and units are rela-tively
new. Of the 60 economies that provided their
units’ date of establishment, 65 percent were created
after 1999, and 45 percent after 2005.
A number of countries—31—reported that consumer
protection work is assigned to a financial institution
supervision department. In Austria, Botswana, Kenya,
the former Yugoslav Republic of Macedonia, and Sri
Lanka, consumer protection is part of routine super-visory
work, with no organizational separation of con-sumer
protection tasks from general supervision. In
the Philippines, Spain, Brazil, Israel, and Zimbabwe,
consumer protection is handled by an allocated team
or unit within the banking supervision department.
An alternative approach taken by 13 economies is to
create a special department. In the Czech Republic,
the Consumer Protection Department reports directly
to the board of the Czech National Bank; in Ecuador
the department reports directly to the bank superin-tendent;
and in the United States the Federal Reserve
Board has a Division of Consumer and Community
Affairs, with a staff of 120.
Agencies’ powers to enforce consumer protection
regulations and monitor compliance are limited
What actions can regulators take if financial institu-tions
do not comply with regulations? And how do
regulators monitor compliance? Financial Access 2010
finds that regulatory powers are often limited. Regula-tors
in a little more than half of the economies have
powers to issue warnings to financial institutions or
impose fines and penalties for violation of consumer
protection regulations, and only about a third are em-powered
to issue a public notice of violation, require
providers to refund excess charges, or withdraw a li-
% of economies
Agency has responsibility
for consumer protection
Agency has a dedicated unit
for consumer protection
56
33
67
67
69
79
85
South Asia
Europe Central Asia
East Asia Pacic
High-Income OECD
Sub-Saharan Africa
48
33
38
50
31
55
59

FIGURE 3.8
What enforcement actions can regulators take?
30 40 50 60
Require refund of excess charges
Issue public notice of violations
Withdraw licenses to operate
Withdraw misleading ads
Impose nes and penalties
cense to operate (figure 3.8). A number of respondents
commented that even though their agency had the
responsibility to monitor compliance with consumer
protection regulations, they were authorized to take
action only if the violation of consumer protection
provisions posed a risk to financial stability, signifi-cantly
limiting the regulator’s ability to step in.
Credible deterrence is a critical element of successful
enforcement. A recent evaluation of consumer credit
interventions in the United Kingdom suggests that
greater publicity for the actions taken and the regula-tor
publicly identifying the offending institutions can
increase the deterrent effect.13 So how often do regula-tors
exercise their powers? Surprisingly few economies
were able to provide statistics on the number of times
actions were taken against institutions. Twenty-one
economies reported the number of times they issued
warnings, out of 85 economies with the authority to do
so. Of these 21, only half issued more than five warn-ings.
Statistics on fines were provided by 22 economies
out of 79 authorized to impose fines and penalties. Of
these, three economies did not apply any actions in
2009 and a little more than half of the economies ap-plied
fines to seven or fewer institutions. Among 21
economies, mostly high-income OECD, that had an
authority and provided statistics on more than one ac-tion,
the most common actions were requirements to
withdraw advertisements. Only the United Kingdom,
Italy, Japan, Lithuania, Nicaragua, and Sierra Leone
report more than one case of issuing a public notice of
violation—potentially a very effective tool.
FIGURE 3.9
What monitoring actions are available to regulators?
Mystery shopping
Consumer interviews
Receive complaints stats
Operate complaints hotline
Onsite inspection of nancial institutions
10 20 30 40 50 60
The low number of actions taken indicates that there
are either no violations or no effective monitoring and
enforcement mechanisms. The statistics on the num-ber
of complaints in economies with effective moni-toring
systems, such as the United Kingdom, where
the financial regulator records 3 million complaints
per year,14 suggest that violations are likely. But with-out
consistent data on the number of complaints re-ceived
and the resolution steps taken, it is impossible
to assess either the scale of the problem or the effec-tiveness
of the reaction. So how do regulators monitor
compliance with consumer protection provisions?
To identify risks to the economy resulting from inad-equate
consumer protection, regulators need to com-plement
onsite inspections with routine monitoring of
complaint statistics and advertisements, mystery shop-ping,
and focus groups with consumers and industry.
However, Financial Access 2010 survey results indicate
that most financial regulators tasked with monitoring
compliance with consumer protection regulations rely
mainly on onsite inspections as part of a routine fi-nancial
institution examination and rarely use other
methods (figure 3.9).
Monitoring customer complaints and tracking en-forcement
actions is an important step in improving
the effectiveness of regulations. Analyzing the trends
in enforcement actions can help regulators adjust ex-isting
frameworks and improve oversight, as well as
identify market-wide risks. Financial Access 2010 sug-gests
that thus far only a few economies have put the
necessary monitoring mechanisms in place.
% of economies
Issue warnings to nancial institution
% of economies
Monitor ads/Web sites

Dispute resolution mechanisms
The power imbalance between providers and users of
financial services is acute in retail financial transac-tions,
especially when they involve low-income indi-viduals.
A consumer of financial services is unlikely to
have the resources to go through the court process to
resolve a dispute with a financial institution. Effective
complaint-handling mechanisms by financial service
providers and extrajudicial third-party dispute reso-lution
mechanisms are essential parts of a consumer
protection system. Yet these mechanisms are often not
in place, limiting the effectiveness of the legislation.
Financial institutions are the first line of defense when
it comes to resolving disputes. Not only is complaints
resolution required by fairness provisions in most
countries’ legislation, but research shows that address-ing
customer complaints is beneficial to business sus-tainability.
15 The Financial Access 2010 survey asked
if an economy’s laws or regulations set standards for
complaints resolution by financial institutions. Only
about a third of the economies require financial institu-tions
to implement procedures for resolving customer
complaints, set limits for timeliness of response, and
ensure accessibility. Even though many economies re-port
that institutions have put in place voluntary codes
of conduct, it is not clear how effective these voluntary
arrangements are due to a lack of monitoring.
If a customer’s complaint is not resolved under the fi-nancial
institution’s internal procedures, do economies
have an effective third-party dispute resolution mecha-nism
such as an ombudsman16 or a mediation center?
Financial Access 2010 survey results show that 58 per-cent
of economies have some type of ombudsman or
mediation service. Thirty percent have a specialized
financial ombudsman, whereas in 21 percent of coun-tries,
a general ombudsman handles financial cases
along with other consumer protection issues. Media-tion
services are more common in Asia, where about
half of the economies report having established one
FIGURE 3.10
How are disputes resolved?
% of economies
24
21 19
57
29
30
25
11
5
Low-income
Middle-income
High-income
Mediation service
General ombudsman
Financial ombudsman
compared with a quarter of the economies or fewer in
other regions.
These institutions are not mutually exclusive, and
some economies have more than one third-party
mechanism to address customer complaints. El Salva-dor,
Pakistan, Poland, South Africa, Taiwan (China)
and Korea all have a financial ombudsman, a general
ombudsman, and a mediation service for resolving
financial disputes. The Czech Republic, Greece, Italy,
Mexico, and Peru have a financial ombudsman and a
mediation service.
Financial ombudsmen are more common in high-income
countries. Fifty-seven percent of high-income
countries reporting have a financial ombudsman in
place, compared with 5 percent of low-income coun-tries
(figure 3.10).
Institutional arrangements and funding for third-party
dispute resolution mechanisms vary across countries.
In a majority of economies that provided data on fund-ing
(41 of 63 economies), the ombudsman or equiva-lent
institution is fully funded by the government,
mostly through the annual budget of the relevant gov-ernment
agency, and is sometimes part of the financial
regulator’s budget, as is the case in Israel, Nepal, and
Uruguay. In eight more economies, the ombudsman
is cofunded by the government and the private sec-

FIGURE 3.11
Excessive rates/fees is the most common
cause for complaint
0 10 20 30
No loan approval
ATM transactions
Credit card issues
Mortgage/housing loan
Insurance
FIGURE 3.12
The number of complaints received by ombudsmen
varies greatly across countries
0 1 2
Consumer complaints per 1,000 adults
Honduras
Gambia
Botswana
Belgium
Norway
Kuwait
Malaysia
Armenia
Dominican Republic
Sweden
Chile
Azerbaijan
Puerto Rico
Spain
Slovak Republic
Venezuela
Denmark
Netherlands
Switzerland
New Zealand
France
Singapore
Israel
Australia
Colombia
Namibia
Mexico
Korea, Rep.
United Kingdom
Portugal
Number of economies
by most common complaint
Excessive rates/fees
tor. And in 30 out of 63 economies, dispute resolution
mechanisms are funded by members (mostly service
providers) or industry associations. Privately funded
dispute resolution schemes can be voluntary, as is the
case in Chile, or mandatory, as in Armenia.
What are the most frequent causes for complaints
across countries? Excessive interest rates and fees is by
far the most common cause for complaint. Out of 70
economies providing data, 31 ranked excessive inter-est
or fees as the most frequent cause for complaint,
and 48 named it among the top three (figure 3.11).
Product-specific complaints related to credit cards,
mortgages, and ATMs all rank at about the same level.
Only two economies listed not getting approved for a
loan as the most frequent cause for complaint.
A number of economies reported additional causes for
complaints. In the Czech Republic, the most frequent
complaint concerns domestic payment transactions. In
Finland it is the functioning of the deposit guarantee
scheme; in Mozambique it is insurance complaints and
the register of declined checks. A number of economies
cited complaints related to bank staff as the most com-mon.
In Namibia, Norway, and Hungary, complaints
relate to poor financial advice provided to the custom-er;
in Syria and Uganda, they relate to mistreatment of
customers by bank staff.
How often are complaints referred to the
third-party dispute resolution entities, and
how often are they upheld?
Fifty-three of the 82 economies where such a mecha-nism
exists provided statistics on the number of com-plaints
received by the third-party dispute resolution
mechanism. These ombudsmen or equivalent institu-tions
vary substantially in the scope of operations and
the types of disputes they are set up to address. The Fi-nancial
Ombudsman Service in the United Kingdom
and Condusef in Mexico, both of which handle a wide
array of consumer complaints on a range of financial
services, received about 130,000 complaints each in
the past year—2.52 and 1.76 per 1,000 adults, respec-

tively (figure 3.12). On the other hand, the Federal
Reserve Consumer Help Center in the United States—
one of a number of dispute resolution mechanisms—
received about 5,000 complaints. In economies where
ombudsmen or equivalent institutions were created
recently, customers may not know how to file com-plaints
or may be skeptical about the effectiveness of
the scheme. Poland and Bulgaria reported nine and
five complaints received, respectively—less than one
per million adults. In a functioning system, the num-ber
of complaints is likely to increase in the early years
of operation as public awareness and confidence in
effective resolution improve. In the United Kingdom,
for example, the number of complaints referred to the
Financial Ombudsman Service increased fivefold be-tween
2000 and 2009.
Respondents were also asked to provide the total num-ber
of cases processed and closed, and out of these cas-es,
the number of cases that were resolved in favor of
the customer. Thirty economies provided data on both
figures. In 67 percent of these economies, less than half
of all complaints were resolved in favor of the customer.
Variation between the economies is substantial, though.
In Singapore only 2 percent of customer complaints
were resolved in the customer’s favor. But in Venezuela,
resolution was in the favor of the customer 97 percent
of the time. International comparisons of this sort are
not very informative, as they mostly reflect structural
differences in the existing systems. But at the country
level, consistent tracking of the number of complaints
and the number of complaints upheld by the ombuds-man
can be an important policy tool. In the United
Kingdom, Malaysia, Sweden, Spain, Singapore, Paki-stan,
and Canada, information on complaints resolu-tion
by product is publicly available and is shared with
regulators to inform policy. For example, spikes in the
number of complaints or a share of upheld cases for a
certain product may indicate a systemic problem and
may warrant regulatory action. In a number of coun-tries,
the regulator’s role is broader, as in Pakistan and
Ecuador, where regulators can receive appeals if the
customer is not satisfied with the ombudsman.
Effective third-party dispute resolution mechanisms
are an essential part of consumer protection frame-works,
especially in economies with weak judiciary
systems. Yet 34 economies reporting do not have an
ombudsman or an equivalent scheme, relying solely
on the court system to resolve disputes. And few econ-omies
where these mechanisms exist are able to pro-vide
statistics on the number of complaints received
and resolved. In a number of economies the dispute
resolution schemes are new and may not be known to
consumers and thus are rarely used. Across the board,
further work to clarify legal and regulatory frame-works
for the role of third-party mechanisms and to
improve monitoring and consumer awareness can go
a long way in enhancing overall effectiveness of the
consumer protection system.
Regional trends
in consumer protection
How do consumer protection frameworks vary from
region to region? As mentioned earlier, almost all
economies have consumer protection legislation on
the books, whether an explicit financial consumer
protection law or a general consumer protection law.
However, the trends on enforcement and implementa-tion
mechanisms tell a different story.
Figure 3.13 displays the regional means for five areas
measured by the Financial Access 2010 survey. The
first area measures the average number of the four leg-islative
requirements on fair treatment practices im-plemented
by each region. For example, South Asian
economies on average require 46 percent (or 1.8 out
of 4) of the fair treatment practices measured by the
survey. The second area measures the average num-ber
of the 13 disclosure requirements upon opening
implemented by each region. For example, Sub-Saha-ran
African economies on average require 37 percent
(or 4.8 out of 13) of the disclosure requirements upon
opening measured by the survey. The third area mea-sures
the average number of the 13 periodic disclosure
requirements implemented by each region. The fourth

55
42
37
37
33
83
29
42
31
54
30
56 46
38
42
32
60
65
area measures the percentage of economies in each re-gion
that have at least one recourse mechanism. And
the fifth area measures the percentage of economies
in each region that have an allocated unit for financial
consumer protection.
Overall, high-income countries have on average the
most comprehensive consumer protection framework.
Latin American economies follow close behind, par-ticularly
on fair treatment requirements and recourse
mechanisms. This can be partly attributed to the fact
that consumer protection frameworks in high-income
countries have existed longer, and thus are better es-tablished
and have had a chance to improve over time.
Economies in Sub-Saharan Africa and South Asia have
the least comprehensive legal frameworks in terms of
the coverage of fair treatment and disclosure require-ments.
And across all groups, less than 60 percent of
economies have an allocated team working on con-sumer
protection issues.
59
81
44
63
notes
50
50
46
59
50
With designated
unit within
regulatory body
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
46
1. For an overview, see Rutledge (2010) and Brix and McKee
(2010).
2. See Gokhale (2009), Reuters (2009), and Reille (2009).
3. Peterson (2003).
4. Ibid.
5. See Ardic, Ibrahim, and Mylenko (forthcoming) on consumer
protection for further details of statistical analysis.
6. The focus of the Financial Access 2010 survey was consumer
protection for loan and deposit services, rather than for pen-sions,
investments, and insurance.
7. Rutledge (2010).
8. Godfrey et al. (2008).
9. Lusardi and Tufano (2009).
10. U.S. GAO (2005).
11. Rutledge (2010); Brix and McKee (2010).
12. Ibid.
13. Office of Fair Trading (2009).
14. Financial Services Authority (2010).
15. Ibid.
16. An ombudsman is an entity or a person designated to investi-gate
complaints and mediate fair settlements. In some cases,
the ombudsman is completely independent of any government
agency (including being housed by an industry association),
and in other cases, it can be housed under the relevant regula-tory
authority.
Middle East
North Africa
Latin America
Caribbean
47
Sub-Saharan
Africa
South
Asia
56
East Asia
Pacic
Average extent
of fair treatment
86
High-Income
OECD
FIGURE 3.13
Regional dierences in consumer protection legislation and implementation
% of economies
Europe
Central Asia
48
67
44
76

SME finance:
Supply-side data availability
Lack of finance is one of the key obstacles
to SME growth
SMEs are critical for sustainable economic growth. In
high-income countries, SMEs constitute 67 percent
on average of the formal employment in the manufac-turing
sector. In developing countries, this number is
lower at about 45 percent. Similarly, SMEs contribute
a sizeable share to formal GDP: 49 percent on average
in high-income countries and 29 percent on average
in low-income countries.1
A number of factors, ranging from the overall busi-ness
environment to the availability of an educated and
trained labor force, affect the growth of SMEs. But lack
of access to finance consistently ranks as one of the
most important obstacles to doing business, according
to World Bank surveys of firms in more than 100 econ-omies.
2 Empirical research supports entrepreneurs’
views and indicates that lack of finance is negatively
correlated with SME firm growth.3 Access to finance
for SMEs remains low. In the survey of firms, only
about 32 percent of SMEs had a loan with a financial
institution, compared with 56 percent of large firms.4
The appeal for the need to support SMEs is hardly
new. Most economies have comprehensive SME fi-nance
programs, many of which trace their history to
the 1950s and 1960s. Governments around the world
have used interest rate subsidies, directed lending,
guarantee funds, and a variety of other approaches to
get SMEs financed. However, the gap between SMEs
and larger businesses remains. With the recent fi-nancial
crisis, many economies are looking to SMEs
to provide much needed jobs and to help pull their
economies out of recession, putting SMEs back into
the spotlight of development and political agendas.
In 2009, G-20 countries committed to identifying les-sons
learned on innovative approaches to providing
financial services to SMEs and to promoting success-ful
regulatory and policy approaches.5 In the Finan-cial
Access 2010 survey, 44 percent of economies cite
SME support as a priority for financial regulators, and
47 percent report implementing reforms that support
SME finance. Most of these programs and reforms set
targets for the number of SMEs reached, volume of
SME financing facilitated, and employment created.
Some progress has been made in collecting compara-ble
demand-side information across countries through
firm surveys by the World Bank, European Bank for
Reconstruction and Development (EBRD), and other
development organizations. Yet, to date there are no
reliable data across countries on the volume of SME
financing, which makes it difficult to set global targets
and track progress. In 2004, the OECD identified the
need to foster greater international comparability of
SME statistics,6 and a number of initiatives are under
way to reach this goal. One of them is to strengthen
the culture of evaluation of SMEs and entrepreneur-ship
policies across nations.7 Moreover, the SME Per-formance
Review, launched by the European Com-mission
in 2008, represents one of its main tools to
monitor the implementation of the Small Business
Act.8 It represents a comprehensive source of informa-tion
on the performance of SMEs in Europe.
Financial Access 2010 contributes to the effort to im-prove
measurement of SME financing and reviews SME
finance data available to financial regulators as well
as data collection methodologies. Supply-side data—
information collected from financial service provid-ers—
are likely the most effective tool to collect in-formation
on SME finance volume. Firms are often
reluctant to share information on the dollar amounts
of their operations, such as sales or loan sizes, during
interviews. As a result, information on the volume of
SME financing is difficult to obtain from firm surveys
and requires a survey of credit providers. The most
economical way to collect this information worldwide
is to survey government authorities instead of survey-ing
individual financial institutions in each economy.
The Financial Access 2010 survey, as a survey of finan-cial
regulators, evaluates whether they collect infor-mation
on SMEs.

Irregular
reporting
FIGURE 4.1
How often are SMEs required to report about their lending?
% of economies by frequency of required reporting
High-Income OECD
Europe Central Asia
Sub-Saharan Africa
East Asia Pacic
Irregular 0 25 50 75 100
reporting 11%
The objectives of this year’s survey were to identify the
feasibility of consistent cross-country data on SMEs
going forward, summarize methodological challenges,
and provide a rough estimate of SME financing volume
by regulated financial institutions. The analysis of top-ics
such as the effectiveness of SME support programs,
the impact of the SME sector on economic growth, and
the relationship between access to finance and SME
development is beyond the scope of this year’s report.
Financial regulators in more than half of the
economies worldwide monitor levels of SME
financing, but use a variety of definitions
Data on SME volumes are collected by financial regu-lators
in 74 out of 142 economies surveyed in Finan-cial
Access 2010. In 21 more economies, SME finance
statistics are collected by other government agencies.
The Ministry of Economy collects SME data in Chile,
Lithuania, Taiwan (China), Nicaragua, and Venezuela.
The Ministry of Trade monitors SME lending in Alba-nia,
Botswana, Colombia, and Zambia; the Ministry
of Cooperatives does so in Indonesia. In a number of
economies, including Japan, Denmark, and Greece,
the National Statistics Office collects this type of data.
Financial regulators in 53 percent of the economies
that responded to the survey monitor the level of lend-ing
to SMEs. Most important, in 42 percent of these
economies these data are collected through regular
reporting (figure 4.1). Financial regulators in middle-and
low-income countries are more likely to require
regular reporting of SME statistics. Out of 59 econo-mies
that collect SME lending data on a regular ba-sis,
86 percent are low- and middle-income countries.
Most economies in East Asia and the Pacific, as well
as in South Asia, monitor SME lending at least peri-odically
(figure 4.1). Often, these data are collected to
monitor compliance with lending targets set for prior-ity
sectors, including SME, as is the case in Afghani-stan,
India, the Philippines, and Pakistan.
In a number of economies where data are not collected
through regular reporting, they are collected through
surveys of financial institutions or by estimating lend-ing
volume in credit registries. Credit registries con-tain
loan-level data and allow estimation of a variety
of SME statistics using loan size as a proxy for an SME
definition. In 13 of the reporting economies, including
Argentina, Tunisia, and Brazil, regulators use public
credit registries to estimate the volume of SME lend-
Regular
reporting
42%
Regular
reporting
No reporting
32%
No
reporting
No response
to survey
15%
No response
to survey
South Asia

ing. In 23 economies, regulators conduct periodic sur-veys
of financial institutions to monitor SME lending.
The frequency of surveys varies. For example, Estonia,
Singapore, and Armenia conduct such surveys annu-ally,
Algeria and Tunisia do so monthly, and Uganda
does it on an ad-hoc basis. Financial institution sur-veys
can be an important tool for a regulator to col-lect
information not only on SME lending volumes
but also on other aspects of SME finance such as fees
and number of applications received and rejected, all
of which are essential for the implementation of SME
finance reforms and programs. In 10 economies, 8 of
which are in the Western African Monetary Union,
regulators combine information from the credit regis-tries
and periodic surveys from financial institutions.
There is a clear regional pattern in reporting SME
data. More than half of the economies in Asia and Af-rica
report that they regularly collect information on
SME finance. These are also regions where regulators
tend to identify access to finance as a priority. Finan-cial
regulators in high-income countries and in Latin
America and the Caribbean are the least likely to col-lect
data on SME finance, because some other agency
is usually assigned this task.
The responsibility to promote SME finance often lies
with more than one government agency, each of which
also has the responsibility to monitor the performance
of the sector, including availability of finance. Agen-cies
collecting regular statistics from financial institu-tions,
such as central banks and bank regulators, are
well positioned to collect SME finance statistics, and
already do so in a majority of economies. Experience
in economies such as Malaysia, Russia, Greece, and
the Czech Republic that have introduced monthly re-porting
for SMEs shows that SME data collection on a
monthly basis is possible when there is a clear defini-tion
of SMEs, in addition to a well-established report-ing
process that is easy to follow.
Lack of a clear definition is the main
challenge in measuring SME finance
What is an SME? Definitions vary greatly across coun-tries,
and financial regulators in 68 economies report-ed
that their SME definition is based on number of
employees, sales volume, or loan size. Number of em-ployees
and sales volume seem to be the most widely
used criteria, present in 50 and 41 economies, respec-tively.
Sixteen economies use the value of loans. Often,
the definition relies on multiple criteria and depends
on the industry. In Pakistan, for example, SME refers
to an entity that employs no more than 250 persons in
manufacturing or service sectors or 50 persons in the
trade sector, as well as sales criteria of up to $590,000
for trade and industry firms, $1.2 million for manu-facturing
firms, and no more than $3.5 million for any
industry of operation. In addition, a number of econo-mies
use alternative criteria such as total assets, fixed
assets, and turnover, and 17 economies report that no
official definition exists at all.
The following examples underscore the diversity of
definitions used. In Zambia it is a firm with fewer than
50 employees and sales of no more than $50,000. In
Russia SMEs include individual entrepreneurs and
firms with fewer than 250 employees and sales of up
to $30 million. In Canada it is a firm with up to 500
employees and sales of up to $45 million at current
exchange rates. And in Korea, SMEs can have up to
1,000 employees and sales of up to $130 million.
The most common cutoff points for the maximum
number of employees cluster around 50, 100, and 250
employees (figure 4.2). A large portion of economies
(20 out of 49 that use number of employees as a crite-rion
to define SMEs) set 250 employees as the maxi-mum
cutoff.9 Maximum values of sales range from
$50,000 in Zambia to over $70 million in Korea, Ger-many,
France, Greece, and Hungary, with no clear pat-terns
or clustering. The maximum sales cutoff value is
closely correlated with income per capita but does not
translate into a common ratio of SME maximum sales

Azerbaijan
Sudan
Liberia
New Zealand
Italy
Zimbabwe
Ghana
Ukraine
El Salvador
Estonia
Iran, Islamic Rep.
Zambia
Cape Verde
Oman
Lao PDR
Uzbekistan
Hong Kong SAR, China
Armenia
Afghanistan
Botswana
Uruguay
Bangladesh
Malaysia
Mongolia
Thailand
Colombia
Taiwan, China
Portugal
Lithuania
Albania
Ireland
Moldova
Greece
Serbia, Rep. of
Mexico
Latvia
Spain
Kazakhstan
Poland
Hungary
Pakistan
United Kingdom
Russian Federation
Nigeria
Germany
Croatia
Slovenia
Tunisia
Canada
Korea, Rep.
Number of employees
Annual sales
Ratio of sales to GDP per capita
Azerbaijan
Zambia
Costa Rica
Botswana
Taiwan, China
Lao PDR
Estonia
El Salvador
Oman
Panama
Spain
Uruguay
Cape Verde
Mongolia
Albania
United Kingdom
Lebanon
Malaysia
Canada
Netherlands
France
Germany
Slovenia
Greece
Mexico
Serbia
Indonesia
Morocco
Afghanistan
Ukraine
Ghana
Russian Federation
Argentina
Moldova
Lithuania
Hungary
Korea, Rep.
Madagascar
South Africa
100 250 500
0 2,000
0
4,000 6,000
1,000
FIGURE 4.2
Denitions of SMEs cover a large range in sales volume and number of employees

to average income per capita. Maximum sales values
represent 23 times income per capita in Azerbaijan at
the lower end and more than 8,000 times income per
capita in South Africa at the higher end (figure 4.2).
Number of employees and sales volume are prob-ably
the most accurate parameters to define SME, but
this information is not always available from lend-ers.
Banks may collect this information at the time of
evaluating loan applications but often do not keep it
in their systems and as a result are not able to report
lending volumes based on these criteria. Thus, some
economies choose to rely on loan size as a proxy when
collecting information on SME finance from financial
institutions. Extracting information on loans to firms
below a certain size and loans to individual entrepre-neurs
can be a reasonable approximation for SME
lending volume. Fifteen economies in the Financial
Access 2010 survey reported using loan size criteria
to define SMEs (figure 4.3). As in sales criteria, high-income
countries tend to have higher loan size brack-ets
in their definition of SMEs. Canada, the United
States, Estonia, and Australia set the loan value cutoff
for SMEs above $1 million.
In the long term, encouraging financial institutions
to collect and maintain information on employee
numbers and sale volumes will allow for more accu-rate
monitoring of SME lending. The data may also
be useful to banks themselves for client segmentation
and development of SME scoring models. In the short
term, collecting data using loan size criteria as a proxy
may provide a reasonable estimate of SME volumes
for regulators tasked with monitoring this statistic.
A number of efforts aim to streamline and harmo-nize
SME definitions,10 although the heterogeneity
of SMEs themselves and the nature of the economies
in which they operate might mean that establishing a
global definition is not feasible.
Variation in definition is not significantly
correlated with variation in lending volumes
to SMEs
Do economies that set higher cutoff criteria for the
number of employees and sales tend to have a higher
ratio of SME lending volume to GDP? The correla-tion
between the maximum number of employees and
the ratio of SME loans to GDP reported in Financial
Access 2010 is positive but weak and not statistically
significant at the 10 percent level.11 The correlation
coefficient between the maximum definition for sales
and SME lending volume is also not statistically signif-icant.
These results must be interpreted with caution
as estimates are based on a small number of observa-tions:
40 for the number of employees and 31 for the
sales volume. Lack of a strong correlation (except for
those economies defining SMEs as firms with 1,000
employees or more) indicates that the variation in the
definitions for the most part is not a strong enough
factor to permit cross-country comparison of the data
on SME lending using national definitions.
Estimating global SME volume
In Financial Access 2010, 50 economies provided data
on the total value of outstanding loans to SMEs (fig-ure
4.4). Out of these, 30 economies (60 percent) are
FIGURE 4.3
Economies that dene SMEs by loan value
Loan value threshold
middle-income and 14 (28 percent) are high-income.
$ thousands
Source: Financial Access database. Among low-income countries, only Afghanistan, Ban-
Peru
Tajikistan
Dominican Republic
Guatemala
Zimbabwe
Syrian Arab Republic
Morocco
Liberia
Azerbaijan
Kuwait
South Africa
United States
Estonia
Australia
Canada
0 500 1,000 1,500 2,000

FIGURE 4.4
Value of outstanding loans to SMEs
Tajikistan
Botswana
Guatemala
Cape Verde
Indonesia
Peru
Argentina
Afghanistan
Liberia
Pakistan
Ecuador
Panama
Brazil
Costa Rica
India
Armenia
Uzbekistan
United States
Russian Federation
Georgia
El Salvador
Iran, Islamic Rep.
Mongolia
Kazakhstan
Uruguay
Turkey
Poland
Jordan
Morocco
France
South Africa
Albania
Italy
Hungary
Singapore
Australia
Bangladesh
Malaysia
Belgium
Taiwan, China
Thailand
Estonia
Japan
Korea, Rep.
Latvia
China
Portugal
Netherlands
as a % of GDP
0 10 20 30 40 50
as a % of commercial bank loans to individuals and nonnancial businesses
Cape Verde
Guatemala
Indonesia
Botswana
Panama
Tajikistan
Peru
Singapore
Costa Rica
Argentina
India
Jordan
United States
South Africa
Pakistan
Brazil
Kazakhstan
Iran, Islamic Rep.
Australia
Russian Federation
El Salvador
Liberia
Belgium
Malaysia
Ecuador
Netherlands
Italy
Mongolia
Taiwan, China
Morocco
Hungary
Uzbekistan
Georgia
Poland
Turkey
Armenia
Estonia
Afghanistan
France
Albania
China
Thailand
Portugal
Uruguay
Japan
Latvia
Bangladesh
Korea, Rep.
0 10 20 30 40 50

FIGURE 4.5
SME lending volumes are higher in developed credit markets and where starting a business is faster
gladesh, Liberia, Pakistan, Tajikistan, and Uzbekistan
provided these data points. The ratio of SME lending
to GDP ranges from less than 1 percent in Tajikistan to
more than 50 percent in the Netherlands and Portugal.
The median ratio of SME credit to GDP is 6.4 percent,
and in 75 percent of the economies in the sample, it is
below 15 percent.
The share of SME loans as a percentage of total loans
also varies greatly across countries, reflecting the struc-ture
of the local financial market (figure 4.4). The ratio
of SME loans to total loans ranges from less than 1 per-cent
in Hong Kong Special Administrative Region (Chi-na),
to 56 percent in Korea, where SMEs can employ up
to 1,000 people. Overall, high-income countries tend
to have higher ratios of SME finance volume to GDP
and to total loans, suggesting a more developed SME
finance market compared with developing countries.
To assess the global volume of SME financing from for-mal
institutions for Financial Access 2010, the value of
SME lending to GDP ratio was estimated for economies
that have not provided statistics on SME finance using a
regression model. Model selection is based on two fac-tors:
data availability and predictive power. The ratio of
overall private credit to GDP, number of days to start a
business, and a control for offshore financial centers are
used as explanatory variables in this model.12 The level
of SME finance is likely to be affected by the overall
development of the credit market as measured by the
ratio of private credit to GDP (figure 4.5). In addition,
economies in which it is easier to start a business are
likely to have higher levels of SME lending. One poten-tial
explanation is that in those economies where it is
more difficult to start a business, there are fewer formal
SMEs to finance, and hence lower SME lending. This
finding supports earlier evidence on the importance of
reforming business registration and other regulations
affecting firm entry.13 The share of SME finance in rela-tion
to total lending volume is likely to be affected by
the structure of the financial market. Specifically, off-shore
financial centers are likely to have high levels of
credit to GDP but low levels of SME financing.
On the basis of these estimates, global volume of SME
lending was roughly $10 trillion in 2009 (map 4.1).
The bulk of SME lending volume—70 percent—is
concentrated in high-income countries. The second
largest SME loans market is in East Asia and the Pa-cific,
which accounts for 25 percent of the total SME
High
Low
Low High
Private credit / GDP*
SME lending volume / GDP
SME lending volume / GDP
High
Low
Slower Faster
Time to start a business**
* Correlation controls for time to start a business and oshore centers. The relationship is statistically signicant at the 5 percent level.
** Correlation controls for expected private credit/GDP and oshore centers. The relationship is statistically signicant at the 5 percent level.

MAP 4.1
SME lending volume
(% of GDP)
lending volume. But 90 percent of this amount is in
China, where the SME definition is broad and SMEs
can employ up to 2,000 people. Without China, the to-tal
SME lending volume in East Asia is comparable to
Eastern Europe and Central Asia, or about 3 percent of
the total. Africa, Middle East, and South Asia together
account for only 1.6 percent of the total SME volume.
A similar picture emerges when comparing ratios of
SME lending to GDP (map 4.1). The median ratio of
SME lending to GDP in high-income OECD countries
is about 13 percent, compared with the 3 percent world
median. In more than 80 percent of economies, the
SME lending to GDP ratio is below 10 percent.
Data analysis indicates that further efforts are neces-sary
to define the criteria and processes for collecting
data on SME financing, which can also be compara-ble
across countries. A recently created SME Finance
subgroup under the G-20 Financial Inclusion Experts
Group,14 bringing together international experts, de-velopment
agencies, and governments, offers an excel-lent
platform for the establishment of a comprehensive,
consistent, and scalable framework and mechanism to
measure and track the progress over time of SME ac-cess
to financial services in the developing world.
notes
1. Ayyagari, Beck, and Demirgüç-Kunt (2007).
2. World Bank Enterprise Analysis Surveys (various years).
3. Beck and Demirgüç-Kunt (2006).
4. World Bank Enterprise Analysis Surveys (various years).
5. The Pittsburgh G-20 Summit (2009).
6. OECD (2004).
7. OECD (2007).
8. European Commission (various years).
9. This figure is based only on data provided in the Financial Ac-cess
2010 survey and does not include any external sources.
10. OECD (2004).
11. The correlation, controlling for income per capita, is not statisti-cally
significant when countries that set a maximum definition
at 1,000 employees or more are excluded (Korea and China).
The estimate is based on 65 observations. Financial Access 2010
survey data were supplemented by information on maximum
number of employees for SMEs from other sources, including
World Bank (2004) and World Bank Enterprise Analysis Sur-veys
(various years).
12. For details on estimation results see Ardic, Mylenko, and Sal-tane
(forthcoming). A number of macroeconomic and business
environment factors were tested, but relationships are not sta-tistically
significant after controlling for overall level of private
credit to GDP.
13. See World Bank (2004) for an overview.
14. See the Pittsburgh G-20 Summit (2009), “Leaders’ Statement,”
paragraph 41.
0–4
4–8
8–20
20 and above
NO DATA
Europe
Central Asia
$256 billion
High-Income OECD
and Non OECD
$7 trillion
East Asia
Pacic
$2.5 trillion
Middle
East
North
Africa
$43 billion
Latin America
Caribbean
$133 billion
South
Asia
$73 billion
Sub-Saharan
Africa
$45 billion
Note: OECD = Organisation for Economic Co-operation and Development
The map plots a ratio of SME lending volume to GDP. Actual data is presented for 50 economies that
provided information. For the remainder of the economies, the ratio of SME lending to GDP is predicted by
a regression model controlling for the ratio of private credit to GDP, the number of days to start a business
(Doing Business database) and a dummy for oshore nancial centers. See Ardic, Mylenko and Saltane
(forthcoming) for detailed methodology. Data for Taiwan (China), Hong Kong SAR (China), and Puerto Rico
(US) have been broken out from the national dataset.
42

Data availability
More economies provided data on the value and num-ber
of loans and deposits across all types of institutions
in the Financial Access 2010 survey compared to the
2009 survey (figure 5.1). Information for commercial
banks remains the most comprehensive. But even for
commercial banks, while most economies provided
information on the values of deposits and loans, only
76 percent had data on the number of deposits and 53
percent on the number of loans.
Information for nonbanks is limited for four primary
reasons. First, if nonbanks are not regulated by the
main financial regulator, this regulator may not have
data on these institutions. Second, even if nonbanks
are regulated, it may be difficult to collect accurate data
on their performance because of a lack of adequate
systems in nonbanks. Third, in economies where there
are several types of regulated nonbanks, the regula-tor
may be able to collect information on only certain
types of institutions, resulting in distorted statistics.
Fourth, institutions may change their type (in other
words, the way they categorize themselves), or a new
type of institution may be introduced that fits into one
of the categories in the Financial Access 2010 survey,
introducing breaks in data consistency.
Most economies take measures to improve data avail-ability,
demonstrated by the improved responses to
the Financial Access 2010 survey and responses to
the International Monetary Fund’s (IMF) “Access to
Finance” project launched this year.1 A number of
countries, such as Mexico and Bangladesh, were able
to provide more comprehensive coverage of nonbanks
this year, including institutions that were not covered
last year.
With improved and cheaper technology and the push
for transparency and better reporting, data on access
will undoubtedly improve over time. But even today,
available data provide useful insights. A consistent
sample in which comparable data are available for
both years is sufficiently large, at least for commercial
banks, enabling empirical analysis presented in this
FIGURE 5.1
More economies provided data in 2010
Reported in
Financial Access 2009
Reported in
Financial
Access 2010
0 20 40 60 80 100 120 140
Number of economies providing data
Data provided
Commercial banks
Number of deposit accounts
Volume of deposit accounts
Number of loans
Volume of loans
Cooperatives
Number of loans
Volume of loans
SSFIs
Number of loans
Volume of loans
Micronance institutions
Number of loans
Volume of loans
Note: SSFI = specialized state nancial institution.
report: 85 economies for the number of deposits and
65 for the number of loans.
To understand what research and data collection in-struments
beyond regular reporting are available to
financial regulators, the Financial Access 2010 survey
asked what type of survey instruments (household
surveys, surveys of firms, surveys of financial institu-tions)
they use for collecting information on the level
of access to financial services.
Fifty-one percent of financial regulators responding
say they collect at least some information through one
type of survey instrument (figure 5.2). Household sur-veys
are most popular, followed by surveys of financial
institutions. Surveys of firms are the least popular.

FIGURE 5.2
Data collection
13
19
10 1
23
52
18
64
22
58
Annually
Irregular
Regular surveys by regulators are an important source
of information for guiding policy. For example, in the
United States, the Senior Loan Officer Opinion Sur-vey
on Bank Lending Practices is conducted quarterly
to inform the meetings of the Federal Open Market
Committee determining U.S. monetary policy. The
survey questions cover changes in the standards and
terms of the banks’ lending and the state of business
and household demand for loans.
These surveys could also become an important tool for
collecting information comparable across countries by
introducing standardized questions.
note
1. IMF (2009).
49%
No data
collected
51% of economies
collect information
through at least one survey
% of economies by type and frequency of survey
Household
surveys
Survey
of rms
2
Survey of
nancial
institutions
2
Never
Every 3
or more
years
Every 2 years
16

Methodology
Financial Access 2010 is the second in an annual series
presenting indicators on access to savings, credit, and
payment services in banks and regulated nonbank fi-nancial
institutions. The report updates data on access
to financial services from a survey of financial regula-tors
in 142 economies and includes new chapters on
financial inclusion mandates and reforms, consumer
protection policies, and SME finance.
Survey design
Data were collected through a survey sent to the main
financial supervisors, such as central banks or bank su-pervisory
agencies. The survey questionnaire consists
of two parts: the statistical table and policy questions.
Statistical table Similar to the 2009 survey, the
2010 questionnaire collected data on the numbers
and volumes of deposit accounts and loans, number
of bank branches, ATMs, and POS terminals, as well
as other measures of the use of financial services by
banks and formal regulated nonbank financial insti-tutions.
A formal financial institution is a registered
business whose primary activity is providing financial
services. Formal financial institutions can be regulated
or nonregulated. A financial institution is considered
regulated if it is subject to regulation and/or supervi-sion
by any of the state regulators. The regulatory re-quirements
that apply to such institutions could be
prudential or nonprudential. The data were collected
for commercial banks and for regulated nonbank fi-nancial
institutions, adding value to other studies that
have preceded it. To make the cross-country compari-son
of the services provided by the different types of
financial institutions possible, the respondents were
asked to classify types of regulated institutions into
four broad categories:1
Commercial banks Banks with a full banking license.
In some countries, the term “universal banks” or other
terms may be used. Majority government- and state-owned
banks should be included in this category to
the extent that they perform a broad set of retail bank-ing
functions and are regulated and supervised in the
same manner as privately owned banks.
Cooperatives, credit unions, and mutuals Financial
institutions that are owned and controlled by their
members (customers), regardless of whether they do
business exclusively with their members or with mem-bers
and nonmembers.
Specialized state financial institutions Specialized
state-owned institutions are extensions of the govern-ment
whose main purpose is to lend support to eco-nomic
development and/or to provide savings, pay-ment,
and deposit services to the public. They include
postal banks, government savings banks, SME lending
facilities, agriculture banks, and development banks.
Microfinance institutions Institutions whose primary
business model is to lend to (and possibly take depos-its
from) the poor, often using specialized methodolo-gies
such as group lending.
The data collected using this institutional classifica-tion
necessarily understate the scale of microfinance
because many banks, cooperatives, and specialized
state-owned institutions provide microfinance servic-es
as part of their activities.
Policy questions The second part of the survey con-tains
questions on regulations relating to the provi-sion
of financial services, including financial inclusion
mandates, consumer protection, and measurement of
SME finance.
Survey sample
Questionnaires were sent to 151 economies: 13 in East
Asia and the Pacific, 27 in Europe and Central Asia, 20
in Latin America and the Caribbean, 14 in the Middle
East and North Africa, 6 in South Asia, 40 in Sub-
Saharan Africa, and 23 in the high-income OECD
countries. For practical purposes, most small islands
and economies at war were not included. The sample
covers more than 94 percent of the world’s population
and nearly 98 percent of global GDP.
The questionnaires were sent directly to the governors’
offices of central banks. When appropriate, they were
also sent to monetary authorities or banking super-visory
agencies. Depending on the economy and the

structure of the regulatory authority, the questionnaires
were filled out by one or several of the following de-partments:
research, statistics, supervision, and foreign
relations. Of the 151 questionnaires sent, 142 econo-mies
responded, for a response rate of 94 percent.
The data passed several robustness checks. First, the
numbers and values of deposit and loan accounts for
banks and other regulated financial institutions were
compared with those from the 2009 survey. Where
discrepancies exceeded 20 percent from the previ-ous
year, extensive follow-up was conducted to verify
the numbers or to explain the data differences. Values
were also cross-checked with GDP, population, private
credit, and deposit statistics available in World Devel-opment
Indicators and International Financial Statis-tics
databases.
Multiple checks for internal consistency and rational-ity
were also conducted. When anomalies were found,
the respondents were asked to provide clarification. In
the absence of adequate clarity, the data points were
dropped (in only a few cases).
Main limitations of the approach
The survey collects information only on regulated
financial institutions, leaving out nonregulated pro-viders
of financial services. This practice is likely to
significantly understate the scale of credit services,
which are often not regulated, unlike deposit services.
Even though the main financial regulator was asked to
provide data on all regulated financial institutions, in
cases where some financial institutions are regulated
by other regulators, the data are rarely available. As a
result, the available data understate the true scale of
financial services provided by regulated financial in-stitutions
and likely understate the size of the nonbank
segment in relation to commercial banks.
Data on the number of borrowers and depositors are
available in only a few economies. Instead, the number
of deposit and loan accounts is used as a basis for core
access indicators, double-counting clients with mul-tiple
accounts. Another imperfection stems from the
different treatment of dormant accounts—some banks
close dormant accounts after six months of inactivity,
while others keep such accounts open for many years.
Global estimates and maps of banked
individuals and SME lending
Maps for banked individuals use data from the Finan-cial
Access database as well as other sources. More spe-cifically,
country-level data from the Financial Access
database are complemented by various household sur-veys.
Because most financial regulators are unable to
report data on the number of individuals with a bank
account, the use of household surveys is of great value
even though these surveys are not fully comparable
across economies and time.
Nonetheless, data from 46 such household surveys
across the world are used to estimate a regression
model.2 The share of households having a deposit ac-count
in commercial banks is then predicted using the
estimates of this model where the number of deposit
accounts per 1,000 adults and number of branches per
km2 are controlled for.3
Financial Access 2010 predicts the ratio of SME lend-ing
to GDP using the ratio of overall private credit
to GDP, a control for offshore financial centers (both
from the IMF), and number of days to start a busi-ness
(from the Doing Business database) by employing
a regression model.4 Model selection is based on two
factors: data availability and predictive power.
notes
1. To improve cross-country data comparability, definitions have
been slightly modified from those in Financial Access 2009.
2. This regression model was originally developed by Beck, Demir-güç-
Kunt, and Martinez Peria (2007) and Honohan (2008).
3. For estimation results, see Ardic, Heimann, and Mylenko (forth-coming)
on financial access.
4. For estimation results, see Ardic, Mylenko, and Saltane (forth-coming)
on SME financing.

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IFC Discussion Paper 43. International Finance Corpora-tion,
Washington, DC.
Stephanou, Constantinos, and Camila Rodriguez. 2008. “Bank
Financing to Small and Medium-Sized Enterprises (SMEs)
in Colombia.” Policy Research Working Paper 4481. World
Tejerina, Luis, and Glenn D. Westley. 2007. “Financial Ser-vices
for the Poor: Household Survey Sources and Gaps in
Borrowing and Saving.” Sustainable Development Depart-ment
Technical Papers Series POV–117. Inter-American
Development Bank, Washington, DC.
U.S. GAO (Government Accountability Office). 2005. “Credit
Reporting Literacy: Consumers Understood the Basics but
Could Benefit from Targeted Educational Efforts.” United
States Government Accountability Office, Washington,
DC.
World Bank. 2004. Doing Business in 2004: Understanding
Regulations. Washington, DC: World Bank.
———. Various years. Enterprise Analysis Surveys. Washing-ton,
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———. Various years. Living Standard Measurement Survey.
Washington, DC: World Bank. http://iresearch.worldbank.
org/lsms/lsmssurveyFinder.htm.

49
REGIONAL PROFILE
East Asia and
the Pacic
Number of key
nancial access indicators
included in Financial Access 2010
Accounts in commercial banks
Median per 1,000 adults
2,022
High-income
countries
East Asia 1,756
Pacic
737
Developing
countries
Bank branches and ATMs
32 High-income
countries
East Asia
Pacic
Deposit
accounts
701
258
272
Loan
accounts
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
54
54
East Asia
Pacic
% of economies:
With strategy document
for nancial industry
With designated unit
within regulatory agency
Average extent
of regulator's
responsibilities
34
54
65
Developing
countries
15
10
Branches ATMs
94
29
11
Consumer protection legislation and implementation
% of economies:
within regulatory body
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
31
54
30
56
56
High-income
countries
Developing
countries
East Asia
Pacic
4
3
2
1
0
Note: The key nancial access indicators are number of
deposit accounts, value of deposit accounts, number of
loan accounts, and value of loan accounts.

REGIONAL PROFILE
Europe and
Central Asia
Number of key
Europe 1,330
Central Asia
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
38
20
701
258
Europe
Central Asia
% of economies:
Average extent
of regulator's
responsibilities
34
54
41
Europe 18
Developing
countries
32
High-income
countries
10
Central Asia
Branches ATMs
94
29
50
38
42
32
60
Europe
Central Asia
% of economies:
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
65
High-income
countries
Developing
countries
4
3
2
1
0
2,022
High-income
countries
737
Developing
countries
Deposit
accounts
Loan
accounts
349

REGIONAL PROFILE
Latin America
and the Caribbean
Number of key
2,022
High-income
countries
737
Developing
countries
1,140
Latin America
Caribbean
Deposit
accounts
701
258
346
Loan
accounts
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
38
33
Latin America
Caribbean
% of economies:
Average extent
of regulator's
responsibilities
34
54
39
32
High-income
countries
10
31
Latin America
Caribbean
Branches ATMs
94
29
14
Developing
countries
46
Latin America
Caribbean
4
3
2
1
0
48
67
44
76
% of economies:
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
High-income
countries
Developing
countries

REGIONAL PROFILE
Middle East
and North Africa
Number of key
4
3
2
1
0
2,022
High-income
countries
818
Middle East
North Africa
Developing 737
countries
Deposit
accounts
701
258
201
Loan
accounts
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
40
23
Middle East
North Africa
% of economies:
Average extent
of regulator's
responsibilities
34
54
40
Developing
countries
32
High-income
countries
17
10
Branches ATMs
94
29
50
50
46
59
Middle East
North Africa
% of economies:
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
50
High-income
countries
Developing
countries
Middle East
North Africa
28

REGIONAL PROFILE
South
Asia
Number of key
2,022
High-income
countries
737
Developing
countries
South 317
Asia
Deposit
accounts
701
258
38
Loan
accounts
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
100
58
South
Asia
% of economies:
Average extent
of regulator's
responsibilities
34
54
92
High-income 32
countries
Developing
countries
10
4
Branches ATMs
94
29
7
29
South
Asia
% of economies:
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
High-income
countries
Developing
countries
South Asia
4
3
2
1
0
33
83
42
46

REGIONAL PROFILE
Sub-Saharan
Africa
Number of key
2,022
High-income
countries
737
Developing
countries
Sub-Saharan 163
Africa
Deposit
accounts
701
258
28
Loan
accounts
Financial inclusion
mandate
17
23
High-income
countries
56
40
Developing
countries
81
56
Sub-Saharan
Africa
% of economies:
Average extent
of regulator's
responsibilities
34
54
71
Developing
countries
32
High-income
countries
10
5
Branches ATMs
94
29
3
% of economies:
With at least
one recourse
mechanism
Average extent
of periodic
disclosure
Average extent
of disclosure
at opening
Average extent
of fair treatment
59
81
44
63
86
45
52
38
48
59
55
42
37
37
47
High-income
countries
Developing
countries
Sub-Saharan
Africa
Sub-Saharan
Africa
4
3
2
1
0

Statistical
and policy tables
Table 1 Financial access: Commercial banks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
Table 2 Financial access: Cooperatives and credit unions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
Table 3 Financial access: Specialized state financial institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Table 4 Financial access: Microfinance institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
Table 5 Outreach: ATMs and POS terminals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
Table 6 Financial inclusion: Aspects under the purview of the financial regulator . . . . . . . . . . . . . . . . 67
Table 7 Financial inclusion: Areas of reform in 2009 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
Table 8 Consumer protection: Compliance monitoring and enforcement by supervisory agency . . . 73
Table 9 Consumer protection: Disclosure requirements at account opening . . . . . . . . . . . . . . . . . . . . . 76
Table 10 Consumer protection: Requirements for periodic disclosure . . . . . . . . . . . . . . . . . . . . . . . . . 79
Table 11 Consumer protection: Fair treatment, dispute resolution, and recourse . . . . . . . . . . . . . . . . . 82
Table 12 Small and medium enterprise finance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Deposits Loans Outreach
Table 1
Financial access: Commercial banks
Accounts per
1,000 adults
Value (% of
GDP)
Average account
value (% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Branches per 100,000 adults
Economy Total Urban Rural
Afghanistan 83.85 25.90 .. 3.32 7.79 .. 2.00 0.24 1.76
Albania 1,278.63 56.58 58.38 107.53 36.70 450.35 22.29 .. ..
Algeria 736.56 36.05 67.73 .. 23.57 .. 5.30 .. ..
Anguilla 4,426.58 .. .. 790.84 .. .. 55.07 36.71 18.36
Antigua and Barbuda 2,971.58 104.24 47.88 579.76 95.18 224.07 27.13 .. ..
Argentina 906.29 21.61 31.95 526.33 12.92 32.91 13.20 .. ..
Armenia 630.51 14.48 28.90 163.67 16.25 124.92 15.99 .. ..
Australia .. 75.18 .. .. 115.67 .. 31.86 24.49 7.37
Austria 2,402.71 50.84 24.95 .. 58.63 .. 27.54 .. ..
Azerbaijan 678.32 11.55 22.58 .. 22.16 .. 9.57 4.97 4.60
Bangladesh 316.67 50.04 232.52 41.37 36.88 1,311.74 5.16 2.57 2.59
Belarus .. .. .. .. 37.83 .. 45.00 .. ..
Belgium 3,968.95 137.40 41.63 .. 140.96 .. 48.49 .. ..
Benin 99.85 .. .. .. .. .. 2.89 .. ..
Bolivia 337.50 41.74 195.49 75.60 24.78 518.03 6.94 5.78 1.16
Bosnia and Herzegovina .. 49.74 .. 338.29 55.84 195.69 19.95 .. ..
Botswana 479.36 30.19 95.00 212.08 14.61 103.91 8.00 5.78 2.22
Brazil 1,065.35 35.55 45.32 533.49 30.88 78.61 12.71 .. ..
Bulgaria 2,005.78 51.78 29.81 455.14 71.34 181.02 92.10 .. ..
Burkina Faso 67.61 .. .. .. .. .. 1.82 .. ..
Burundi 23.35 30.10 2,112.28 3.81 21.36 9,195.09 1.81 0.87 0.93
Cambodia 95.83 34.68 549.34 27.15 25.53 1,427.20 3.92 .. ..
Canada .. 117.79 .. .. 95.18 .. 24.11 .. ..
Cape Verde 1,137.83 73.92 103.04 184.30 55.92 481.23 28.94 25.12 3.82
Chile 729.76 40.05 71.44 647.26 64.34 129.41 14.92 14.92 ..
China .. 206.90 .. .. 143.88 .. .. .. ..
Colombia 1,267.44 25.97 29.09 469.75 24.64 74.45 14.30 9.26 5.04
Costa Rica 1,353.83 46.76 46.95 602.52 45.32 102.23 23.30 16.67 6.64
Côte d'Ivoire 75.44 .. .. .. .. .. .. .. ..
Croatia 1,441.51 70.10 57.42 .. 71.28 .. 34.54 .. ..
Czech Republic 1,739.26 62.91 42.13 .. 46.89 .. 22.17 .. ..
Denmark .. 95.46 .. .. 129.50 .. 45.36 .. ..
Dominica 1,608.76 130.16 107.22 219.40 78.65 475.08 14.48 7.24 7.24
Dominican Republic .. 28.06 .. 245.09 19.53 116.89 9.98 5.93 4.04
Ecuador 569.24 26.70 68.44 300.60 17.98 87.30 1.61 .. ..
El Salvador 825.00 41.03 74.26 341.30 39.06 170.89 9.30 .. ..
Estonia 2,669.14 70.95 31.26 985.49 114.55 136.70 18.68 17.81 0.88
Ethiopia 93.59 23.99 456.51 1.70 12.10 12,648.43 1.39 .. ..
Finland .. 30.03 .. .. 59.96 .. .. .. ..
France 771.99 25.75 40.88 .. 35.83 .. 43.21 .. ..
Gambia, The 283.20 .. .. 31.11 .. .. 6.70 4.29 2.41
Georgia 626.63 19.53 37.59 313.19 24.26 93.44 18.57 15.25 3.32
Germany .. 25.61 .. .. 28.13 .. 15.91 .. ..
Ghana 332.61 39.49 193.74 .. 27.08 .. 5.11 .. ..
Greece 2,951.45 105.23 41.56 1,208.83 94.44 91.08 41.50 .. ..
Grenada 2,556.00 135.29 73.68 355.90 112.74 440.93 32.97 15.82 17.14
Guatemala 1,139.58 34.54 52.48 341.75 24.48 124.04 35.75 15.45 20.31
Guinea-Bissau 5.81 .. .. .. .. .. .. .. ..
Honduras 758.02 48.73 103.67 335.00 .. .. 1.47 1.47 ..
Hong Kong SAR, China .. 381.47 .. .. 192.64 .. 21.19 21.19 ..

Table 1 (continued)
Accounts per
1,000 adults
Value (% of
GDP)
Average account
value (% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Hungary 2,058.27 38.06 21.74 .. 58.02 .. 18.31 17.80 0.52
Iceland .. 80.65 .. .. 84.43 .. 37.50 18.35 19.15
India 747.29 55.03 107.86 137.46 40.93 436.09 10.11 3.82 6.29
Indonesia 504.74 36.95 100.76 196.86 26.93 188.28 7.74 .. ..
Iran, Islamic Rep. of .. 52.65 .. .. 44.53 .. 29.15 .. ..
Ireland 2,181.85 84.36 48.67 .. 180.14 .. 57.27 .. ..
Israel 1,055.71 102.28 134.20 926.12 81.94 122.56 19.85 19.49 0.36
Italy 774.99 47.78 71.84 701.10 66.83 111.07 52.04 .. ..
Jamaica 1,149.68 26.96 33.49 201.72 19.36 137.03 6.64 3.66 2.97
Japan 7,172.42 146.24 23.56 177.63 85.08 553.33 12.46 .. ..
Jordan 898.81 142.85 244.91 200.64 92.87 713.30 17.79 17.19 0.60
Kazakhstan .. 40.06 .. .. 49.51 .. 2.79 .. ..
Kenya 381.62 38.99 178.49 75.48 27.77 642.80 4.38 .. ..
Korea, Rep. of .. 61.55 .. .. 67.01 .. 12.27 .. ..
Kuwait .. 52.03 .. .. 52.27 .. 16.47 .. ..
Kyrgyz Republic 145.59 17.49 170.99 23.31 13.25 808.72 6.45 4.83 1.62
Lao PDR .. 25.53 .. .. 16.87 .. 1.64 .. ..
Latvia 1,205.16 55.91 53.80 653.17 90.40 160.51 14.64 .. ..
Lebanon 1,371.98 338.49 332.69 519.89 93.38 242.20 28.83 15.67 13.16
Lesotho 254.41 31.32 202.38 38.98 10.56 445.26 2.12 2.12 ..
Liberia 102.08 31.76 545.23 3.67 15.76 7,528.90 1.85 1.85 ..
Lithuania 4,190.10 34.91 9.83 353.53 52.19 174.25 25.90 .. ..
Macedonia, FYR .. 44.74 .. 463.86 41.35 109.29 25.69 25.45 0.24
Madagascar .. 19.90 .. .. 10.84 .. 1.49 .. ..
Malawi 163.44 27.94 319.05 16.52 18.45 2,084.29 2.16 1.10 1.06
Malaysia 2,063.33 105.45 72.96 963.60 113.16 167.64 11.44 9.55 1.89
Mali 116.02 .. .. .. .. .. 3.48 .. ..
Mauritania .. .. .. .. .. .. 3.89 3.89 ..
Mauritius 2,109.04 92.10 56.85 479.24 64.10 174.10 20.11 10.16 9.95
Mexico 1,096.76 15.08 19.38 .. 13.36 .. 14.67 13.22 1.44
Moldova .. 35.47 .. .. 5.90 .. 9.57 9.37 0.20
Mongolia 2,089.32 37.99 24.75 259.66 35.11 184.09 53.99 10.45 43.54
Montserrat 3,680.04 .. .. 246.48 .. .. 54.23 54.23 ..
Morocco 265.28 53.08 280.98 .. 51.31 .. 9.92 .. ..
Mozambique 140.50 38.40 488.58 .. 26.83 .. 2.89 .. ..
Namibia 757.61 38.14 80.38 209.80 46.87 356.74 7.25 7.25 ..
Nepal .. 57.62 .. .. 40.70 .. 4.19 .. ..
Netherlands 1,765.79 217.89 150.38 1,085.06 322.40 362.11 25.36 .. ..
New Zealand .. 57.19 .. .. 131.34 .. 35.41 .. ..
Nicaragua .. 38.52 .. .. 28.03 .. .. .. ..
Niger 25.07 .. .. .. .. .. .. .. ..
Nigeria 461.21 31.69 119.88 .. 28.36 .. 6.42 .. ..
Norway .. 82.28 .. .. 84.00 .. 34.49 .. ..
Oman 1,042.61 43.70 .. 412.79 47.28 .. 22.61 .. ..
Pakistan 229.49 29.72 206.50 34.67 21.67 996.76 8.68 5.97 2.51
Panama 411.92 95.29 328.35 349.66 80.79 327.94 18.52 18.52 ..
Papua New Guinea .. 53.93 .. .. 24.05 .. 1.71 .. ..
Paraguay 108.74 37.16 521.21 118.58 23.19 298.25 6.78 .. ..
Peru 783.37 26.81 49.40 317.22 24.07 109.54 7.31 6.01 1.30
Philippines 499.10 48.61 148.21 .. 26.27 .. 11.81 4.33 7.48

Table 1 (continued)
Accounts per
1,000 adults
Value (% of
GDP)
Average account
value (% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Poland 1,626.41 30.27 21.95 .. 33.93 .. 32.21 .. ..
Portugal .. 78.09 .. .. 141.22 .. 68.08 .. ..
Puerto Rico 1,300.23 69.57 .. .. 69.21 .. 15.72 .. ..
Romania .. 27.42 .. 344.42 32.69 111.97 35.00 29.43 5.56
Russian Federation .. 25.34 .. .. 38.85 .. 2.62 .. ..
Rwanda 226.15 16.79 128.48 .. 13.98 .. 1.87 .. ..
Senegal 109.35 .. .. .. .. .. 4.05 .. ..
Serbia .. 50.17 .. .. 43.89 .. 43.36 .. ..
Sierra Leone 98.62 21.47 383.61 9.68 9.83 1,789.61 2.31 1.93 0.38
Singapore 2,236.25 280.88 151.53 914.55 213.43 281.55 10.54 10.54 ..
Slovak Republic 1,857.83 62.73 40.03 .. 54.45 .. 26.64 .. ..
Slovenia 1,380.42 102.07 85.84 .. 99.20 .. 10.99 .. ..
South Africa 839.13 92.92 159.93 .. 95.96 .. 8.00 .. ..
Spain 780.47 46.66 70.11 339.46 68.07 235.15 38.19 .. ..
Sri Lanka 1,891.74 39.52 27.58 .. 29.86 .. 9.05 .. ..
St. Kitts and Nevis 4,366.64 204.20 77.72 663.74 158.04 395.75 57.44 50.68 6.76
St. Lucia 2,504.70 122.28 66.66 373.31 143.37 524.38 18.48 .. ..
St. Vincent and the Grenadines 1,690.53 88.40 71.90 256.82 75.68 405.15 15.12 6.30 8.82
Sudan .. .. .. .. .. .. .. .. ..
Swaziland 236.11 22.39 157.96 70.15 14.82 351.73 2.85 2.85 ..
Sweden .. 136.93 .. .. 152.42 .. 25.87 .. ..
Switzerland .. .. .. .. .. .. .. .. ..
Syrian Arab Republic 191.47 43.88 354.49 72.94 29.79 631.75 2.42 1.92 0.50
Taiwan, China 5,187.77 172.84 40.04 635.68 136.40 257.87 17.95 17.69 0.27
Tajikistan 30.98 10.28 530.89 .. 8.72 .. 3.91 1.29 2.62
Tanzania .. 28.94 .. .. .. .. 1.84 .. ..
Thailand 1,448.84 79.58 70.38 272.45 87.25 410.33 11.04 3.70 7.34
Togo 186.73 .. .. .. .. .. 3.47 .. ..
Tunisia 639.66 58.58 120.04 193.46 59.08 400.31 14.40 13.89 0.51
Turkey 1,661.21 41.82 34.59 360.67 31.18 118.80 17.77 .. ..
Uganda 173.21 19.01 215.18 25.21 12.88 1,001.65 2.25 2.25 ..
Ukraine 3,145.32 22.03 8.14 .. 50.16 .. 2.74 .. ..
United Arab Emirates 1,750.65 .. .. .. .. .. 20.85 .. ..
United Kingdom 2,923.25 61.32 25.44 .. 80.64 .. 20.74 .. ..
United States 2,021.89 43.91 27.30 .. 44.81 .. 36.33 26.64 9.69
Uruguay 529.39 37.55 92.16 428.56 17.81 53.99 12.62 12.62 ..
Uzbekistan 914.92 20.63 32.25 .. 20.28 .. 4.25 1.51 2.73
Venezuela, R. B. de 1,246.39 30.98 35.59 .. 21.61 .. .. .. ..
Vietnam .. 0.11 .. .. 0.10 .. 3.21 1.18 2.03
Yemen, Rep. of 103.90 24.96 430.57 8.25 7.63 1,658.25 1.80 .. ..
Zambia 27.59 18.52 1,248.90 17.81 11.13 1,163.23 3.64 2.58 1.06
Zimbabwe 144.36 85.41 .. 20.53 35.30 .. .. 6.18 0.16

Table 2
Financial access: Cooperatives and credit unions
Economy
Regulated by
supervisory
agency
Accounts per
1,000 adults
Value (% of
GDP)
Average
account value
(% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Total Urban Rural
Albania Yes .. 0.13 .. 8.17 0.37 59.47 .. .. ..
Argentina Yes 0.14 0.01 122.74 6.19 0.04 8.43 0.01 .. ..
Australia Yes .. 4.51 .. .. 4.27 .. 6.78 5.71 1.07
Austria Yes 1,529.80 33.12 25.53 .. 32.98 .. 30.62 .. ..
Azerbaijan Yes .. .. .. 1.46 0.05 49.97 .. .. ..
Belarus No 0.02 0.00 62.35 0.04 0.00 24.04 .. .. ..
Belgium Yes .. 0.04 .. .. .. .. .. .. ..
Bolivia Yes 185.98 5.20 44.17 17.81 3.78 335.95 2.24 1.34 0.90
Botswana No 8.08 0.12 22.12 7.13 0.10 21.65 .. .. ..
Brazil Yes 3.79 0.69 245.71 18.61 0.73 53.51 3.06 .. ..
Burundi Yes 81.40 2.00 40.27 12.48 2.22 291.17 2.80 0.61 2.19
Canada Yes .. 13.02 .. .. 12.80 .. 11.80 .. ..
Chile Yes 73.43 0.62 11.01 42.58 0.62 19.10 1.48 .. ..
Colombia Yes 27.34 0.31 16.08 24.24 0.54 31.41 0.78 0.47 0.31
Costa Rica Yes 370.58 5.28 19.35 191.75 6.66 47.19 8.47 5.31 3.15
Croatia Yes .. 0.11 .. .. 0.12 .. .. .. ..
Czech Republic Yes .. 0.38 .. .. 0.38 .. 0.26 .. ..
Denmark Yes .. 0.73 .. .. 0.69 .. 2.01 .. ..
Dominican Republic Yes .. 4.09 .. 25.17 2.93 170.62 2.82 1.80 1.01
Ecuador Yes 372.06 3.37 13.23 48.15 3.10 93.80 0.36 .. ..
El Salvador Yes 23.35 1.06 68.01 12.63 1.74 205.58 0.80 .. ..
Estonia No 1.25 0.01 8.13 1.46 0.05 36.46 1.75 0.88 0.88
Finland Yes .. 18.91 .. .. 22.19 .. .. .. ..
France Yes 842.05 31.56 45.94 .. 35.24 .. 32.02 .. ..
Gambia, The Yes 37.00 .. .. .. .. .. 5.76 2.51 3.25
Georgia Yes 0.15 0.00 39.55 .. 0.01 .. 14.18 14.18 ..
Germany No .. 17.01 .. .. 15.80 .. 17.43 .. ..
Greece Yes 10.42 1.40 157.01 8.18 1.31 186.71 1.35 .. ..
Honduras No .. 1.19 .. .. 2.91 .. .. .. ..
Hungary Yes .. 4.24 .. .. 2.26 .. 21.64 8.18 13.46
Iceland Yes .. .. .. .. .. .. 0.40 .. 0.40
India Yes 68.90 6.08 129.25 10.15 4.19 604.43 2.78 0.97 1.82
Ireland Yes .. .. .. .. .. .. 11.74 .. ..
Italy Yes 195.00 9.77 58.41 113.09 19.10 196.77 14.22 .. ..
Jamaica Yes 982.43 8.31 12.08 23.60 6.39 386.43 2.50 1.17 1.33
Japan Yes .. 25.97 .. .. 14.64 .. 8.55 .. ..
Korea, Rep. of Yes .. 19.17 .. .. 14.65 .. 16.12 .. ..
Kyrgyz Republic Yes .. .. .. .. 0.51 .. .. .. ..
Latvia Yes 8.79 0.04 5.00 4.06 0.05 14.15 .. .. ..
Lithuania Yes 34.43 0.66 22.57 .. 0.51 .. 6.26 .. ..
Malawi No 12.13 0.03 4.22 30.87 0.34 20.77 .. .. ..
Malaysia No 2.78 0.04 19.16 87.26 0.63 10.25 .. .. ..
Mexico Yes 7.24 0.33 65.01 .. 0.36 .. 1.58 0.11 1.47
Morocco Yes 112.36 23.11 288.87 .. 18.66 .. 3.82 .. ..
Mozambique Yes .. 0.19 .. .. 0.00 .. 0.10 .. ..
Nepal Yes .. 0.40 .. .. 0.37 .. .. .. ..
New Zealand Yes .. 1.32 .. .. 1.22 .. .. .. ..
Papua New Guinea Yes .. 1.51 .. .. 0.98 .. .. .. ..

Table 2 (continued)
Financial access: Cooperatives and credit unions
Economy
Regulated by
supervisory
agency
Accounts per
1,000 adults
Value (% of
GDP)
Average
account value
(% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Total Urban Rural
Peru Yes .. 0.56 .. 25.43 0.65 36.78 1.46 0.68 0.13
Philippines Yes 6.18 0.11 27.07 .. 0.11 .. 0.20 0.00 0.20
Poland Yes 202.27 2.79 16.26 .. 2.19 .. 11.88 .. ..
Portugal Yes .. 6.26 .. .. 4.97 .. 11.85 .. ..
Puerto Rico No 372.12 5,517.97 .. .. 5.01 .. .. .. ..
Romania Yes .. 0.08 .. .. 0.09 .. 0.37 0.33 0.04
Rwanda Yes .. 1.47 .. 5.92 1.39 406.88 .. .. ..
Slovak Republic Yes .. 0.00 .. .. 0.00 .. 0.09 .. ..
South Africa Yes .. 0.04 .. .. 0.04 .. .. .. ..
Spain Yes 1,797.77 70.68 46.10 429.82 83.39 227.51 75.26 .. ..
Sri Lanka No .. 2.31 .. .. 1.75 .. .. .. ..
St. Kitts and Nevis No .. .. .. .. .. .. 13.52 13.52 ..
Taiwan, China No 176.02 4.17 28.45 10.44 2.61 299.90 1.48 1.25 0.24
Tajikistan No 0.05 0.03 818.50 .. 0.01 .. .. .. ..
United Kingdom Yes .. 12.60 .. .. 12.18 .. .. .. ..
United States Yes 723.78 8.63 14.99 .. 10.41 .. 13.05 .. ..
Uruguay Yes 0.83 0.02 33.25 3.32 0.03 11.58 0.04 0.04 ..
Uzbekistan Yes 2.09 0.36 245.55 2.88 0.50 250.05 .. .. ..
Vietnam Yes .. 0.00 .. .. 0.00 .. 0.04 .. ..

Table 3
Financial access: Specialized state financial institutions
Economy
Regulated by
supervisory
agency
Accounts per 1,000
adults
Value (% of
GDP)
Average
account value
(% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Total Urban Rural
Algeria No .. 4.54 .. .. .. .. .. .. ..
Austria Yes 0.01 0.21 25,514.96 .. 2.05 .. .. .. ..
Azerbaijan Yes .. .. .. 0.39 0.04 148.44 0.18 .. 0.18
Bangladesh No 40.02 2.75 101.04 38.52 2.81 107.39 1.26 0.14 1.11
Botswana Yes 421.10 1.21 4.34 16.62 2.32 210.73 1.19 0.95 0.24
Brazil Yes 0.56 0.72 1,753.92 2.20 5.22 3,217.48 1.49 .. ..
Burundi Yes 1.04 0.79 1,245.86 5.59 2.30 673.33 0.04 0.04 ..
Canada Yes .. 1.47 .. .. 1.41 .. 0.60 .. ..
Chile Yes 1,293.17 12.16 12.25 190.14 12.01 82.26 2.66 2.66 ..
Colombia Yes .. 1.94 .. 5.27 3.18 856.96 0.01 0.01 ..
Costa Rica Yes .. 0.09 103,998.10 0.02 0.43 29,317.22 0.03 0.03 ..
Czech Republic Yes 0.75 0.82 1,269.74 .. 0.54 .. 0.07 .. ..
Dominican Republic Yes .. 0.55 .. 0.64 0.34 787.96 0.03 0.03 ..
Ecuador Yes 100.88 3.16 45.65 43.96 4.14 137.36 1.03 .. ..
El Salvador Yes .. .. .. .. 1.15 .. .. .. ..
Ethiopia Yes 0.08 0.13 2,710.00 0.15 2.49 28,780.13 0.07 .. ..
France Yes 0.55 0.01 31.59 .. 0.12 .. 0.14 .. ..
Germany No .. 28.89 .. .. 44.47 .. 19.71 .. ..
Greece No 8.48 2.26 311.25 20.52 2.40 136.41 0.04 .. ..
Honduras Yes 31.58 0.31 15.87 4.17 .. .. 0.07 0.07 ..
Hungary Yes .. 0.12 .. .. 3.00 .. .. .. ..
Iceland Yes .. .. .. .. 38.08 .. .. .. ..
Iran, Islamic Rep. of Yes .. 8.01 .. .. 11.10 .. 6.09 .. ..
Ireland No .. .. .. .. .. .. 27.72 .. ..
Japan Yes .. 0.61 .. .. 5.59 .. 0.24 .. ..
Jordan No .. .. .. .. 1.77 .. 0.91 .. ..
Korea, Rep. of Yes .. 16.78 .. .. 31.56 .. 3.77 .. ..
Kuwait Yes .. .. .. .. .. .. 0.10 .. ..
Lesotho Yes 64.96 1.23 31.05 .. .. .. 0.98 0.57 0.41
Macedonia, FYR Yes .. .. .. .. 0.01 3,400.53 .. .. ..
Malaysia Yes 1,146.06 13.71 17.08 113.07 12.09 152.60 4.26 .. ..
Mexico Yes 63.20 0.15 3.40 .. 0.07 .. 0.75 0.48 0.28
Morocco Yes 34.50 9.62 391.63 .. 11.67 .. 2.17 .. ..
Nepal Yes .. 4.91 .. .. .. .. 1.39 .. ..
Nigeria Yes .. .. .. .. 0.29 .. 0.26 .. ..
Norway No .. .. .. .. 7.36 .. .. .. ..
Oman Yes .. 0.03 .. .. 1.28 .. 1.22 .. ..
Pakistan Yes 11.32 0.21 29.39 8.37 1.14 216.66 0.52 0.34 0.18
Panama No 351.35 28.23 114.04 62.51 13.37 303.54 4.64 4.64 ..
Peru Yes 242.89 4.04 24.02 30.83 0.60 28.20 2.25 0.52 1.74
Philippines Yes 55.60 5.07 138.83 .. 3.27 .. 0.71 0.15 0.56
Portugal Yes .. 6.26 .. .. 4.97 .. 11.85 .. ..
Puerto Rico Yes .. 8.62 .. .. 8.14 .. .. .. ..
Romania Yes .. .. .. .. .. .. 0.07 0.07 ..
Rwanda Yes .. .. .. 0.16 1.82 19,750.08 .. .. ..
Sierra Leone Yes .. .. .. .. .. .. 0.03 .. ..
Slovak Republic Yes .. 0.25 .. .. 0.55 .. 0.24 .. ..

Table 3 (continued)
Financial access: Specialized state financial institutions
Economy
Regulated by
supervisory
agency
Accounts per 1,000
adults
Value (% of
GDP)
Average
account value
(% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Total Urban Rural
Slovenia Yes .. 5.43 .. .. 7.59 .. .. .. ..
South Africa Yes .. 0.13 .. .. 0.63 .. .. .. ..
Spain No 0.01 0.12 21,241.52 0.06 1.40 27,244.42 .. .. ..
Sri Lanka Yes 1,016.32 7.76 10.09 .. 2.96 .. 2.65 .. ..
St. Kitts and Nevis No .. .. .. .. .. .. 6.76 6.76 ..
Swaziland Yes 147.38 3.60 40.69 20.55 5.71 462.61 1.28 1.28 ..
Syrian Arab Republic Yes 2.45 0.90 571.29 25.64 1.50 90.55 0.77 0.41 0.36
Taiwan, China No 1,483.83 35.56 28.80 0.56 0.02 42.10 7.11 6.73 0.38
Tajikistan Yes 17.07 1.32 123.64 .. 0.11 .. 1.76 .. ..
Tunisia No 503.70 12.17 31.66 .. .. .. 13.00 6.89 6.11
Turkey No .. .. .. 0.02 0.72 44,376.91 0.04 .. ..
United States No .. .. .. .. 4.02 .. .. .. ..
Uruguay No .. 0.79 .. .. 4.40 .. 0.31 .. ..
Venezuela, R. B. de Yes 0.72 .. .. .. .. .. .. .. ..
Yemen, Rep. of Yes 37.79 .. .. .. .. .. .. .. ..
Zambia Yes 16.59 0.19 21.00 4.57 0.22 88.64 0.41 0.25 0.16
Zimbabwe Yes 34.24 2.11 .. 1.77 1.27 .. 1.06 0.66 0.40

Table 4
Financial access: Microfinance institutions
Economy
Regulated by
supervisory
agency
Accounts per
1,000 adults
Value (% of
GDP)
Average
account value
(% of income
per capita)
Accounts per
1,000 adults
Value (% of
GDP)
Average value
(% of income
per capita)
Total Urban Rural
Azerbaijan Yes .. .. .. 27.98 0.42 20.06 0.83 0.12 0.70
Bangladesh No .. 3.62 .. 342.77 4.13 17.72 2.36 .. 2.36
Benin Yes 174.07 .. .. 22.10 .. .. 4.55 .. ..
Bolivia Yes 171.74 4.98 45.81 53.99 5.02 147.06 4.96 3.18 1.78
Bosnia and Herzegovina Yes .. .. .. .. 2.47 .. 12.60 7.07 5.53
Botswana Yes 3.97 .. 0.71 0.23 .. 6.19 1.11 0.08 1.03
Brazil Yes 1.09 .. .. 0.04 .. 37.13 0.03 .. ..
Burkina Faso Yes 100.35 .. .. .. .. .. 4.75 .. ..
Burundi Yes 7.35 0.34 75.46 3.74 0.45 199.15 0.47 0.28 0.18
Cambodia Yes 10.63 0.10 14.18 89.99 3.12 52.62 .. .. ..
Côte d'Ivoire Yes 95.12 .. .. 4.13 .. .. 2.12 .. ..
El Salvador Yes 0.36 0.03 128.60 9.39 0.29 45.50 .. .. ..
Ethiopia Yes 50.35 0.67 23.81 50.35 1.43 50.74 0.96 .. ..
Gambia, The Yes 166.83 .. .. 5.41 .. .. 12.04 2.09 9.95
Georgia Yes .. .. .. 29.25 0.61 25.10 14.18 14.18 ..
Ghana Yes .. 2.00 .. .. 1.16 .. 3.17 .. ..
Honduras No .. 0.04 .. .. .. .. 1.25 1.25 ..
Indonesia Yes 2.45 0.33 186.68 17.03 0.52 42.39 0.58 .. ..
Kenya Yes 8.00 3.06 669.55 5.97 0.13 36.68 0.02 .. ..
Madagascar Yes 33.29 0.33 17.26 8.36 0.52 110.12 2.99 1.04 1.95
Malaysia No .. .. .. 19.03 0.22 16.17 1.55 .. ..
Mali Yes 107.11 .. .. 36.07 .. .. 14.76 .. ..
Mexico Yes 30.24 0.07 3.12 8.37 0.07 12.35 1.05 0.94 0.11
Morocco Yes .. .. .. .. 0.82 .. .. .. ..
Mozambique Yes .. .. .. .. 0.06 .. 0.90 .. ..
Nepal Yes .. 0.20 .. .. 0.84 .. 1.94 .. ..
Nicaragua Yes .. 1.77 .. .. 4.03 .. .. .. ..
Niger Yes 26.83 .. .. 4.26 .. .. 1.64 .. ..
Nigeria Yes 34.00 .. .. .. 0.17 .. 2.87 .. ..
Pakistan Yes 20.68 0.05 3.87 17.12 0.15 13.79 1.42 .. ..
Panama Yes 5.50 0.32 81.89 5.01 0.38 106.90 0.54 0.54 ..
Papua New Guinea Yes .. 0.39 .. .. 0.08 .. .. .. ..
Peru Yes 84.88 1.90 32.32 75.04 2.40 46.23 3.78 1.57 2.21
Philippines Yes 8.41 0.02 3.73 .. 0.02 .. 0.47 0.04 0.43
Rwanda Yes .. 0.47 .. 11.00 0.59 92.53 .. .. ..
Senegal Yes 96.72 .. .. 34.41 .. .. 8.75 .. ..
Sierra Leone Yes .. .. .. .. .. .. 0.10 .. ..
South Africa Yes .. 0.04 .. .. 0.57 .. .. .. ..
Sudan Yes .. .. .. .. .. .. 0.04 0.04 ..
Syrian Arab Republic Yes 0.06 .. 8.26 1.13 0.03 37.74 0.06 0.06 ..
Tajikistan No .. 0.12 .. .. 0.09 .. .. .. ..
Togo Yes 104.26 .. .. 15.78 .. .. 4.25 .. ..
Tunisia No .. .. .. 29.77 0.34 15.00 4.48 4.29 0.19
Uganda Yes 22.52 0.12 10.75 8.07 0.33 79.85 0.47 0.47 ..
Uzbekistan Yes .. .. .. 1.17 0.02 26.23 .. .. ..
Yemen, Rep. of Yes 2.93 .. 1.35 3.27 0.42 228.29 0.27 .. ..
Zambia Yes 0.17 0.01 124.03 53.47 0.58 20.22 1.56 1.39 0.18
Zimbabwe Yes .. .. .. 0.76 0.23 .. 1.07 0.85 0.23

Table 5
Outreach: ATMs and POS terminals
Economy
Automated teller
machines Point-of-sale terminals
Per 100,000
adults
Per 1,000
sq. km.
Per 100,000
adults
Per 1,000
sq. km.
Afghanistan 0.38 0.09 2.75 0.67
Albania 31.11 27.04 183.45 159.49
Algeria 5.75 0.60 .. ..
Anguilla 137.67 .. 3,937.23 ..
Antigua and Barbuda 71.81 102.27 1,881.31 2,679.55
Argentina 36.85 4.01 .. ..
Armenia 28.71 24.89 111.24 96.45
Australia 156.69 3.52 4,039.64 90.83
Austria 118.86 102.01 4,174.11 3,582.38
Azerbaijan 25.89 20.49 132.33 104.73
Belarus 32.76 13.02 336.04 133.53
Belgium 138.32 407.24 1,193.42 3,513.66
Bolivia 17.53 0.99 .. ..
Bosnia and Herzegovina 24.45 15.20 473.03 294.02
Botswana 21.46 0.48 288.68 6.43
Brazil 112.06 18.73 2,247.41 375.56
Bulgaria 80.42 48.87 789.56 479.77
Burundi 0.08 0.16 .. ..
Cambodia 4.19 2.30 34.13 18.72
Canada 218.55 6.66 2,556.01 77.93
Cape Verde 38.80 30.27 443.97 346.40
Chile 58.74 10.10 486.07 83.56
Colombia 29.56 8.36 441.06 124.72
Costa Rica 181.52 118.39 1,695.31 1,105.72
Croatia 95.89 64.40 2,284.79 1,534.41
Czech Republic 39.91 46.25 868.98 1,006.95
Dominica 36.21 26.67 1,032.01 760.00
Dominican Republic 27.11 37.58 .. ..
Ecuador 12.80 4.27 .. ..
El Salvador 27.21 53.96 520.83 1,032.67
Estonia 88.25 23.73 1,345.73 361.90
Ethiopia 0.14 0.06 .. ..
Finland 38.31 5.56 64.29 9.33
France 105.27 96.89 2,456.92 2,261.41
Gambia, The 3.04 2.90 .. ..
Georgia 37.00 19.27 211.32 110.04
Germany 112.18 228.00 836.53 1,700.24
Ghana 4.77 3.00 .. ..
Greece 80.58 60.26 3,848.25 2,877.85
Grenada 47.47 105.88 873.01 1,947.06
Guatemala 21.85 15.92 414.69 302.09
Honduras 23.38 9.38 .. ..
Hungary 55.62 52.99 831.30 791.88
Iceland 82.19 2.05 .. ..
India 7.29 19.08 67.06 175.55
Indonesia 14.44 13.22 117.89 107.91
Iran, Islamic Rep. of 29.79 9.95 2,038.07 680.42
Ireland 95.74 49.24 2,258.04 1,161.27

Table 5 (continued)
Economy
Automated teller
Per 100,000
adults
Per 1,000
sq. km.
Per 100,000
adults
Per 1,000
sq. km.
Israel 104.33 254.34 .. ..
Italy 97.81 170.82 2,091.02 3,652.04
Jamaica 22.25 38.69 708.42 1,231.95
Jordan 26.27 11.41 .. ..
Kazakhstan 52.10 2.31 170.86 7.57
Kenya 8.28 3.21 .. ..
Kuwait 53.42 62.63 1,040.14 1,219.42
Lao PDR 3.49 0.58 .. ..
Latvia 67.56 21.19 1,219.32 382.49
Lebanon 39.32 117.99 1,382.77 4,149.07
Lesotho 6.68 2.70 .. ..
Liberia 1.43 0.32 1.43 0.32
Lithuania 54.23 24.62 1,362.28 618.36
Macedonia, FYR 50.06 32.72 1,476.34 964.92
Malawi 2.65 2.16 4.44 3.61
Malaysia 53.99 31.07 1,063.09 611.81
Mauritius 39.09 187.68 763.80 3,667.49
Mexico 44.80 17.39 592.14 229.84
Mongolia 15.10 0.19 194.13 2.40
Montserrat 54.23 .. 1,111.71 ..
Morocco 18.63 9.29 89.93 44.81
Mozambique 5.09 0.79 38.31 5.94
Namibia 30.51 0.49 337.61 5.43
Nepal 1.81 2.27 .. ..
Netherlands 64.14 255.43 2,343.41 9,332.41
New Zealand 73.13 9.25 4,268.13 539.81
Norway 56.85 7.20 3,014.45 382.01
Oman 45.91 2.81 .. ..
Pakistan 4.06 5.49 48.98 66.16
Panama 40.56 13.03 .. ..
Peru 22.26 3.47 53.96 8.42
Philippines 14.25 28.37 .. ..
Poland 49.14 51.85 666.71 703.52
Portugal 206.94 203.38 .. ..
Puerto Rico 40.23 142.28 1,523.98 5,389.18
Romania 53.21 42.19 540.33 428.39
Russian Federation 76.51 5.65 293.05 21.63
Rwanda 0.46 1.05 1.67 3.81
Serbia 45.10 30.82 978.07 668.37
Sierra Leone 1.14 0.50 1.52 0.67
Singapore 49.83 2,901.31 2,091.42 121,764.90
Slovak Republic 49.34 46.78 713.06 676.03
Slovenia 101.67 88.68 1,871.85 1,632.72
South Africa 52.41 14.55 89,086.84 24,728.07
Spain 154.76 120.47 3,711.27 2,889.09
Sri Lanka 12.29 29.03 .. ..
St. Kitts and Nevis 94.61 107.69 2,328.02 2,650.00
St. Lucia 31.33 63.93 902.14 1,840.98

Table 5 (continued)
Economy
Automated teller
Per 100,000
adults
Per 1,000
sq. km.
Per 100,000
adults
Per 1,000
sq. km.
St. Vincent and the Grenadines 23.94 48.72 656.47 1,335.90
Sudan 2.03 0.21 5.60 0.59
Swaziland 18.68 7.62 81.00 33.02
Sweden 36.63 6.86 .. ..
Switzerland 93.06 150.00 1,985.35 3,200.00
Syrian Arab Republic 2.67 1.99 2.22 1.65
Taiwan, China 132.75 787.32 1,141.95 6,772.72
Tajikistan 3.98 1.21 2.11 0.64
Tanzania 3.44 0.91 16.14 4.28
Thailand 71.32 73.42 .. ..
Tunisia 17.26 8.75 121.65 61.68
Turkey 44.25 30.92 3,232.79 2,259.17
Uganda 3.29 2.69 4.53 3.71
Ukraine 71.34 49.01 187.17 128.60
United Arab Emirates 99.27 43.05 .. ..
United Kingdom 122.84 257.07 2,330.70 4,877.44
United States 175.69 46.39 .. ..
Uruguay 30.59 4.49 272.76 40.00
Uzbekistan 1.05 0.47 317.50 142.53
Venezuela, R. B. de 28.19 6.24 .. ..
Yemen, Rep. of 2.84 0.69 16.98 4.14
Zambia 6.35 0.58 13.11 1.20
Zimbabwe 7.83 1.51 33.69 6.49

Table 6
Financial inclusion: Aspects under the purview of the financial regulator
Economy
Consumer
protection
Financial
capability
Regulation of
microfinance
Promoting
savings
A = Agency is responsible
A+ = Agency is responsible and has a dedicated team or unit
Promoting SME
access to finance
Promoting access
in rural areas
Strategy document
to improve financial
inclusion
Afghanistan A A+ A A+ A+ 4
Albania A+ A A+
Algeria A+ A+
Anguilla A+ A+
Antigua and Barbuda A+ A+
Argentina A+ A+ A+ A+ A+ A+ 4
Armenia A+ A+ A+ A 4
Australia A
Austria A
Azerbaijan A+ A+ A+ A+ 4
Belarus A A A A 4
Benin A+ A+ A A+ A+ 4
Bolivia A+ A A A+
Bosnia and Herzegovina A+
Botswana A A+ A+ A A+ A+
Brazil A+ A+ A A A 4
Burkina Faso A+ A+ A A+ A+ 4
Cambodia A A+ A+ A A A
Canada A+ A+
Cape Verde A+ A A+
Chile A+ A+
China 4
Colombia A+ A+ A+ 4
Côte d'Ivoire A+ A+ A A+ A+ 4
Croatia A
Czech Republic A+
Denmark A+ A
Dominica A+ A+
Dominican Republic A+
Ecuador A+ A+ A 4
El Salvador A+ A+ A+ A
Estonia A+ A+
Ethiopia A A A+ A+ A A+ 4
Finland A+ A+
France A+ A+ A+ A+
Gambia, The A+ A+ A+ A+ A+ A+ 4
Georgia A+
Ghana A+ A+ A+ A+ A+ 4
Grenada A+ A+
Guatemala A+ A+ 4
Guinea-Bissau A+ A+ A A+ A+ 4
Honduras 4
Hungary A+ A+ A+ 4
India A A A A+ A+ 4
Indonesia A+ A+ A+ A+ A+ A+ 4
Iran, Islamic Rep. of A+ A+ A+ 4
Ireland A+
Israel A+ A+
Italy A+ A+ A
Japan A A+ A A A A
Jordan A+
Kazakhstan A+ A+ 4

Table 6 (continued)
Economy
Consumer
protection
Financial
capability
Regulation of
microfinance
Promoting
savings
Promoting SME
access to finance
Promoting access
in rural areas
Strategy document
inclusion
Kenya A+ A+ A+ A+ 4
Korea, Rep. of A+ A+ A+ A+ A+ A 4
Kuwait A A
Kyrgyz Republic A A A A A 4
Lao PDR A+ A + 4
Lesotho A+ A+ A+ A+ A+ 4
Liberia A A A A A 4
Macedonia, FYR +
Madagascar A+ A+ 4
Malawi A+ 4
Malaysia A+ A+ A+ A+ A+ A+ 4
Mali A+ A+ A A+ A+ 4
Mauritania A+ A+ A+ A+ A+ A+ 4
Mauritius A+ A+ A
Mexico A+ 4
Moldova A+
Montserrat A+ A+
Morocco A+ A+ A A 4
Mozambique A+ A+ A+ 4
Namibia A+ A+ A+ 4
Nepal A A+ A+ A A A+ 4
Netherlands + A
Niger A+ A+ A A+ A+ 4
Nigeria A+ A+ A+ A+ A+ A+ 4
Norway A
Oman + A A A A A
Pakistan A+ A+ A+ A+ A+ A+ 4
Panama A+
Papua New Guinea A+
Paraguay A
Peru A+ A+ A+ A+ A+ A+ 4
Philippines A+ A+ A+ A+ A+ A+ 4
Poland A+ A+ A A A A
Portugal A+ A+ A+ 4
Puerto Rico A+ A+ A+ A+
Russian Federation A+ A+ A+ 4
Rwanda A+ 4
Senegal A+ A+ A A+ A+ 4
Serbia A+ A+ A+ A+
Sierra Leone A+ A+ A+ A+ 4
Singapore A+
Slovenia A
Sri Lanka 4
St. Kitts and Nevis A+ A+
St. Lucia A+ A+
St. Vincent and the Grenadines A+ A
Sudan A+ A+ A+
Swaziland A A A A
Sweden A+
Switzerland A
Syrian Arab Republic A+ A+ A+ A+ A+ 4
Tajikistan A+ A A+ A+ A+ A+ 4

Table 6 (continued)
Economy
Consumer
protection
Financial
capability
Regulation of
microfinance
Promoting
savings
Promoting SME
access to finance
Promoting access
in rural areas
Strategy document
inclusion
Tanzania A+ A+ A+ A+ A+ 4
Thailand A+ A+ A+ A A+ A+ 4
Togo A+ A+ A A+ A+ 4
Tunisia A+ A+ 4
Turkey A+
Uganda A+ A A+ 4
Ukraine A A
United Kingdom + A+ 4
United States A+ A+
Uruguay A+ A+ 4
Uzbekistan A A A A A A 4
Venezuela, R. B. de A+ A+ A+ A+ 4
Vietnam A+ A+ A+ A 4
Zambia A A+ A+ A+ A+ A 4
Zimbabwe A+ A A+ A+ A+ A+ 4
Note: SME = small and medium enterprise.

Table 7
Financial inclusion: Areas of reform in 2009
Economy
Consumer
protection
Financial
capability
Limiting
multiple
borrowing
Introducing
basic
accounts
Facilitating
SME access
to finance
Enabling
microfinance
Facilitating
access to
finance in
rural areas
Enabling
branchless
banking
Revising KYC
requirements
Promoting
government
transfers Other
Afghanistan + + + +
Algeria + + + + + + + +
Anguilla +
Argentina + + + + +
Armenia + + + +
Austria + +
Azerbaijan + + + + +
Bangladesh +
Belarus +
Belgium + + +
Benin + +
Bolivia + + + + +
Bosnia and Herzegovina +
Botswana + + + +
Brazil + + +
Bulgaria + + + + + +
Burkina Faso + +
Cambodia + + +
Canada + + + +
Cape Verde + + +
Chile +
China +
Colombia + + + + + + + +
Costa Rica +
Côte d'Ivoire + +
Croatia + + + +
Czech Republic +
Dominican Republic + +
Ecuador + + + + + + + + + +
El Salvador + + + + +
Ethiopia + + + + + + + +
Finland + +
France + + + + +
Gambia, The + + + + + + + +
Ghana + + + + + +
Guatemala + +
Guinea-Bissau + +
Honduras + +
Hong Kong SAR, China +
Hungary + + + +
India + + + + + + +
Indonesia + + + + +
Iran, Islamic Rep. of + + + + + +
Ireland + +

Table 7 (continued)
Economy
Consumer
protection
Financial
capability
Limiting
multiple
borrowing
Introducing
basic
accounts
Facilitating
SME access
to finance
Enabling
microfinance
Facilitating
access to
finance in
rural areas
Enabling
branchless
banking
Revising KYC
requirements
Promoting
government
transfers Other
Israel + + +
Italy + +
Japan + +
Jordan +
Kazakhstan + + + + +
Kenya + + + +
Korea, Rep. of + + + + + +
Kuwait + + + + +
Kyrgyz Republic + + + + + +
Lao PDR + + +
Latvia + + + +
Lebanon + + + +
Lesotho + + + + + + +
Liberia + + + + + + +
Lithuania + + + +
Macedonia, FYR +
Madagascar + + + +
Malawi + + + + +
Malaysia + + + + + + + + + +
Mali + +
Mauritius +
Mexico + + + + + + +
Moldova +
Montserrat +
Morocco + + + + + +
Mozambique + + +
Namibia +
Nepal + + + + +
New Zealand + + +
Nicaragua + +
Niger + +
Nigeria + + + + + + + + + +
Oman + + + + + + +
Pakistan + + + + + + + + +
Panama + +
Papua New Guinea + + + +
Paraguay + +
Peru + + + + + +
Philippines + + + + + + + +
Portugal + + + + + +
Puerto Rico + +
Russian Federation + + + +
Rwanda + + + + + +
Senegal + +

Table 7 (continued)
Economy
Consumer
protection
Financial
capability
Limiting
multiple
borrowing
Introducing
basic
accounts
Facilitating
SME access
to finance
Enabling
microfinance
Facilitating
access to
finance in
rural areas
Enabling
branchless
banking
Revising KYC
requirements
Promoting
government
transfers Other
Serbia +
Sierra Leone + + + +
Singapore + + +
Slovak Republic + + +
Spain + +
Sri Lanka + + + + + +
St. Kitts and Nevis +
Sudan + + + + + +
Swaziland + + + + + + +
Switzerland + +
Syrian Arab Republic + + + + + + +
Taiwan, China + + + +
Tajikistan + + + + + + + +
Tanzania + +
Thailand + + + + + +
Togo + +
Turkey + +
Uganda + + + + + +
Ukraine + + +
United Kingdom + + + + + + +
United States +
Uruguay + + + + +
Uzbekistan + + + +
Venezuela, R. B. de + + + + + +
Vietnam + + + + +
Zambia + +
Zimbabwe + + + + + + + +
Note: KYC = know your customer; SME = small and medium enterprise.

Table 8
Consumer protection: Compliance monitoring and enforcement by supervisory agency
Methods to monitor compliance
Require FIs to report statistics on number of complaints
Operate call center to receive complaints
Monitor providers' advertisements, Web sites, etc.
Mystery/incognito shopping
Interviews, focus groups, and consumer research
Require providers to withdraw misleading advertisements
Impose fines and penalties
Withdraw the offending provider's license to operate
Issue warnings to FIs
Require providers to refund excess charges
Onsite inspection and investigation of FIs
Actions for enforcement
Economy
Afghanistan + + + + + +
Albania + + + + + +
Algeria + + + + +
Argentina + + + + + +
Armenia + + + + + + + +
Australia + + + + +
Austria + + + + + + + +
Azerbaijan + + + + + + + + +
Belgium + + + + + + + + +
Benin +
Bolivia + + + + +
Botswana + + + + + +
Brazil + + + + + +
Burkina Faso +
Cambodia + + + + + + +
Canada + + + + + + + + + +
Cape Verde + + +
Chile + + + + + + + + + +
Colombia + + + + + + + + +
Costa Rica + + + +
Cote d'Ivoire +
Croatia + +
Czech Republic + + + + +
Denmark + + + +
Dominican Republic + + + +
Ecuador + + + + + + +
Estonia + + + + + + + +
Ethiopia + + + +
Finland + + + + + + + +
France + + + + + + + +
Gambia, The + + +
Ghana + + + + + + +
Greece + + + + + + +
Guatemala + +
Guinea-Bissau +
Hungary + + + + + + + + + +

Table 8 (continued)
Methods to monitor compliance
Operate call center to receive complaints
Economy
India + + + + + + + + + +
Indonesia + +
Iran, Islamic Rep. of + + + + + + + + + + +
Ireland + + + + + + + + +
Israel + + + + + + +
Italy + + + + + + + +
Japan + + + + + + + +
Jordan + + + +
Kazakhstan + + + + + + + + +
Kenya + + + + + + +
Korea, Rep. of + + + + + + + + + +
Kuwait + + + + + + + + + +
Kyrgyz Republic + + + + + + +
Lao PDR + + + + +
Latvia + + + +
Lesotho + + + + + + + +
Liberia + + + + +
Lithuania + + + +
Macedonia, FYR + +
Madagascar + + + +
Malawi + +
Malaysia + + + + + + + +
Mali +
Mauritania + + + + + +
Mauritius + + + + + + +
Mexico + + + + + + + +
Moldova + + + +
Mongolia + + + +
Morocco + + + + + +
Mozambique + + + + + +
Netherlands + + + + + + + + +
Nicaragua + + + + + + +
Niger +
Nigeria + + + + + + + + + + +
Pakistan + + + + + + +
Panama + + +

Table 8 (continued)
Economy
to monitor compliance
Methods Operate call center to receive complaints
Papua New Guinea +
Paraguay + + + +
Peru + + + + + + +
Philippines + +
Poland + + + + +
Portugal + + + + + + + + + +
Puerto Rico + + + + + + + + + + +
Senegal +
Serbia + +
Sierra Leone + + + + +
Singapore + + + + + + + +
Slovak Republic + + + + +
Slovenia + + + +
South Africa + + + + + + + + + + + +
Spain + + + + + + +
Sri Lanka + + + + + + +
Swaziland + + + + +
Sweden +
Switzerland + + + + + +
Syrian Arab Republic + +
Tajikistan + + + + + +
Thailand + + + + +
Togo +
Turkey + + + + +
Uganda + + + +
Ukraine + + + +
United Kingdom + + + + + + + + + + + +
United States + + + + + + +
Uruguay + + + + + + +
Uzbekistan + + + + + + + + +
Venezuela, R.B. de + + + +
Vietnam + + + + +
Yemen, Rep. of + +
Zambia + + + + + + +
Zimbabwe + + + + + + + + +
Note: FI = financial institution.

Table 9
Consumer protection: Disclosure requirements at account opening
Notify customers in writing of pricing, terms conditions
Banks
Other regulated financial institutions
Early withdrawal penalties
Requirements related to credit products
Annual percentage rate using standard formula
Computation method (av. balance, interest)
Fees
Insurance
Recourse rights and processes
Requirements related to deposit products
Annual percentage yield and interest rate
Method of compounding
Minimum balance requirement
Fees and penalties
Unregulated financial institutions
General requirements
Plain language requirement
Local language requirement
Prescribed, standardized disclosure format
Economy
Afghanistan + + + + + + + + + + +
Albania + + + + + + + + + + + +
Algeria + + + + + + + + + + + + + +
Argentina + + + + + + + + + + + + + +
Armenia + + + + + + + + + + + + + +
Australia + +
Austria + + + + + + + + + + + +
Azerbaijan + + + + + + + + + + + + + +
Belarus + + +
Belgium + + + + + + + + + + + +
Benin + + + + +
Bolivia + + + + + + + +
Botswana + + + + + + + + +
Brazil + + + + + + + + +
Bulgaria + + + + + + + + + + + + + +
Burkina Faso + + + + +
Cambodia + +
Canada + + + + + + + + + + + + + + +
Cape Verde + + + + + + + + + + + + + +
Chile + + + + + + + + + + + +
Colombia + + + + + + + + + + + +
Costa Rica + + + + + + + +
Cote d'Ivoire + + + + +
Croatia + + + + + + + + + + + + +
Czech Republic + + + + +
Denmark + + + + + + + + + + + + +
Dominican Republic + + + + + + + + + +
Ecuador + + + + + + + + +
El Salvador + + + + + + +
Estonia + + + + + + + + + + + + +
Ethiopia + + + + + + + + +
Finland + + + + + + +
France + + + + + + + + + + + + + + +
Gambia, The + + + + + + + + +
Ghana + + + + + + + + + +
Greece + + + + + + + + + + + + +
Guatemala + + + + + +
Guinea-Bissau + + + + +
Honduras + + + + + + +
Hong Kong SAR, China + + + + + + + + + + + + +

Table 9 (continued)
Economy
Banks
Fees
Insurance
Fees and penalties
Hungary + + + + + + + + + + + + + + +
India + + + + + + + + + + + + +
Indonesia + + + + + + + + + + + + + +
Iran, Islamic Rep. of + + + + + + + + + + +
Ireland + + + + + + +
Israel + + + + + + + + +
Italy + + + + + + + + + + + + + + +
Jamaica + + + + + + + + + + +
Japan + + + + + + + + +
Jordan + + + + + + + + + +
Kazakhstan + + + + + +
Korea, Rep. of + + + + + + + + + + + + + +
Kuwait + + + + + +
Kyrgyz Republic + + + + + + + + + + + +
Lao PDR + + + + + + + +
Latvia + + + + + + + + + + + +
Lebanon + +
Liberia + + + + + + + + + +
Lithuania + + + + + + + + + + + + +
Macedonia, FYR + + + + + +
Madagascar + + + + + + +
Malaysia + + + + + + + + + + + + +
Mali + + + + +
Mauritania + + + + + + + + + + + + +
Mauritius + + + + + + + + + + + + + +
Mexico + + + + + + + + + + + +
Moldova + + + + + + + + + + + + + +
Mongolia + + + +
Morocco + + + + + + + + + + + +
Nepal + + +
Netherlands + + + + + + + + + + + + + + +
New Zealand + + + + + + + + + + + +
Nicaragua + + + + + + + + + + +
Niger + + + + +
Nigeria + + + + + + + + + + +
Norway + + + + + + +
Oman + + + + + + + + + + + + + + +
Pakistan + + + + + + + + + + + +
Panama + + + + + + + + + + + + +

Table 9 (continued)
Economy
Banks
Fees
Insurance
Fees and penalties
Papua New Guinea + + + + + + + + +
Paraguay + + + + + +
Peru + + + + + + + + + + + + +
Philippines + + + + + + + + + +
Poland + + + + + + + + + + + + + + +
Portugal + + + + + + + + + + + + + +
Puerto Rico + + + + + + + + + + + + + +
Russian Federation + + + + + + + + +
Rwanda + + + + + + + + + + + + + + +
Senegal + + + + +
Serbia + + + + + + + + + + +
Sierra Leone + + + + + + + +
Singapore + + + + + +
Slovak Republic + + + + + + + + + +
Slovenia + + + + + + + + + +
South Africa + + + + + + + +
Spain + + + + + + + + + + +
Swaziland + + + + + + + + + +
Sweden + + + + + +
Switzerland + + + + + + + + + + + +
Syrian Arab Republic + + + + + + + + +
Taiwan, China + + + + + + + + + + + + + + +
Tajikistan + + + + + + + + + + +
Thailand + + + + + + + + + + + +
Togo + + + + +
Tunisia + + + + + + + + + + +
Turkey + + + + +
Ukraine + + + + + + + + + +
United Arab Emirates + + +
United Kingdom + + + + + + + + + + + + +
United States + + + + + + + + + + + + +
Uruguay + + + + + + + + + + + + + + +
Uzbekistan + + + + + + + + + + + + +
Venezuela, R.B. de + + + + + + + + + + + + + + + +
Vietnam + + + + + + + + + + + +
Yemen, Rep. of + + + + + + + + + +
Zambia + + + + + + + + + + + + +
Zimbabwe + + + + + + + + + + +

Table 10
Consumer protection: Requirements for periodic disclosure
Economy
Statement includes information on dispute procedures
Provide periodic statements
Banks
Fees imposed
Account balance
Annual percentage yield calculation
Amount of interest earned
All account transactions during the period
Annual percentage rate
Interest charged for the period
Fees charged for the period
Minimum amount due
Date due
Outstanding balance
Afghanistan + + + + + + + +
Albania + + + + + + + + + + +
Algeria + + + + + + + + + + + + + +
Argentina + + + + + + + + + + + +
Armenia + + + + + + + + + + + + +
Austria + + +
Azerbaijan + + + + + + + + + + + +
Belarus + + + + + + + +
Belgium + + + + + + + +
Benin + + + + + + +
Bolivia + + + + + + +
Botswana +
Brazil + + + + + +
Bulgaria + + + + + + + + +
Burkina Faso + + + + + + +
Canada + + + + + + + + + + + + + +
Cape Verde + + + + + + + + + +
Chile + + + + + + + + + + + + + +
Colombia + + + + + + + + + + + + + +
Costa Rica + + + +
Côte d'Ivoire + + + + + + +
Croatia + + + + + + + + + + + + +
Czech Republic + +
Denmark + + + + + + + + + + + + + +
Ecuador + + + + + + + +
El Salvador + + + + + + + + + + + +
Estonia + + +
Ethiopia + + + + + + + + + + +
Finland + + + + + +
France + + + + + + + + + + + + +
Gambia, The + + + + + + + + + +
Ghana + + + + + + + + + + + + +
Greece + + + + + + + + + + + + + +
Guatemala + + + + + +
Guinea-Bissau + + + + + + +
Honduras + + + + + + + + + + + +

Table 10 (continued)
Economy
Provide periodic statements
Banks
Fees imposed
Account balance
Annual percentage yield calculation
Minimum amount due
Date due
Outstanding balance
Hong Kong SAR, China + + +
Hungary + + + + + + + + + + + +
India + + + + + + + + + + +
Indonesia + + + + + + +
Iran, Islamic Rep. of +
Israel + + + + + + + + + + +
Italy + + + + + + + + + + + + +
Jamaica + + + + +
Jordan + + + + + +
Kazakhstan +
Kuwait + + + + + + + + + + + + +
Kyrgyz Republic +
Lao PDR + + + + +
Lebanon + +
Lithuania + + +
Macedonia, FYR + + + + + + +
Madagascar + + + + +
Malaysia + + + + + + + + + +
Mali + + + + + + +
Mauritania + + + + + + + + + +
Mauritius + + + + + + + + + + + + + +
Mexico + + + + + + + + + + + + + + +
Moldova + + +
Mongolia + +
Morocco + + + + + + + + + +
Mozambique + +
Netherlands + +
New Zealand + + + + + + + + + + + + +
Nicaragua + + + + + + + + + + + +
Niger + + + + + + +
Nigeria + + + + + + + + + + + +
Norway + +
Pakistan + + + + +
Panama + + + + + + + + + + + +
Paraguay + + + + + + + + +
Peru + + + + + + + +

Economy
periodic statements
Banks
Provide Annual percentage yield calculation
Fees imposed
Account balance
Minimum amount due
Date due
Outstanding balance
Philippines + + + + + + +
Poland + + +
Puerto Rico + + + + + + + + + + + + + +
Rwanda + + + + + + + + + +
Senegal + + + + + + +
Serbia + + + + + + + +
Sierra Leone + + + + + + + + +
Singapore +
Slovak Republic + + +
South Africa + + + + + + +
Spain + + + + + + + + + + + + + +
Switzerland + + + + + + + + + + + + + +
Taiwan, China + + + + + + + + + + + +
Tajikistan + + + + + + + + + + + + +
Thailand + + + + + + + + +
Togo + + + + + + +
Tunisia + + + + + + + + + + +
United Arab
+
Emirates
United Kingdom + + +
United States + + + + + + + + + + + +
Uruguay + + + + + + + + + + + + + +
Uzbekistan + + + + + + + + + + + +
Venezuela, R. B. de + + + + + + + + + + + + + + +
Vietnam + + +
Yemen, Rep. of + + + + + + + + + + + +
Zimbabwe + + + + + + + + + + + + + +

Table 11
Consumer protection: Fair treatment, dispute resolution, and recourse
Economy
Provisions to restrict unfair treatment
Deceptive advertising
Unfair or high-pressure selling practices
Abusive collection practices
Unauthorized use of client data or breach of client
confidentiality
No fair treatment provisions reported
Regulated standards on FIs for
complaints resolution
Procedures and processes
Timeliness of response
Accessibility
System for recourse with a third party
Financial ombudsman
General ombudsman
Mediation service
Afghanistan + + + + +
Albania + + + + + + + +
Algeria + + + + +
Anguilla + +
Antigua and Barbuda + +
Argentina + + + + + + +
Armenia + + + + + + + +
Australia + + + + +
Austria + + + + + + +
Azerbaijan + + + + + + +
Bangladesh +
Belarus +
Belgium + + + + + + + +
Benin +
Bolivia + + + + + +
Bosnia and Herzegovina +
Botswana + + + + + +
Brazil + + + + + + + + +
Bulgaria + + + + + + + +
Burkina Faso +
Burundi + + +
Cambodia +
Canada + + + + + + +
Cape Verde + + + + + +
Chile + + + + + + + +
China +
Colombia + + + + + + +
Costa Rica + + + + + +
Côte d'Ivoire +
Croatia + + + + + + + +
Czech Republic + + + + + + +
Denmark + + + + + +
Dominica + +
Dominican Republic + + + + + + + + +
Ecuador + + + + + +
El Salvador + + + + + + +
Estonia + + + +
Ethiopia + + + + + +
Finland + + + + + +
France + + + + +
Gambia, The + + + + +
Georgia +
Germany +
Ghana + + + + + + + +
Greece + + + + + + + + +
Grenada + +
Guatemala + + + + +
Guinea-Bissau +

Economy
confidentiality
Accessibility
Financial ombudsman
General ombudsman
Mediation service
Honduras + + + + + +
Hong Kong SAR, China + + + + + +
Hungary + + + + + + +
Iceland +
India + + + + + + + +
Indonesia + + + + +
Iran, Islamic Rep. of + +
Ireland + + + + + +
Israel + + + +
Italy + + + + + + + + +
Jamaica + + + + + + +
Japan + + + + +
Jordan + + +
Kazakhstan + + + + +
Kenya + +
Korea, Rep. of + + + + + + +
Kuwait + + + + +
Kyrgyz Republic + + +
Lao PDR + + + + + +
Latvia + + + +
Lebanon +
Lesotho +
Liberia + + + +
Lithuania + + + + + +
Macedonia, FYR + +
Madagascar + + +
Malawi +
Malaysia + + + + + + + +
Mali +
Mauritania + + + + + +
Mauritius + + + + + +
Mexico + + + + + + + + +
Moldova + + + + + + + +
Mongolia + +
Montserrat + +
Morocco + + + + + +
Namibia + + +
Nepal + +
Netherlands + + + + + +
New Zealand + + + + + + +
Nicaragua + + + + + + +
Niger +
Nigeria + + + + +
Norway + + + + +
Oman + + + + + + + +
Pakistan + + + + + + + + + +
Panama + + + + + + + +

Economy
confidentiality
Accessibility
Financial ombudsman
General ombudsman
Mediation service
Papua New Guinea +
Paraguay + + + +
Peru + + + + + + + + +
Philippines + + + + + + +
Poland + + + + + + +
Puerto Rico + + + + + + +
Romania +
Russian Federation + +
Rwanda + + + + +
Senegal +
Serbia + + + + + +
Sierra Leone + + + + +
Singapore + + + + +
Slovak Republic + + + + +
Slovenia + + + + +
South Africa + + + + + + + + + +
Spain + + + + + + +
Sri Lanka + + +
St. Kitts and Nevis + +
St. Lucia + +
St. Vincent and the Grenadines + +
Sudan +
Swaziland + + + + +
Sweden + + + + + + +
Switzerland + + + + +
Syrian Arab Republic +
Taiwan, China + + + + + + + + + +
Tajikistan + + + +
Tanzania +
Thailand + + + + + + + +
Togo +
Tunisia + + + + + + +
Turkey +
Uganda + + + +
Ukraine +
United Arab Emirates +
United Kingdom + + + + + + + +
United States + + + + + +
Uruguay + + + + + + +
Uzbekistan + + + + + + +
Venezuela, R. B. de + + + + + + + + +
Vietnam + + + +
Yemen, Rep. of + + + + +
Zambia + + + + + + +
Zimbabwe + + + + + + + +
Note: FI = financial institution.

Table 12
Small and medium enterprise finance
Agency monitors the level of lending to SMEs SME definition SME lending
Economy
Yes,
regularly
Yes,
irregularly No
No, but
another
agency does
Number of
employees
(max.) Sales (max. in USD)
Loan size (max. in
USD)
Value of loans (%
of GDP)
Afghanistan + 100 995,355.00 .. 2.25
Albania + + 249 2,632,185.00 .. 11.30
Algeria + .. .. .. ..
Anguilla + .. .. .. ..
Antigua and Barbuda + .. .. .. ..
Argentina + .. 23,900,000.00 .. 1.28
Armenia + 100 .. .. 4.36
Australia + .. .. 1,559,833.00 15.33
Austria + .. .. .. ..
Azerbaijan + + 5 124,411.60 311,029.10 ..
Bangladesh + 150 .. .. 17.35
Belarus + .. .. .. ..
Belgium + + .. .. .. 21.50
Benin + .. .. .. ..
Bosnia and Herzegovina + .. .. .. ..
Botswana + + 100 698,301.00 .. 0.42
Brazil + .. .. .. 3.77
Bulgaria + .. .. .. ..
Burkina Faso + .. .. .. ..
Cambodia + .. .. .. ..
Canada + 499 43,700,000.00 4,374,069.00 ..
Cape Verde + 51 1,889,713.00 .. 0.60
Chile + + .. .. .. ..
China .. .. .. 48.65
Colombia + + 200 .. .. ..
Costa Rica + + .. 540,000.00 .. 4.29
Côte d'Ivoire + .. .. .. ..
Croatia + 250 .. .. ..
Czech Republic + .. .. .. ..
Denmark + .. .. .. ..
Dominica + .. .. .. ..
Dominican Republic + + .. .. 13,878.58 ..
Ecuador + .. .. .. 2.87
El Salvador + 50 1,000,000.00 .. 5.77
Estonia + 50 4,340,278.00 1,388,889.00 30.98
Ethiopia + .. .. .. ..
Finland + .. .. .. ..
France + .. 69,400,000.00 .. 10.64
Gambia, The + .. .. .. ..
Georgia + .. .. .. 5.54
Germany + 250 73,500,000.00 .. ..
Ghana + 30 2,129,472.00 .. ..
Greece + 250 69,400,000.00 .. ..
Grenada + .. .. .. ..
Guatemala + .. .. 19,604.11 0.51
Guinea-Bissau + .. .. .. ..
Honduras + + .. .. .. ..
Hong Kong SAR, China 100 .. .. 0.77

Economy
Yes,
regularly
Yes,
irregularly No
No, but
another
agency does
Number of
employees
Loan size (max. in
USD)
Value of loans (%
of GDP)
Hungary + 250 69,400,000.00 .. 11.89
India + .. .. .. 4.34
Indonesia + + .. 4,812,349.00 .. 0.67
Iran, Islamic Rep. of + 50 .. .. 5.94
Ireland 249 .. .. ..
Israel + .. .. .. ..
Italy + 20 .. .. 11.42
Jamaica + .. .. .. ..
Japan + .. .. .. 35.90
Jordan + .. .. .. 10.18
Kazakhstan + 250 .. .. 6.42
Kenya + .. .. .. ..
Korea, Rep. of + 1,000 117,000,000.00 .. 37.39
Kuwait .. .. 868,702.80 ..
Lao PDR 99 117,425.50 .. ..
Latvia + 250 .. .. 42.23
Lebanon + + .. 5,000,000.00 .. ..
Liberia + 16 262,500.00 155,000.00 2.34
Lithuania + + 249 55,600,000.00 .. ..
Macedonia, FYR + .. .. .. ..
Madagascar + .. 2,555,968.00 .. ..
Malawi + .. .. .. ..
Malaysia + 150 7,093,199.00 .. 17.43
Mali + .. .. .. ..
Mauritania + .. .. .. ..
Mauritius + .. .. .. ..
Mexico + 250 18,500,000.00 .. ..
Moldova + 249 4,500,622.00 .. ..
Mongolia + 199 1,043,264.00 .. 6.39
Montserrat + .. .. .. ..
Morocco + .. 6,205,707.00 124,114.10 10.39
Mozambique + .. .. .. ..
Namibia + + .. .. .. ..
Netherlands + .. 73,500,000.00 .. 53.86
New Zealand + 19 .. .. ..
Nicaragua + + .. .. .. ..
Niger + .. .. .. ..
Nigeria + 250 .. .. ..
Norway + .. .. .. ..
Oman 99 5,201,561.00 .. ..
Pakistan + 250 .. .. 2.54
Panama + .. 2,500,000.00 .. 3.25
Peru + .. .. 9,961.79 1.09
Philippines + .. .. .. ..
Poland + 250 .. .. 7.81
Portugal + 249 .. .. 52.00
Puerto Rico + .. .. .. ..
Russian Federation + 250 31,500,000.00 .. 5.23

Economy
Yes,
regularly
Yes,
irregularly No
No, but
another
agency does
Number of
employees
Loan size (max. in
USD)
Value of loans (%
of GDP)
Rwanda + .. .. .. ..
Senegal + .. .. .. ..
Serbia + 250 13,900,000.00 .. ..
Sierra Leone + .. .. .. ..
Singapore + .. .. .. 14.96
Slovak Republic + .. .. .. ..
Slovenia + 250 48,600,000.00 .. ..
South Africa + .. 47,200,000.00 885,094.30 10.71
Spain + 250 13,900,000.00 .. ..
St. Kitts and Nevis + .. .. .. ..
St. Lucia + .. .. .. ..
St. Vincent and the Grenadines + .. .. .. ..
Sudan + 10 .. .. ..
Switzerland + + .. .. .. ..
Syrian Arab Republic + .. .. 107,048.00 ..
Taiwan, China + + 200 2,420,099.00 .. 24.81
Tajikistan + .. .. 12,069.40 0.36
Thailand + 200 .. .. 30.67
Togo + .. .. .. ..
Tunisia + 300 .. .. ..
Turkey + + .. .. .. 7.38
Uganda + .. .. .. ..
Ukraine 50 8,984,449.00 .. ..
United Arab Emirates + .. .. .. ..
United Kingdom + 250 35,500,000.00 .. ..
United States + .. .. 1,000,000.00 4.93
Uruguay + 100 3,323,292.00 .. 6.86
Uzbekistan + 100 .. .. 4.39
Venezuela, R. B. de + + .. .. .. ..
Yemen, Rep. of + .. .. .. ..
Zambia + + 50 49,543.12 .. ..
Zimbabwe + + 20 .. 50,000.00 ..

Table 13
Consumer protection legislation
G E F O
General consumer protection
law without explicit reference
Consumer protection law with
explicit reference to financial
services
Consumer protection regula-tions
within the framework of
financial sector legislation
Other types of consumer
protection regulation
Afghanistan X X X 4
O There is no specific law, but regulations exist that can be enforced in cases of violation of laws or regulations.
Albania X 4 4 X
E Law No. 9902 on Consumers' Protection (2008). The law contains provisions on consumer credit.
F Regulation No. 05 on the Consumer Credit and Mortgage Credit for Households (2009); Regulation No. 59 on the Transparency of Banking and Financial Products and Services (2008)
Algeria 4 4 4 X
G Name of law not provided.
E Law N°09–03 of 25 February 2009 on Consumer Protection (2009)
F Regulation N°09–03 of 26 May 2009 Establishing General Rules on Banking Conditions Applicable to Bank Operations (2009)
Anguilla X X X X
Antigua and
X X X X
Barbuda
Argentina X 4 4 4
E Laws 24240 and 26361 on Consumer Protection (1993 and 2008); Law 25065 on Credit Cards (1999)
F Resolution 9, Consumer Protection (2004)
O Transparency Regime consisting of Communiqués “A” 4184 and “A” 4191 on Interest Rates in Credit Operations and Relations Between Financial Entities and their Clients (2004)
Armenia 4 4 4 X
G Consumer Rights Protection Law (2001)
E Law on Attraction of Bank Deposits (2008); Law on Consumer Lending (2008)
F Regulation 8/01 Calculation of Annual Percentage Rate: Explanations and Examples (2009); Regulation 8/02 Calculation of Annual Percentage Yield of Deposits (2009); Regulation 8/03
Information Disclosure by Banks, Credit Organizations, Insurance Companies, Insurance Brokers, Investment Companies, Central Depository and Payment Service Organizations Realizing
Remittance (Money) Transfer (2009); Regulation 8/04 Minimal Conditions and Principles of Internal Legal Acts Administering Process of Examination of Customers’ Appeals (2009);
Regulation 8/05 Communication Between Bank and Depositor, Creditor and Consumer: Methods, Conditions and Minimal Requirements (2009)
Australia X 4 4 4
O ASIC (Australian Securities and Investments Commission) administers the regulatory system for consumer protection for deposit–taking activities (i.e., transactions or savings
accounts); general insurance; life insurance; superannuation; retirement savings accounts; managed investments; securities (i.e., shares and debentures); derivatives (i.e., futures
contracts); foreign exchange contracts; and credit.
Austria 4 X 4 X
G Consumer Protection Act (1979)
F Banking Act (1993); Insurance Act (1958); Investment Funds Act (1993); Securities Supervision Act (2007)
Azerbaijan 4 4 4 X
G Law on Protection of Consumers᾽ Rights (1995); Law on Banks (1992); Law on Deposit Insurance (2006); Law on Advertising (1997)
E Name of law not provided (2000)
F Corporate Governance Standards; Regulation on Credit Allocations in Banks (2004)
Bangladesh X X X X
Belarus X X X X
Belgium 4 4 4 4
G Law on Business Practices and on Consumer Protection (1991)
E Certain provisions in the Law on Business Practices and on Consumer Protection (1991, 2010) are particular to financial services.
F Law on Payment Services (2010)
O Law on Consumer Credit (1991); Law on Loans and Credit Facilities Secured by a Mortgage (1992)
Benin X 4 X 4
E Law on the Definition and Repression of Usury (1997)
O Notices to Banks and Financial Institutions on Banking Conditions (1992)

G E F O
services
Bolivia 4 X 4 X
G Constitution (2009)
F Rules for Customer Service and Users (of Financial Services) (2010)
Bosnia and
Herzegovina X 4 X X
E Consumer Protection Law of Bosnia Herzegovina (2006)
Botswana 4 4 4 X
G Consumer Protection Act (1998). The Consumer Protection Act is under the Ministry of Trade and Industry.
E Banking Act, Chapter 46:04 (1995). The Banking Act has selected sections which cover consumer protection issues.
F Banking Act, Chapter 46:04 (1995)
Brazil 4 4 4 X
G Law 8.078, Consumer Defense Code (1990). Law 8.078 is a general consumer protection law with an explicit reference to financial services. However, it does not have specific instru-ments
for handling financial services.
E Law 8.078, Consumer Defense Code (1990). Concerning financial services, all financial institutions must also comply with National Monetary Council (CMN) and Central Bank of Brazil
regulations on (i) transparency of information in credit contracts, which must include all interest and costs charged in the normal course of the operation, the monthly and annual
equivalent effective interest rate (Circular 2,905/1999, as modified by Circular 2,936/1999); and (ii) portability of client information (Resolution 2.835/2001), in addition to those
Resolutions listed in Section F.
F Resolution 3.401, Portability of Credit (2006); Resolution 3.402, Portability Of Wages, Salaries, Pensions and Similar Earnings (2006); Resolution 3.477, Mandatory Ombudsman in Financial
Institutions (2007); Resolutions 3.516 and 3.518 and Circular 3.371, Charging of Service Fees (2007); Resolution 3.517, Obligation to Inform Ahead of Extending Credit the Total Cost of the
Operation Expressed in the Form of an Annual Percentage Rate, as well as Taxes and Fees (2007); Resolution 3.694, Establishing that Contracts Should Be Clear and Disclose All Information
Necessary for the Consumer's Decision (2009)
Bulgaria 4 4 4 4
G Law on Protection of the Consumers (2006)
E Law on Consumer Credit (2010)
F Law on Credit Institutions (2006); Law on Public Offering of Securities (1999)
O Law on Payment Services and Payment Systems (2009); Law on Distance Provision of Financial Services (2007); Law on Bank Deposit Guarantee (1998); Law on Markets in Financial Instru-ments
(2007)
Burkina Faso X 4 X 4
Burundi X X 4 4
F Banking Law N°1/017 (2003); Decree N°100/203 (2006). These are regulations that apply to the supervision of the financial sector. There is no specific consumer protection law.
O Business Code (1996)
Cambodia X X 4 X
F Law on Banking and Financial Institutions (1999)
Canada 4 X 4 X
G The Government of Canada’s Budget 2009 and Budget 2010 included measures related to consumer protection. Further information on these measures can be found at: www.
budget.gc.ca/2010/home–accueil–eng.html, Chapter 3.
F The Financial Consumer Agency of Canada Act (2001). Other provisions can be found within financial institutions' statutes.
Cape Verde X X X X
Chile 4 X X 4
G Law No. 19.496, Rules on Protection of Consumer Rights (1997); Law No. 19.628, Protection of Privacy (1999)
O DFL N°3, General Banking Act (1997). The General Banking Act gives broad power to the Superintendency of Banks, including interpreting the law and enforcing it by establishing
norms of banking consumer protection. In the updated norms issued by this superindentency, the following issues are addressed in the Updated Compilation of Rules (RAN):
Chapters 1–3 on classification and solvency; 18–14 on transparency of information to the public; 19–9 on information to the public; and 7–1 on interest and adjustments.

G E F O
services
China X X X X
Colombia X 4 4 4
E Law 1328, Title I: Financial Consumer Protection (2010). Financial consumer protection in Colombia is a constitutional matter, covered by Articles 333, 335, and 78. Before June 2009,
general rules on financial matters were addressed in the Financial System Organic Statute, Articles 72, 97, 98, 99, and 100. Law 1328, Title I, which came into effect July 2010, explicitly
refers to financial consumer protection.
F Original Statute of the Financial System (1993); Law 1328, Title I: Financial Consumer Protection (2010)
O Basic Legal Circular, Title I, Chapter VI: Rules on Competition and Consumer Protection (1996 and subsequent updates)
Costa Rica X 4 X 4
E Law of Promotion of Competition and Effective Consumer Protection (1995). The Law of Promotion of Competition and Effective Consumer Protection specifically establishes regulations
for credit card issuers concerning information on users of its services. Additionally, there is regulation on the disclosure of information and the advertisement of financial products
whose compliance is monitored by the General Superintendent of Financial Institutions.
O Regulation of the Law of Promotion of Competition and Effective Consumer Protection (1996)
Côte d'Ivoire X 4 X 4
Croatia 4 X 4 X
G Customer Protection Act (2007)
F Credit Institutions Act (2009); Act on Leasing Insurance (2007); Customer Credit Act (2007)
Czech
Republic 4 4 4 X
G Act No. 634/1992 Coll., Consumer Protection Act (1992)
E Act No. 321/2001 Coll., Conditions for Negotiating a Consumer Loan (2001)
F Act No. 256/2004 Coll., Capital Market Undertakings Act (2004) (contains provisions regulating information disclosure to consumers); Act No. 189/2004 Coll., On Collective Investment
Schemes (2004); Act No. 37/2004 Coll., On Insurance Contract (2004); Act No. 38/2004 Coll., On Insurance Intermediaries and Loss Adjusters (2004); Act No. 284/2009 Coll., Payment System
Act (2009); Act No. 40/1964 Coll., Civil Code (1964, amended by 2002/65/EC); Act No. 229/2002 on the Financial Arbitrator (2002)
Denmark X X 4 4
F Good Business Practice Act (2009)
O Executive Order on Investor Protection in Connection with Securities Trading (2009)
Dominica X X X X
Dominican
Republic 4 4 4 4
G General Law on Consumer Protection (2005)
E Monetary and Financial Law, Article 52 (2002)
F Regulation for Protection of Users of Financial Services (2006)
O Law 288–05, Regulation of Credit Information Bureaus and Protection of Client Information, including Norms for Electronic Payments (2005)
Ecuador 4 4 4 X
G Original Law on Consumer Protection (2000)
E Law on Regulation of Maximum Effective Cost of Credit (2007)
F Banking Board Resolution No. 306 (2006)
El Salvador X 4 4 X
E Law of Consumer Protection (1996). The regulation includes aspects of financial services but also of goods and services in general.
F Regulation of the Law of Consumer Protection (1996)
Estonia 4 X X X
G The Consumer Protection Act (2004); The Law of Obligations Act (2002); The Securities Market Act (2002); Credit Institutions Act (1999); Insurance Activities Act (2005); Investment Funds
Act (2004); Funded Pensions Act (2004); Payment Service Providers and Electronic Money Institutions Act (2010). Different rules aimed at protecting financial consumers can be found
in different legal acts, mainly from the Securities Market Act and the Law of Obligations Act. The primary approach has been service–centered, where the rules related to financial
services can be found from the specific law of the financial service.

G E F O
services
Ethiopia X X X X
O A complaint handling framework that will enable the amicable settlement of complaints from customers of banks, microfinance institutions, and insurance companies is being
implemented.
Finland X 4 4 4
E Consumer Protection Act (1978)
F Act on Credit Institutions (2007)
O Act on Guarantees and Third–Party Pledges (1999). Several acts include provisions on consumer protection matters. The most important acts are mentioned here. Both the Finnish
Financial Supervisory Authority (FIN–FSA), as well as the Finnish Consumer Agency have published guidelines covering different subjects on financial services.
France 4 4 4 4
G Consumer Code (2010)
E Consumer Code (2010)
F Ordinance of 21 January 2010 on the creation of the Prudential Supervisory Authority (2010)
O Orders from the Ministry of Economy and Finance that are not part of the Consumer Code also specify rules for informing customers and the general public on the terms and pricing
applicable to the management of a deposit account or a payment account, on the manner of relations between payment service providers and their clients in terms of disclosure
requirements to users of payment services, on identifying key provisions to be included in agreements on deposit accounts and contracts on payment services, and on the condi-tions
of remuneration from funds received by credit institutions.
Gambia, The 4 4 4 X
G Consumer Protection and Competition Act (2009)
E Banking Act (2009)
F Banking Act (2009)
Georgia X X X X
Germany X X X X
Ghana X X X X
O No explicit laws are in place but the Banking Act (2004) vests Bank of Ghana with the responsibility for dealing with ''unlawful and improper practices'' by banks.
Greece 4 4 4 X
G Law 2251 on the Protection of the Consumer (1994)
E Law 2251 on the Protection of the Consumer (1994)
F Bank of Greece Governors Act 2501 (2002). The Bank of Greece Governors Act 2501/2002 lays out credit institutions' disclosure requirements to retail customers with respect to the
terms and conditions governing banking transactions.
Grenada X X X X
Guatemala 4 X X 4
G Decree No. 006: Consumer Protection Act (2003)
O Law on Access to Public Information (2008)
Guinea-Bissau X 4 X 4
Honduras X 4 X X
E Rules to Strengthen Transparency, Financial Literacy and Protection of the Financial Consumer in Regulated Institutions (2009)
Hong Kong
SAR, China X X X 4
O Code of Banking Practice (1997). While the Hong Kong Monetary Authority (HKMA) has a general duty to “provide a measure of protection to depositors” under the Banking Ordi-nance
(BO), there is no explicit mandate with respect to consumer protection. However, HKMA, as a banking regulator, does have an interest in encouraging standards of good
banking practice whereby authorized institutions (AIs) act fairly and reasonably in relation to their customers. The good banking practices to promote a fair and transparent rela-tionship
between AIs and their customers are currently embodied in the Code of Banking Practice (the Code). The Code is a nonstatutory code issued on a voluntary basis jointly by
the industry associations and endorsed by HKMA. The Code sets out the minimum standards that AIs should follow in their dealings with personal customers. HKMA monitors the
AIs’ compliance with the Code.

G E F O
services
Hungary X X 4 X
F Act CXXXV on the Hungarian Financial Supervisory Authority (2007). There are specific consumer protection matters in the procedures, laws, and government decrees of the Hungar-ian
Financial Supervisory Authority.
Iceland X X X X
India 4 4 X 4
O Banking Ombudsman Scheme (2006)
Indonesia 4 X 4 X
F Bank Indonesia Regulation No.7/6/PBI/2005, Transparency in Bank Product Information and Use of Customer Personal Data (2005); No.7/7/PBI/2005, Resolution of Customer Complaints
(2005)
Iran, Islamic
Rep. of 4 X 4 X
G Consumer Protection Law (2009). The Consumer Protection Law is a general law that covers many areas, including banks.
F Banking Law (1983). The Banking Law includes a clause referring to consumer protection.
Ireland X 4 4 X
E The following Web site contains a list of legislation relevant to the role of the Central Bank of Ireland in relation to the protection of consumers: www.financialregulator.ie/processes/
consumerprotection/legislation.
F Consumer Protection Code (2006); Code of Conduct on Mortgage Arrears (2009); Code of Conduct for Business Lending to SMEs (2009)
Israel 4 4 4 X
G Banking (Service to Customer) Law, 5741–1981 (1981); Banking Rules (Customer Service), Proper Disclosure and Presentation of Documents (1992); Banking Rules (Customer Service),
Advertisements Geared to Minors (1995); Banking Rules, Proper Disclosure via Electronic Means; Banking Rules, Bank Accounts; Banking Rules, Form of General Terms for Managing an Ac-count;
Banking Rules, Unreasonable Refusal to Open an Account; Regulation 402, The Business Day in Banking Corporations; Regulation 417, Activity of a Banking Corporation in a Closed
System; Regulation 419, Retention of Documents; Regulation 403, Benefits to Customers; Regulation 404, Benefits to Customers' Employees; Banking Ordinance, Joint Account and Joint
Safe-deposit Boxes; Regulation 434, Joint Accounts Survivors Clause; Regulation 416, Minors' Accounts; Regulation 406, Banking Services for New Immigrants; Regulation 435, Telephone
Instructions; Regulation 407, Investing on a Customer's Account without his Explicit Agreement; Regulation 325, Management of Credit Facilities in Current Accounts; Regulation 432,
Transferring Activity and Closing a Customer's Account
E Payment Services: Regulations on Banking (1992); Credit Cards Law, 5746–1986 (1986); Regulation 470 on Credit Cards; Regulation 439, Debits by Authorization
F Loans for Dwellings Law (1992); Regulation 451, Procedures for Giving Dwelling Loans; Regulation 452, Loan Management Procedures; Banking Ordinance, Section 13; Banking Order (fee
for early repayment of mortgages) (2002); Regulation 454, Early Repayment Fee on a Non-dwelling Loan; Execution Law, Utilizing the Mortgage and Protecting the Apartment (1967);
Execution Law, Amendment 29, Amendment of Section 38 and Transitory Regulation (2009); Regulation 409, Charging Customers for Legal Fees; Submitting Information to the Debtors;
Clarification with Regard to Collecting Debts via External Lawyers; Law of Guarantees (1967); Regulation 453, Third-Party Guarantees for a Banking Corporation; Guarantees for Homebuy-ers;
The Sales (Assurance of Homebuyers’ Investments) Act, 5735–1974; Regulation 326, Close-end Project Finance, Bank Charges and Interest Rate; The Banking Rules (Customer Service)
(Bank Charges), 5768–2008 (2008); Banking Regulations (1990); Operating Days, Retrieval of Data by Customers and ATMs; Regulation 441, Retrieval of Data by Customers; Regulation
442, Cash Withdrawals from ATMs; Dormant Accounts; Banking Law, Sections 1 and 13B; Banking Order (2000); Investing Dormant Deposits; Regulation 413, Losing Contact with Renters
of Safe-deposit Boxes; Checks without Cover Law, 5741–1981 (1981); Law on Anti-Money Laundering (AML) (2000); Prohibition on Money Laundering (The Banking Corporations' Require-ment
regarding Identification, Reporting, and Record-Keeping for the Prevention of Money Laundering and the Financing of Terrorism) Order, 5761–2001 (2001); Obeying the Transitional
AML Regulations; Proclamation on the Prohibited Association; Clarifications and Interpretations on Anti-Money Laundering and the Combating the Financing of Terrorism (AML-CFT); Law
on CFT (2005); Regulations on CFT (proclamation on the organization on foreign terror or on an activator of foreign terror) (2008); Regulations on CFT (permit to do purchasing activities)
(2006)
Italy 4 4 4 X
G Consumer Code (2005)
E Legislative Decree No. 385/1993 (Consolidated Banking), Title VI, Disclosure of Terms and Conditions of Contract (1993); Consumer Code, Part III, Title III, Chapter I, Section IV–a, Distance
Marketing of Consumer Financial Services (2005); Legislative Decree No. 11/2010, Transposition of the Payment Services Directive (2010)
F Provisions on the Transparency of Banking and Financial Operations and Services (2010)
Jamaica 4 4 4 X
G Consumer Protection Act (2005); Fair Competition Act (1993)
E Credit Reporting Act (2010). Some consumer protection issues will be addressed under the new Credit Reporting Act. However, consumer protection is generally dealt with under the
Consumer Protection Act and the Fair Competition Act, which are respectively administered by the Consumer Affairs Commission and the Fair Trading Commission.
F Name of law not provided.

G E F O
services
Japan 4 4 4 X
G Consumer Contract Act (2000); Act on Specified Commercial Transactions (1976)
E Act on Sales of Financial Products (2000)
F Banking Act (1981); Money Lending Business Act (1983)
Jordan X X 4 X
F Banking Law (2000)
Kazakhstan X X 4 X
Kenya X X 4 X
F Banking Act (1997). The Banking Act has consumer protection provisions with respect to bank charges, disclosures, credit reference bureaus and interest on nonperforming loans.
Korea, Rep. of 4 X X X
Kuwait 4 4 4 X
G Name of law not provided. Financial services have to be approved by the Central Bank of Kuwait.
E Name of law not provided.
Kyrgyz
Republic 4 X 4 4
G Law 10.12.1997 on Consumer Protection (1997)
O Law 10.12.1997 on Consumer Protection (1997)
Lao PDR X X 4 X
F Commercial Bank Laws and Depositor Protection Fund (2000)
Latvia 4 X 4 X
G Consumer Rights Protection Law (1999)
F Consumer Credit Regulations (2008)
Lebanon 4 X X X
G Consumer Protection Law (2004). The regulations for consumer protection are under the Directorate General for Consumer Protection of the Lebanese Ministry of Economy and
Trade.
Lesotho X X X 4
O Financial Institutions Act (1999); Insurance Act (1976). The laws relating to banking and insurance consumer protection are indirect and fall under the Financial Institutions Act and
Insurance Act, which requires transparency from practitioners in all its dealings and activities.
Liberia X X X 4
O Central Bank of Liberia Act (1999); New Financial Institutions Act (1999). There are no specific laws or regulations on consumer protection. However, financial consumers are protected
under various provisions of the Central Bank of Liberia Act, New Financial Institutions Act as well as various regulations, guidelines and directives.
Lithuania 4 4 4 4
G Law on Consumer Protection (1994)
E Law on Payments (2003)
F Civil Code (2001)
O Law on Consumer Credit (2010)
Macedonia,
FYR 4 X X 4
O Law on Consumer Protection in Consumer Credit Contracts (2007)

G E F O
services
Madagascar X X 4 X
G A draft law on consumer protection is ready to be adopted by Parliament.
F Law No. 95–030 of February 22, 1996 on the Activity and Supervision of Credit Institutions (1996); Law No. 2005–016 of September 29, 2005 on the Activity and Supervision of Microfinance
Institutions (2005)
Malawi 4 X X X
G Consumer Protection Law (2003)
F The proposed Financial Services Act contains consumer protection provisions with explicit references to financial services.
Malaysia 4 X X 4
O Bank Negara Malaysia has issued a number of market conduct guidelines in 2005.
Mali X 4 X 4
Mauritania 4 4 4 X
G Instr. n°04/GR/2008 (2008)
Mauritius 4 X X X
G Consumer Protection Act (1991); Competition Act (2007)
Mexico X 4 X X
E Law on Protection and Defense of Financial Services Users (1999)
Moldova 4 4 4 X
G Law on Consumer Protection No.105–XV of March 13, 2003 (2003)
F Regulation on Publishing Information on Financial Activity by Licensed Banks of the Republic of Moldova (2000)
Mongolia 4 X 4 X
G Law of Mongolia on Consumer Protection (2003)
F Banking Law (1996); Law on Deposits, Loans and Transactions (1995)
Montserrat X X X X
Morocco X X 4 4
E Bill No. 27–00 enacting consumer protection measures is currently before Parliament.
F Banking Law (Chapter II, Section VI) (2006)
O Law on Fair Pricing and Competition (2006)
Mozambique 4 X 4 X
F Law 15/99—Law of Credit Institutions and Financial Companies (1999), amended by By-Law 9/04 (2004); Notice No. 5/GBM/2009 (2009).
Namibia 4 X X X
Nepal 4 X X X

G E F O
services
Netherlands 4 4 X X
G Dutch civil law (i.e., Dutch Civil Code); Act for the Enforcement of Consumer Protection (2007)
E Financial Services Act (2006)
New Zealand 4 4 4 X
G Fair Trading Act (1986)
E Securities Act (1978); Securities Markets Act (1988); Unit Trusts Act (1960); Superannuation Schemes Act (1989); Credit Contracts and Consumer Finance Act (2003)
F Securities Regulations; Financial Service Providers (Registration and Dispute Resolution) Act (2008); Financial Advisers Act (2008). The Financial Service Providers Act and Financial Advis-ers
Act provide for the registration of all financial service providers, consumer access to dispute resolution schemes, and authorization of financial advisers, conduct rules, and
disclosure of information.
Nicaragua 4 4 X 4
G Law No. 182, Law on Consumer Protection (1994)
E Draft Law on the Protection of the Rights of Consumer Users (2006)
O Regulation of Law No. 182 (1999)
Niger X 4 X 4
Nigeria X 4 X X
Norway 4 4 4 X
G Marketing Control Act (2009); Personal Data Act (2001)
E Financial Contracts Act (1999)
F Loan Contract Regulation (2000)
Oman 4 X X 4
O Banking Law of the Sultanate of Oman (1974). Under the Banking Law, the Central Bank is required to take up customer grievances addressed to it with the concerned licensed
institutions for amicable resolution.
Pakistan X 4 4 4
E Banking Companies Ordinance, Section 82A–G (1962)
F State Bank of Pakistan Act (1956); Microfinance Institutions Ordinance (2001); State Bank of Pakistan regulations
O BPD Circular No. 30 of 2005 Basic Banking Account (2005); BPRD Circular No. 13 of 2008 Fair Debt Collection Guidelines (2008); BPRD Circular No. 38 of 1997 Collection of Utility Bills (1997);
Circular Letter No. 25 of 2009 (2009); BPRD Circular No. 11 of 2009 Pension Disbursement through Banks (2009); BPD Circular No. 23 of 2003 Service Charges on PLS Deposits (2003); BPD
Circular No. 12 of 2006 Suo–Moto (2006); Case No. 4 /2006—Proper Arrangements in Commercial Banks for Depositing Utility Bills (2006); Service Charges PLS Deposits BPD of 2003 (2003);
BSD Circular Letter No. 17 of 2000 (2000). The State Bank of Pakistan is also working on a draft Consumer Protection Law.
Panama 4 4 4 4
G Law No. 45, establishing Norms on Consumer Protection and Fair Competition (2007)
E Banking Law, Executive Decree No. 52 (2008), which adopts the text of Decree Law 9 (1998), as amended by Decree Law 2 (2008)
F Agreement No. 2, Procedures for Dealing with Complaints to the Superintendant (2008)
O Law No. 81, Protection of the Rights of Users of Credit Cards and Other Funding Cards (2009)
Papua New
Guinea X X X X
Paraguay 4 X X 4
G Law No. 1-1334 on Consumer Protection (1998)
O Information Transparency of Law No. 861/96, General Banking, Financial and Other Credit Institutions, Article 106 (1996). The law provides some measure of protection to customers of
financial institutions.

G E F O
services
Peru 4 4 4 X
G Law of the System of Consumer Protection approved by Supreme Decree No. 006–2009–PCM (2009). Since 2000, there have been rules enacted on the issue of consumer protection.
However, these have been updated over time. Currently, the existing rule is the consolidated text of the law named here. It is important to note that the competent authority in
this area is the Institute of the Defense of Competition and Intellectual Property (INDECOPI).
E Complementary Law No. 28587 on Financial Consumer Protection (2005). The aforementioned Supreme Decree No. 006–2009–PCM provides guidelines on the use of financial services
or products, in addition to Complementary Law No. 28587.
F Information Transparency Regulation and regulations applicable to engagement with users of the financial system, approved through Resolution No. 1765–2005 SBS (2005)
O In 2009, work began with the aim of developing a Consumer Code with rules that would provide greater protection to consumers.
Philippines 4 4 4 4
G Consumer Act of the Philippines (1992)
E Republic Act No. 1405 – Law on Secrecy of Deposits (1955), amended by Presidential Decree No. 1792 (1981) and Republic Act No. 7653 – New Central Bank Act (1991); Republic Act No.
6426 – Foreign Currency Deposit Act of the Philippines (1974), amended by Presidential Decree No. 1035 (1976) and Presidential Decree No. 1246 (1977); Republic Act No. 3765 – Truth
in Lending Act (1963); Republic Act No. 8484 – Access Devices Regulation Act (1998); Presidential Decree No. 957, Section 18 – The Subdivision Condominium Buyers’ Protective Decree;
Republic Act No. 7279 – Urban Development Housing Act (1992); Republic Act No. 6977 – Magna Carta for Small Medium Enterprises (1991), amended by Republic Act No. 8289 (1997);
Republic Act No. 9178 – Barangay Micro Business Enterprises Act (2002); Republic Act No. 8435 – Agriculture Fisheries Modernization Act (1997); Republic Act No. 8792 – E-Commerce
Law (2000); Batas Pambansa Blg. 344 – Law for the Disabled (1982); Republic Act No. 9510 – Credit Information System (2008)
F Revised Rules Regulations implementing Republic Act No. 9160 – The Anti-Money Laundering Act (2001), amended by Republic Act No. 9194 (2003); General Banking Law (2000); BSP
Manual of Regulations for Banks (MORB); BSP Manual of Regulations for Non-Banks Financial Institutions (MORNBFI)
O BSP Manual of Regulations on Disclosure; Circular Letter–2009–038 on Consumer Protection against Unfair Collection Practices (2009); Circular Letter–2009–029 on Consumer Bank
Protection Complaints Handling Mechanism on Matters Related to Bank Security Programs Use of Electronic Banking Facilities (2009); Circular Letter–2009–006 on Remittance Scam
Involving the Use of Credit Cards (2009); Various advisories on BSP's Web site and in newspapers.
Poland 4 4 4 4
G Act on Competition and Consumer Protection (2007); Act on Combating Unfair Commercial Practices (2007)
E Act on the Protection of Certain Consumer Rights and on the Liability for Damage Caused by a Dangerous Product (2000)
F Act on Consumer Credit (2001)
O Act on Investment Funds (2004)
Portugal 4 X 4 4
G Law No. 24/1996 – General Consumer Protection Law (1996)
F Decree–Law No. 133/2009 of 2 June: Introduced a regime of maximum annual rates of charge that credit institutions must comply with in consumer contracts; Instruction No. 8/2009:
A Standardized Information Sheet to be provided to customers in the precontractual stages of consumer credit; Instruction No. 11/2009: The standardization of the method for cal-culating
the Annual Rate of Charge; Decree–Law No. 192/2009 of 17 September: The introduction of the concept of Adjusted Annual Rate of Charge, an interest rate that takes into
account the cost of products and services subscribed in tandem with a housing mortgage credit in order to reduce the spread or the fee of this credit, and also extends the rules of
Decree–Law No. 51/2007 to related housing mortgage credits, specifically the caps on penalties in case of early repayment; Decree–Law No. 103/2009 of 12 May: The creation of an
extraordinary credit line, during two years, in order to provide protection of the proprietary home in case of unemployment; Decree–Law No. 222/2009 of 11 September: The inser-tion
of measures of consumer protection concerning life insurance contracts associated to the housing mortgage credit; Notice No. 4/2009 and 5/2009: A Standardized Information
Sheet to be provided to customers for all kinds of deposits (plain vanilla, dual and indexed); Notice No. 6/2009: A 100% capital guarantee for all deposits; the indexed deposits must
be linked to relevant economic or financial variables; Notice No. 10/2008 of 22 December: New information and transparency duties with which credit institutions have to comply
when advertising their products and services; Notice No. 8/2008 of 12 October: A list of fees and charges applied by credit institutions, when selling their products and services, must
be easily accessible to customers in all branches; Decree–Law No. 317/2009 of 30 October: A new legal framework applicable to Payment Services, which transposes the European
Directive No. 2007/64/EC; Decree–Law No. 430/91 of 2 November: Establishes the different types of deposits permitted by law; Decree–Law No. 349/98 of 11 November and Decree–Law
No. 51/2007 of 7 March: Govern the commercial practices and information duties of credit institutions in the scope of housing mortgage credit; introduce the concept of annual
rate of charge as well as a cap on the penalty fees charged in case of early repayment of housing loans; Decree–Law No. 171/2008 of 26 August: Prohibits the charging of any fee
for renegotiating housing mortgage contracts and for making such renegotiations dependent on the subscription of additional financial products and services; Decree–Law No.
240/2006 of 22 December: Establishes the rules on interest–rate rounding in housing mortgage credit contracts.
O Instruction No. 27/2003: Establishes a Standardized Information Sheet for housing mortgage credit, based on European Commission Recommendation No. 2001/193/EC; Notice No.
3/2008: Establishes rules on the information provided to customers regarding their net current account balance.
Puerto Rico 4 4 4 4
G Law No. 4: Creates the Office of the Commissioner of Financial Institutions (1985)
E Regulation No. 6194: Lease of Movable Property with the Option to Buy (2000)
F Regulation No. 6451: On Collection Agencies (2002)
O Regulation No. 7751: Against Deceptive Practices and Advertisements (2009)
Romania X X X X
Russian
Federation X 4 X 4
E Law on Consumer Protection (1992)
O Law on the Insurance of Individual Deposits in Russian Banks (2003)

G E F O
services
Rwanda X X X X
Senegal X 4 X 4
Serbia 4 X 4 4
F RS Official Gazette No. 15/2009—Decision Specifying Conditions and Manner of Dealing With Bank Customer Complaints (2009); RS Official Gazette No. 4/2006—Decision on Minimum
Conditions for the Conclusion of the Financial Lease Contract and the Manner of Disclosing the Leasing Fee and other Costs Arising from the Conclusion of such Contract and its supplement
in RS Official Gazette No. 64/2006 (2006). According to the supplement on the Decision on Minimum Conditions for the lessee–natural person, the obligation to make an upfront
payment (in an amount that cannot be lower then 20% of the gross purchase value of the lease object), was suspended until the end of 2009.
O Decision on the General Terms of Business Applied by Banks in Relations with Natural Person Clients (2009)
Sierra Leone 4 4 4 X
G Banking Act (2000); Other Financial Services Act (2001); Payments System Act (2008)
E Banking Act (2000); Other Financial Services Act (2001)
F Banking Regulations Act (2005)
O A review of the statutes focusing on consumer protection issues is currently in process.
Singapore 4 4 4 X
G Consumer Protection (Fair Trading) Act (2003)
E The Consumer Protection (Fair Trading) (Regulated Financial Products and Services) Regulations (2009); Securities and Futures Act (2001); Financial Advisers Act (2001)
F Securities and Futures Act (2001); Financial Advisers Act (2001). Both acts contain various provisions which address risks to consumers such as those arising from insufficient, false, or
misleading disclosure, conflicts of interest, and misrepresentation.
Slovak
Republic 4 4 4 X
G Act on Consumer Protection (1992)
E Act No. 266/2005 Coll. on the Consumer Protection in Connection with the Distance Financial Services (2005)
F Act No. 747/2004 Coll. on Supervision of the Financial Market (2004); Act No. 659/2007 Coll. on the Introduction of the Euro in the Slovak Republic (2007); Act No. 483/2001 Coll. on Banks
(2001); Act No. 186/2009 Coll. on Financial Intermediation and Financial Counselling (2009); Act No. 492/2009 Coll. on Payment Services (2009); Act No. 8/2008 Coll. on Insurance (2008);
Act No. 43/2004 Coll. on Retirement Pension Saving (2004); Act No. 566/2001 Coll. on Securities and Investment Services (2001); Act No. 594/2003 Coll. on Collective Investment (2003); Act
No. 118/1996 Coll. on Deposit Protection (1996); Act No. 650/2004 Coll. on Supplementary Pension Saving (2004)
South Africa 4 4 X X
G Consumer Affairs Act (2001)
E National Credit Act (2007)
Spain 4 X 4 4
G Royal Legislative Decree 1/2007 of November 16, approving the revised text of the General Law for the Protection of Consumers and Users, and other complementary laws (2007)
F Beyond the specific rules relating to securities and insurance, outside of the Bank of Spain, there is Royal Decree 303/2004, Approving the Regulation of the Commissioners for Financial
Consumer Protection (2004); ECO Order 734/2004, On the Departments and Services of Customer Care and Protection of the Clients of Financial Institutions (2004); Order of 12.12.1989
on Interest Rates and Fees, Performance Standards, Customer Information and Advertising by Financial Institutions (1989); Order of 5.5.1994, Transparency of the Financial Conditions of
Mortgage Loans (1994); Circular No. 8 /1990 of the Bank of Spain, Transparency of Operations and Protection of Customers (1990); Order PRE/1019/2003, Transparency of Prices of Banking
Services Delivered through ATMs (2003).
O Law 7/1995, On Consumer Credit (1995); Act 2, On Subrogation and Modification of Mortgage Loans (1994); Law 22/2007, On Provision of Financial Services Remotely (2007); Law 41/2007,
amending Law 2 /1981, Regulation of the Mortgage Market and other Rules of the Mortgage and Financial System (regulation of reverse mortgages and care insurance, by establishing
certain tax legislation) (2007); Law 2 /2009, Contractual Regulation of Loans or Mortgage Loans Credit and Related Financial Intermediation Services (2009); Law 16/2009, On Payment
Services (2009); Law 7/1998, On General Contractual Conditions (1998). There is different legislation for the protection of financial consumers in various operational provisions, both
in law as Orders and in Circulars of the Bank of Spain.
Sri Lanka 4 4 4 X
E Banking Act (1988)
St. Kitts and
Nevis X X X X
St. Lucia X X X X

G E F O
services
St. Vincent and
the Grenadines X X X X
Sudan X X X X
Swaziland 4 4 4 4
G Competition Commission Act (2008)
F Financial Institutions Act (2005)
O Central Bank of Swaziland (CBS) Order (1974)
Sweden 4 4 4 4
G Consumer Sales Protection Act (1990)
E Consumer Credit Act (1992)
F Financial Advice to Consumers Act (2003)
O Finansinspektionen's (Swedish Financial Supervisory Authority) Regulations and General Guidelines regarding Financial Advice to Consumers (2004)
Switzerland 4 4 4 4
G Several codes of Swiss civil law carry special rules favoring consumers.
E The Konsumkreditgesetz (KKG) (2001) governs credit relations with consumers with the main aim to protect them against over indebtedness.
F Several provisions of Swiss banking law and financial products law carry rules to protect unqualified investors, to mitigate information asymmentries, and to impose duties and
rules of business conducts on financial services providers.
O A lot of topics are governed by self–regulation issued by industry associations, such as the Swiss Banking Association. In part, violation of those self-regulation rules may lead to
supervisory sanctions, as would the breach of state law.
Syrian Arab
Republic X 4 X X
E Consumer Protection Law No. 2 (2008)
Taiwan, China 4 X X X
G The Consumer Protection Law (1994)
Tajikistan 4 X 4 X
G Law on Consumer Protection
Tanzania 4 X X X
G Fair Competition Act (2003)
Thailand 4 X 4 X
F Financial Institutions Act (2008)
Togo X 4 X 4
Tunisia 4 X 4 X
G Law N°92–117 on Consumer Protection (1992); Law N°91–64 on Competition and Pricing (1991); Law N°98–39 on Financing (1998); Law N°98–40 on Sales Techniques and Commercial
Advertising (1998); Organic Law N°2004–63 on the Protection of Personal Data (2004)
F Law N°2001–65 on Credit Institutions (2001); Law N°2006–26 amending and supplementing Law N°58–90 on the Establishment and Organization of the Central Bank of Tunisia (2006).
The Center for Banking Services was created in 2006 under the Central Bank and is charged with monitoring the quality of services provided by credit institutions to their clients
and the establishment of reference guides for banking services in order to inform the public and disseminate best practices in this sector. The promotion of the quality of banking
services was established as a legal obligation in 2006. The supervision of bank–client relations was brought about by the enactment of the management agreement on deposit
accounts, the definition of basic banking services, and the establishment of a mediation system to amicably resolve disputes between two parties.

G E F O
services
Turkey X 4 4 X
E Law No. 4077 on Consumer Protection (1995)
F By–Law on Rules and Procedures for Early Repayment Discount for Consumer Credits and Calculation of Annual Cost Rate (2003); By–Law on Rules and Procedures for Pre–Contractual
Information Sheet Given by Housing Finance Institutions (2007); By–Law on Rules and Procedures for Informing Consumers about Housing Finance Contracts Containing Variable Interest
(2007); By–Law on Rules and Procedures for Early Repayment Discount and Calculation of Annual Cost Rate in the Housing Finance System (2007); By–Law on Rules and Procedures for
Refinance of Loans under Housing Finance (2007)
Uganda X X 4 X
F Financial Institutions Act (2004); Microfinance Deposit–Taking Institutions Act (2003). The Financial Institutions Act and the Microfinance Deposit–Taking Institutions Act ensure the safety
of depositors' funds.
Ukraine 4 4 4 X
G The Law of Ukraine on Consumer Rights Protection (1991)
E The Law of Ukraine on Consumer Rights Protection (amended in 2001 to include financial service provisions)
F Name of law not provided (2007).
United Arab
Emirates X X X X
United
Kingdom 4 4 4 4
G Cancellation of Contracts made in a Consumer’s Home or Place of Work Regulations (2008); Consumer Protection Act (1987); Consumer Protection (Distance Selling) Regulations (2000);
Consumer Protection from Unfair Trading Regulations (2008); Estate Agents Act (1979); Fair Trading Act (1973); General Product Safety Regulations (2005); Package Travel, Package
Holidays and Package Tours Regulations (1992); Prices Act (1974); Property Misdescriptions Act (1991); Protection from Harassment Act (1997); Sale and Supply of Goods to Consumers
Regulations (2002); Sale of Goods Act (1979); Supply of Goods (Implied Terms) Act (1973); Supply of Goods and Services Act (1982); Timeshare Act (1992); Weights and Measures Act (1985);
Weights and Measures (Packaged Goods) Regulations (2006)
E Consumer Credit Act (1974); Unfair Contract Terms Act (1977); Unfair Terms in Consumer Contracts Regulations (1999); numerous other regulations, including provisions relating to
interest rates.
F There are numerous regulations but the main provisions are contained in the Financial Services and Markets Act (2000) and Consumer Credit Act (1974).
O Financial Services and Markets Act (2010) grants power to the Financial Services Authority (FSA) to make rules to protect consumers. These are contained in the FSA's Handbook.
There are many laws and regulations that relate to consumer protection in financial services in the UK. This legislative framework includes acts of the UK parliament and statutory
instruments, some of which enact EU law into domestic law. In addition, the UK's common law system means that these acts and regulations are supplemented by judge–made
laws.
United States 4 4 4 4
G Federal Trade Commission Act (1914)
E Consumer Credit Protection Act (1968)
F There are numerous regulations issued by federal agencies that supervise depository institutions.
O The US has numerous laws, both federal and state, that regulate a broad range of financial services for consumer protection.
Uruguay 4 4 4 4
G Law on Consumer Relations (2000)
E Usury Law (2007)
F Circular 2.016 BCU, Relationship with Customers and Information Transparency (2009)
O Regulatory Decree of the Law of Usury (2009)
Uzbekistan X 4 X X
E Law on Protection of Consumers' Rights (1996)
Venezuela,
R.B. de 4 X 4 4
G Law for the Protection of Persons in Access to Goods and Services (2010)
F Resolution No. 147.02, Official Gazette of the Bolivian Republic of Venezuela No. 37.517, Rules for the Protection of Users of Financial Services (2002); Resolution No. 209.08, Official Gazette
No. 39.002, Concerning Preferential Treatment and the Adequacy of Facilities for People with Disabilities, Seniors and Pregnant Women (2009); Resolution No. 385.07, Official Gazette No.
38.825, Stating that All Financial Institutions that Capture Public Resources Must Provide at Least One Checkbook per Checking Account at the Time of Account Opening (2007)
O Resolution No. 228.07, Official Gazette No. 38.800, Prohibiting Financial Institutions from Using Compound Interest in the Calculation of Interest on Lending in the Form of Credit Cards
(2007)

G E F O
services
Vietnam X X 4 X
F Credit Institution Law (1997); Government's Decree on Deposit Insurance (1999)
Yemen, Rep.
of X X X X
Zambia 4 X 4 X
G Competition and Fair Trading Act (1994)
F Statutory Instruments No. 179 (Cost of Borrowings) and No. 183 (Disclosure of Deposit Charges and Interest) of the Banking and Financial Services Act (1995)
Zimbabwe 4 4 4 X
G Hire Consumer Contact Act (1994)
E Moneylending and Rates of Interest Act (1930); The Banking Act (1999)
F Moneylending and Rates of Interest Act (1930); The Banking Act (1999)

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Financial Access 2010