I was in India a few weeks ago speaking to the Reserve Bank and most of the primary Retail Banks about the impact of mobile and social media on the industry there. The new RBI Governor in India, Raghuram Rajan, has ruffled some feathers with his unconventional approach thus far, but he has his work cut out for him with a very traditional market, with very traditional views.
Enshrined in the banking culture and in bank regulations is the perceived 1:1 relationship between branches and Financial Inclusion. This is not unheard of in developed economies either, but in India it is so much a part of the culture that no one has rethought this paradigm in a very long time. The assumption simply is that if India wants inclusion, it needs more branches. In fact, in a speech given on the 10th of December by Shri P. Vijaya Bhaskar, Executive Director, Reserve Bank of India, he said the following:
Compulsory Requirement of Opening Branches in Un-banked Villages.Banks are directed to allocate at least 25% of the total number of branches to be opened during the year in un-banked (Tier 5 and Tier 6) rural centers.
India has just 110 branches per million persons, compared with the USA which has more than 300 branches per million persons, and Spain which has an incredible 900 branches per million persons, with the next nearest in the EU being Italy with 650/mm. You would think then that there is a need for India to ‘catch up’ to developed economies in respect to branch density if they want to stimulate financial inclusion. However, in countries like Norway (90), Singapore (90), Germany (120), Sweden (150) or South Korea (160) we’re already seen reduction of branch density down to the levels you see in India today (Source: World Bank). In most developed economies the CAGR of aggregate number of bank branches is -2% to -4% annually these days, and is trending towards a steeper decline. Some economies like Australia have been slow to start this decline, but a normalized range of branch density for most developed economies probably is around 100-150 branches per million people given the overarching trend for reductions in branch activity when it comes to customer visits annually and declining revenue effectiveness.
I know this in itself will generate much debate, but bear with me here.
Branch Density is inverse to Inclusion
Regardless of which branch density number is the right number, let’s compare branch density with financial inclusion numbers for a few countries where branch density is above the developed economy norm:
What about some countries where branch density is low, how does this correlate with financial inclusion:
Looking at this data, you could rightly determine that financial inclusion is actually inverse to branch density – however, that may just be correlation dynamics. Now look at Kenya, 50 branches per million people, 20% financial inclusion through a bank, and 65% financial inclusion through a mobile phone or mobile money account.
The correlation here is actually not with branch density, but with the regulators propensity to push paper KYC in a branch as the pre-requisite for account opening. Identity Verification in-branch is the single biggest hurdle to financial inclusion today in both the developed and developing world. In fact, the lesson here is even more stark.
No economy in the world has ever improved financial inclusion for poorer segments of the market through branch access, and no market in the world will ever get to 100% financial inclusion based on branch density and traditional in-branch onboarding. However, it is entirely possible that Kenya could surpass the US in terms of financial inclusion over the next 5 years based on the mobile phone. The only thing that might save the US is the availability of pre-paid debit cards through Alternative Financial Services providers.
Inclusion gets killed by Branch ID&V/KYC
For countries like India more branches are not the answer. Enabling more phones for payments and money movements with easy onboarding might just be. In India the Universal Identity Number (and associated Aadhaar ID card) are hailed by regulators as the mechanism by which face-to-face Identity Verification will be underpinned for financial inclusion. The bigger problem that we see is that even if you were able to get adequate branch density, people are still not going to visit a bank branch. They might visit a post-office outlet, a grocery store or a mobile phone store, but the KYC requirements have to be light.
Let’s think about this simply. KYC regulations have got significantly heavier over the past 20 years due to FATF AML reporting requirements and CIP requirements emerging from the post-terrorist financing push after 9-11 in the US. We now understand that we don’t actually need such harsh account establishment rules to prevent money-laundering or suspicious transactions, because that is based on account activity. We do still need to uniquely identify customers to ensure that identity theft isn’t occuring, and to limit financial crime, but if we are relying on a face-to-face IDV event for that in a bank branch, we will kill the overarching objective of 100% financial inclusion – the stated goal of most economies in the world today.
Here’s the rub. If you’re a regulator and you require a signature along with the physical presence of the individual for account opening ID&V (Identity & Verification) in a branch – then you must accept that you are working against financial inclusion. If, on the other hand, you want both a modern banking system that allows the phone to act as a primary bank account and you wish to enable inclusion, then mobile onboarding of a customer should be the firm priority.
The model of IDV and KYC for mobile onboarding shifts to a progressive KYC model, with behavioral learning around the customer. Behavioral models are still essential for predictive analytics around fraud today in any case, so we are just shifting the emphasis for suspicious transaction reporting and fraud responses to behavior, instead of a one-time event that can be gamed and is no longer efficient or effective.
If a regulator doesn’t have a plan for allowing the on-boarding of new bank accounts via a mobile phone, they are already out of step with the numbers when it comes to both inclusion and customer behavioral adoption when it comes to banking.
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