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Many low- and middle-income countries remain challenged by a financial infrastructure gap, evidenced by very low numbers of bank branches and automated teller machines (ATMs) (e.g., 2.9 branches per 100,000 people in Ethiopia versus 13.5 in India and 32.9 in the United States (U.S.) and 0.5 ATMs per 100,000 people in Ethiopia versus 19.7 in India and 173 in the U.S.) (The World Bank 2015a; 2015b). Furthermore, only an estimated 62 percent of adults globally have a banking account through a formal financial institution, leaving over 2 billion adults unbanked (Demirgüç–Kunt et al., 2015). While conventional banks have struggled to extend their networks into low-income and rural communities, digital financial services (DFS) have the potential to extend financial opportunities to these groups (Radcliffe & Voorhies, 2012). In order to utilize DFS however, users must convert physical cash to electronic money which requires access to cash-in, cash-out (CICO) networks—physical access points including bank branches but also including “branchless banking" access points such as ATMs, point-of-sale (POS) terminals, agents, and cash merchants. As mobile money and branchless banking expand, countries are developing new regulations to govern their operations (Lyman, Ivatury, & Staschen, 2006; Lyman, Pickens, & Porteous, 2008; Ivatury & Mas, 2008), including regulations targeting aspects of the different CICO interfaces.
EPAR's work on CICO networks consists of five components. First, we summarize types of recent mobile money and branchless banking regulations related to CICO networks and review available evidence on the impacts these regulations may have on markets and consumers. In addition to this technical report we developed a short addendum (EPAR 355a) which includes a description of findings on patterns around CICO regulations over time. Another addendum (EPAR 355b) summarizes trends in exclusivity regulations including overall trends, country-specific approaches to exclusivity, and a table showing how available data on DFS adoption from FII and GSMA might relate to changes in exclusivity policies over time. A third addendum (EPAR 355c) explores trends in CICO network expansion with a focus on policies seeking to improve access among more remote or under-served populations. Lastly, we developed a database of CICO regulations, including a regulatory decision options table which outlines the key decisions that countries can make to regulate CICOs and a timeline of when specific regulations related to CICOs were introduced in eight focus countries, Bangladesh, India, Indonesia, Kenya, Nigeria, Pakistan, Tanzania, and Uganda.
In Sub-Saharan Africa, 12% of adults now report having a mobile money account, representing over a quarter of the share of those who have any kind of financial account at all. As mobile money expands, there is interest in how regulatory frameworks develop to support digital financial services (DFS) and also support broader financial inclusion. In theory, protecting consumers from risk, and ensuring that they have the information and understanding required to make informed decisions, may increase their confidence and trust in mobile money systems, leading to higher adoption and usage rates. However, consumer protection regulations may also carry certain trade-offs in terms of cost, usage, and innovation. The challenge, according to proponents of consumer protection, is to develop regulations that promote access and innovation, yet still offer an acceptable level of consumer protection. We review the literature on consumer protection institutions and regulatory documents for DFS (particularly mobile money) in 22 developing countries, and identify examples of specific consumer protection regulations relevant to mobile money in each country.