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Client Protection Principle

State of the Practice: Client Protection in Sub-Saharan Africa’s Microfinance Sectors

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Through the Responsible Finance through Local Leadership (RFLL) program (2012–2016), the SEEP Network is engaged with seven microfinance associations in sub-Saharan Africa (in Benin, Burkina Faso, Côte d’Ivoire, Ghana, Rwanda, Senegal, and Uganda) to promote responsible microfinance. SEEP is supporting initiatives to:

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Bank of Uganda Issues Financial Consumer Protection Guidelines: Know Your Rights

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bank-of-uganda logoIn line with its Financial Inclusion Project, the Central Bank of the Republic of Uganda (BoU), has issued guidelines for Financial Consumer Protection (FCP) Guidelines: Know Your Rights to all Supervised Financial Institutions (SFIs) including commercial banks, credit insititutions and microfinance deposit-taking institutions. BoU’s Financial Inclusion Project is built on four pillars: (1) Financial Literacy; ( 2) Financial Consumer Protection; (3) Financial Innovations; and (4) Financial Services Data and Measurement.

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Collecting and Using Exit Survey Data

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This tool discusses how financial institutions (FIs) can design exit survey tools, collect exit data, and use them for designing and improving products and services. It explains a five-step process for developing, introducing, and using an exit survey. FIs with existing exit surveys can use the tool to rethink and strengthen their current tool. Those without an existing tool can use it to understand their options and design a tool. 
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UGAFODE’s Complaints Handling: A Case Study

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This case study describes UGAFODE’s customer complaint handling system, and how this lines up with both Client Protection Principle 7, mechanisms for complaint resolution, and with the Universal Standards for Social Performance Management.
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Training Tool for Data Privacy

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In simple terms, the Smart Campaign’s Client Protection Principle 6 affirms that clients share very important personal and financial information with FIs and that it is the responsibility of FIs to protect the privacy and confidentiality of such data. If a financial instution has to share the client data with outside agencies, it should seek necessary approval from the client before sharing the data. This tool illustrates what could go wrong if proper policies and procedures for protecting the privacy of client data are either not implemented or not followed.
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Mechanisms for Complaints Resolution

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Most financial institutions (FIs) provide clients with one or more channels for communicating their questions and complaints to the institution. However, not all complaints mechanisms are effective. This tool will discuss how FIs can design effective complaints mechanisms. A complaints “mechanism” refers to a system for collecting, resolving, and responding to client questions and complaints, and for using client feedback to improve products and operations. An “effective” mechanism is one that allows for a timely response to clients and enables the institution to address both individual and systematic problems.
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Client Protection: The State of Practice (A look at client protection practices in Pakistan’s microfinance industry)

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This MicroNote primarily draws on the results of the 10 Smart Assessments conducted for MFPs in Pakistan during 2013. These 10 MFPs account for approximately 70 percent of the market in terms of number of clients and approximately 65 percent in terms of gross loan portfolio.

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A Guide to Client Protection Assessments

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The Smart Campaign offers three options for a financial institution (FI) to evaluate its client protection practices. To help make the most appropriate choice, the Smart Campaign created a helpful and comprehensive resource for FIs, “A Guide to Client Protection Assessments.”

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Tool Recommendations to Address Gaps

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After conducting an initial evaluation of practices with the Getting Started Questionnaire, using this helpful guide “Tool Recommendations to Address Gaps” can help an MFI be directed towards especially helpful resources to improve its client protection performance and adherence to the standards and indicators of the Client Protection Principles.

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Crezcamos’ Welcome Kit

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The objective in the development of this kit was part of a series of strategic activities that Crezcamos carried out to strengthen its practices in client protection. The kit was developed with the guidance of the Smart Campaign tool ‘Essential Documents for New Clients.’

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Resolving Client Complaints: The Example of Ujjivan, India

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This case study describes the successful implementation of Client Protection Principle #7 — Mechanisms for Complaint Resolution, by the Indian MFI Ujjivan Financial Services Pvt Ltd. All financial service providers should have in place a timely and responsive mechanism to resolve client problems and improve their products and services. 

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Fostering Transparency at Banco Delta

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Banco Delta, a leading institution in Panama, used an active complaint resolution mechanism to improve its transparency practices, an area of improvement identified during a Smart Assessment conducted in October 2012.

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Defining and Monitoring Collection Practices at FODEMI

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FODEMI’s management, a microfinance institution based in the North Andean region of Ecuador, had become aware of institutional gaps through a Smart Assessment conducted in February 2013. The resultant effort to bridge the gaps involved collaboration across departments including Human Resources, Social Performance, Internal Audit, Operations, and the Credit Department.

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The Full Feedback Cycle at Contactar

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After experiencing a period of rapid growth, Contactar realized it needed to be more aware of the needs and concerns of its ever-expanding client base. In January 2013, Contactar decided to upgrade its overall strategy to listen to client complaints and concerns after realizing that their suggestion box was clearly not enough.

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Ensuring the Security of Client Information at FUBODE

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While FUBODE already had basic security measures in some of its branches at the time the Smart Assessment was conducted, the results revealed the need to implement these in all of its agencies. As of today, all 18 branches – seven of which are located in urban areas and 11 in rural zones – have a specific room assigned within each branch to store clients’ physical documents.

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Well-Written Privacy Policy, Secure IT Systems, and Staff Trained to Protect Information at SKS and Equitas

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SKS has a written policy on sharing client information with external parties. It clearly categorizes types of information into “confidentiality critical” and “confidentiality sensitive” and lays down the process for handling each category. Equitas is the first MFI in India to have a core banking solution, TEMENOS – T24. This product is an extension of T24 Banking software, developed specifically for microfinance and the community banking sector.

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Monitoring Individual Repayment in Group Guarantee Mechanism

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“Monitoring Individual Repayment in Group Guarantee Mechanism” shares the experiences and discussions on how best to track the exercises of group guarantees at the individual level in the sector comparing the structured approach of MBK in Indonesia and the more informal approach Utkarsh in India. The tool demonstrates two simple approaches of monitoring the implementation of group guarantees.

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SPTF Universal Standards Implementation Example (How Bandhan Trains and Evaluates Credit Staff)

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This case study demonstrates how Bandhan Financial Services Pvt. Ltd. implements Essential Practices from Dimension 5 (Treat Employees Responsibly) of the Universal Standards for SPM. Other financial service providers can use this example to improve their own Human Resources policies and practices.

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Client Protection for Youth Clients (UNCDF – YouthStart Technical Note)

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This technical note is intended to assist Financial Service Providers currently serving youth, planning to serve youth, or making improvements to existing services to do so in a way that ensures that youth are protected. The technical note synthesizes adaptations made by UNCDF – YouthStart to the indicators of the Smart Campaign´s self-assessment tool.

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Implementing Client Protection in Indian Microfinance

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This State of Practice Report represents an important step in understanding the state of client protection practices today in India, three years after the Andhra Pradesh crisis and two years after the Smart Campaign began its deep engagement with the sector.

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Smart Saving and Lending: Member Protection in SHG Model

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This tool is aimed at SHGs, Banks and NGOs (SHPIs) that want to incorporate good protection for SHG members. Since, the majority of SHG linkages with banks are based on Model II of the bank linkage program (Bank –Facilitating Agency –SHG Members) in this tool an attempt has been made to map the process of the SHG linkage with the bank with NGO acting as a facilitator.

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Refinancing Policy – FUBODE

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One document that called our attention was FUBODE’s rescheduling and refinancing policy, one that many MFIs lack. FUBODE Kindly agreed to share their policy with the industry so as to foment best practices.  This document should be used as a starting point for any MFI who wants to improve their restructuring and rescheduling policies as per the Smart Campaign Principles.

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Smart Note: Supporting Members to Adopt Client Protection at Azerbaijan Microfinance Association (AMFA)

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AMFA shared with the Smart Campaign why client protection is a priority for the association, and how they encourage strong client protection practices in the Azerbaijani microfinance industry. Their client protection initiatives can serve as a good practice example to other networks and associations.

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Smart Microinsurance: An Overview for Microfinance Institutions on Incorporating Client Protection Practices into Microinsurance

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The Smart Campaign and the Microinsurance Network present “Smart Microinsurance”—a tool designed specifically for microfinance institutions (MFIs) that serve as intermediaries, offering microinsurance products provided by an external insurance company.

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Smart Note: Appropriate Product Design and Delivery at Musoni

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Musoni_logoMusoni is a microfinance institution using mobile technology to deliver convenient, flexible, and reliable loans to low-income people in Kenya (and other East African countries in the future). Musoni’s products are designed based on the needs and preferences of their clients.

The Smart Campaign’s Client Protection Principle Appropriate Product Design and Delivery, states that institutions should design products and delivery channels in such a way that they do not cause clients harm, and with client characteristics taken into account.

Musoni’s approach to product design can serve as an “excellent practice” example to other institutions. Musoni staff discussed the institution’s product design and delivery with the Smart Campaign, revealing five primary lessons from the field, presented in this Smart Note.

Download the Smart Note (English) »

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Smart Note: Treating Clients with Respect at Fundación Mundo Mujer Popayán

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This Smart Note describes how Fundación Mundo Mujer Popayán developed a stronger pro-client attitude. They developed a set of complementary policies, that, unlike previous material, use specific problem situations to address potential weaknesses in client protection practices.

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Smart Note: Responding to a Crisis at FUNDESER

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The Smart Note, “Responding to a Crisis at Fundeser” describes how the MFI dealt with the aftermath of both the worldwide credit crisis and the internal No Pay Movement (Movimiento No Pago). It explains how the institution overhauled its Human Resource department in an effort to steer the institution to recovery.

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Smart Campaign Tools Training

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The Smart Campaign has developed dozens of tools to assist microfinance institutions (MFIs), investors, and networks/associations in the implementation of client protection. This PowerPoint training introduces participants to the client protection tools available from the Smart Campaign.

The training discusses two “entry points” for using Smart Campaign tools: 1) As part of a client protection strategy, and 2) As a solution to a specific problem. Participants review examples of each entry point, and learn about tools that can assist them during any step of client protection implementation.

Download the Tool »

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Responsible Treatment of Clients: Practicing Non-discrimination

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This tool provides financial service providers with insight into the difference between client targeting and harmful discrimination and illuminates examples of common forms of discrimination. Finally, the tool provides financial service providers with seven action steps to correct and prevent discrimination.

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Nondiscrimination Policy of Fundación Paraguaya

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Fundación Paraguaya has shared its non-discrimination policy, which makes part of their Code of Ethics, with the Smart Campaign to be used as a tool for other institutions to emulate as they strive to implement non-discrimination policies of their own.

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Smart Note: Hiring Staff with Disabilities at AccessBank, Azerbaijan

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This Smart Note focuses on the efforts of AccessBank Azerbaijan to practice non-discrimination among employees through deliberate efforts to hire people with disabilities. Additionally, the Smart Note provides a testimonial from one of AccessBank’s employees about his experience as a person with disabilities working as a cashier at the MFI.

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Over-indebtedness of Microborrowers in Ghana

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To give guidance on how to live up to the standard of responsible finance, the Smart Campaign developed the Client Protection Principles with widespread industry participation. Prevention of over-indebtedness is one of these principles. However, commitment is not sufficient to put a principle into practice. This report makes an important contribution to deepening knowledge on this elusive topic.

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Smart Note: Client Protection Good Practices in Europe and Central Asia

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This Smart Note examines the client protection practices of AccessBank (Azerbaijan), Adie (France), EKI Micro-credit Foundation (Bosnia and Herzegovina), and KazMicroFinance (Kazakhstan), demonstrating how the institutions are preventing client over-indebtedness; transparently disclosing loan prices, terms, and conditions; and treating clients fairly and with respect.

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Compulsory Group Training Tool

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This tool is designed to help MFIs develop a more robust framework to incorporate good client protection practices into their compulsory group training. This tool is most suited for MFIs who employ village banking methodology and Grameen Style “group or groups” methodology.

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Essential Documents for New Clients

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The “Essential Documents for New Clients” refers to the set of documents that help new clients understand their full financial obligations, what they can expect from the institution, and what to do if they experience problems along the way.  

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Code of Conduct for Collections and Collections Practices for Group Loans at Swadhaar FinServe Pvt. Ltd.

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Swadhaar FinServe Pvt. Ltd. shared their Code of Conduct for Collections and their Collections Practices for Group Loans, both of which provide collections staff with specific guidelines and procedures for treating clients with dignity. The Smart Campaign encourages other institutions to review this good practice.

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Collections Guidelines for Financial Service Providers

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This tool is a checklist for institutions to assess their collections policies and practices, with the goal of strengthening client protection during the collections process. The tool addresses collections policies, practices, manuals, and training of field staff. 

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Investor/Donor Planning Guide for Implementing Client Protection Initiatives

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Investors and donors can use this short worksheet to plan for the integration of client protection into their due diligence processes and their funding strategies. The worksheet first guides the user through the process of assessing current resources and priorities, to take stock of where client protection efforts may best fit within current workflows.

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Putting Transparency into Practice: Communicating About Pricing

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This brief document describes how financial service providers observe the principle of transparency, current resources that exist to help providers understand and communicate their prices to clients, and information on where providers can find more information from the Smart Campaign and MFTransparency.

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Smart Note: Ethical Staff Behavior at Alalay Sa Kaunlaran, Inc. (ASKI)

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ASKI implements their written “Code of Conduct and Discipline” through staff training, staff performance reviews, client satisfaction surveys, and the ASKI Values Protocol—an established process for addressing staff violations of the code. In addition, clients can provide instant feedback on staff behavior.

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Code of Conduct E-Learning Module (Grameen Financial Services Pvt. Ltd.)

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Grameen Financial Services Pvt. Ltd. (GFSPL) shared with the Campaign its Code of Conduct E-Learning Module, which is used to test employee knowledge of the institution’s Code of Conduct.  GFSPL’s code was created based on other codes endorsed by leading microfinance bodies in India as well as the guidelines offered by the Smart Campaign

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Avoidance of Over-indebtedness: Guidelines for Financial and Non-financial Evaluation

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This tool is for financial service providers that want to incorporate good client protection practices into their evaluation processes for individual loan clients. Specifically, the tool provides guidelines for determining a loan applicant’s capacity and willingness to repay a loan.

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Illustrations and Activities for Training Loan Officers on Customers’ Rights and Responsibilities (Sahayata Micro Finance Pvt. Ltd.)

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In March 2011, the Smart Campaign issued a Call for Tools to the microfinance industry: “Training Staff for Ethical Behavior.” Sahayata Micro Finance Pvt. Ltd. (India) shared with the Campaign their illustrations and activities for training loan officers on customer rights and responsibilities.

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Smart Note: Responding to Client Complaints at Tameer Bank, Pakistan

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Tameer staff member Murium Hadi discussed the institution’s complaint mechanism with Zahra Khalid of the Pakistan Microfinance Network (PMN), revealing several valuable lessons from the field.

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Transparency in Promotions and Sales: A Checklist for Financial Service Providers

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This tool focuses on the first point of contact with the client—the initial “sales pitch.” Financial service providers can use this tool to improve transparency when promoting and selling credit and savings products.  The tool contains five “good practice” checklists.

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Smart Lending: Client Protection in the Group Lending Process – India

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This guide is designed to help MFIs incorporate good client protection practices into their group lending policies and operations. The tool is applicable to Grameen-style group of groups credit methodology and was developed specifically for Indian MFIs.

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Client Protection and Financial Education Simulation

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With this online tool, you can complete a simulation as if you were managers or loan officers of an MFI. During each simulation, you can see the effects that your decisions have on the success of a fictional microfinance institution.

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Smart Note: Transparent and Responsible Pricing at Mi-Bospo

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The Bosnian MFI Mi-Bospo focuses on client protection to safeguard both the institution and clients. For Mi-Bospo, transparency and responsible prices are key elements of ensuring client satisfaction. The MFI ensures transparency by screening potential hires, adhering to strict marketing guidelines, and taking time during the loan process to be sure that clients understand their rights and responsibilities.

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Smart Lending: Client Protection in the Group Lending Process

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This guide is designed to help MFIs incorporate good client protection practices into their group lending policies and operations. The tool is applicable to a wide range of credit methodologies and can be adapted for use by various forms of group lending including village banking methodology and “group of groups” methodology.

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Smart Savings: Client Protection in the Savings Process

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This guide is designed to help MFIs, banks, NGOs, and other types of financial institutions identify and integrate good client protection practices in the savings process at every point of interaction with the client.

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Implementing the Client Protection Principles: A Technical Guide for Investors, 2nd Edition

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This guide provides an updated set of action steps for investors, including a new due diligence tool that provides practical guidance and tips on how to assess implementation of client protection practices by retail providers. This guide also reflects on the main operational questions investors are facing, such as how to assess over-indebtedness and transparent and responsible pricing, and emerging responses.

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Loan Agreement for Small Business Clients (JSC MFO Crystal)

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JSC Microfinance Organization Crystal, Georgia shared its plain language loan contract with The Smart Campaign.  This contract is used with clients seeking small businesses credit. The contract is succinct, written in plain language, and uses very little jargon.

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Loan Contract Summary Handout (Mibanco)

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Mibanco also provides clients with a loan contract summary so that clients can easily and efficiently understand the most pertinent points of their full loan contracts. Mibanco uses this tool to verbally review the contract highlights, including the loan information, insurance costs/benefits, early repayment fees, and obligations of the guarantors.

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Responsible Pricing: The State of the Practice

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This discussion paper examines the full range of approaches to responsible pricing of loans, from promoting competition, to return on equity limitations, to interest rate caps, to comparative transparency.

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Beyond Codes: The Foundation for Client Protection in Microfinance

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“Beyond Codes,” an action research project of the Center for Financial Inclusion at ACCION, was designed to provide a body of experience and knowledge from leading financial institutions serving low-income people about how consumer protection codes of conduct are implemented.

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Smart Note: Customized IT at Caja Morelia safeguards client data

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Upon transforming to a regulated financial services provider, Caja Morelia needed to meet federal data management and reporting requirements. Faced with these new technology needs, Caja invested in a data management system and supporting processes to provide superior data security.

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Smart Note: Facing Over-indebtedness at Partner Microcredit Foundation

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Partner Microcredit Foundation avoids client over-indebtedness by recognizing that a risk for the client is a risk for the institution. Partner performs rigorous credit analysis of its clients before issuing a loan and follows up with audits to verify proper staff behavior and discover why clients are not able to meet their obligations.

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Smart Note: Implementing an Industry Code of Conduct at PMN

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PMN formally launched its Consumer Protection Initiative in January 2009. The initiative centers on improving consumer protection practices through a voluntary Code of Conduct for Consumer Protection and a call center for receiving and responding to client grievances.

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Complaints-Analysis Spreadsheet (Fundacion Delamujer)

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Fundacion Delamujer has shared with the Campaign their complaints analysis spreadsheet for monitoring and classifying complaints. It is intended to divide complaints according to their importance, type, and branch. 

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Complaints-Handling Manual (Tamweelcom)

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Tamweelcom  in Jordan has provided the Campaign with their Complaints Handling Manual, which contains detailed scripts of telephone interactions with clients, a flow chart of the complaints process within the institution, as well as their internal forms to be filled out by both clients and staff when a complaint is lodged. 

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Banco Solidario: Loan Officer Training Manual

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Banco Solidario shared with the Campaign their Loan Officer Manual, which includes a Code of Ethics for credit staff and procedures for financial and non-financial evaluation. The Code of Ethics gives loan officers full responsibility for client capacity analysis, and the manual guides loan officers thorough the analysis process.

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Fonkoze: Guide for Credit Agents — Evaluating Clients for Fonkoze’s Post-Disaster Recovery Program

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Fonkoze shared with the Campaign their “Guide for Credit Agents: Evaluating Clients for Fonkoze’s Post-Disaster Recovery Program,” which guides credit agents in disbursing credit in a post-disaster environment—a time when microfinance clients are particularly vulnerable to over-indebtedness.

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Opportunity Bank Serbia: Loan Calculator

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Opportunity Bank Serbia shared with the Campaign their Loan Calculator Toolkit for determining the appropriate loan size for a potential client. Based heavily on information gathered from the national credit bureau, this Excel-based tool requires a thorough evaluation of the client’s business, family income, and existing debt.

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KazMicroFinance: How to Assess Client Businesses

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KazMicroFinance shared with the Campaign their PowerPoint training for loan officers, “How to Assess Client Businesses.” This short presentation trains loan officers in how to thoroughly evaluate a potential client.

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Microfund for Women: Client Business Evaluation Toolkit

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Microfund for Women shared with the Campaign their toolkit for assessing the repayment capacity of individual borrowers. Consisting of a total of four forms—including the loan application—this toolkit provides credit staff a complete profile of the health of the potential client’s business, and their capacity to take on debt. 

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Complaints-Handling Manual (FONDESURCO)

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FONDESURCO in Peru shared their Complaints-Handling Manual with the Campaign. The manual carefully describes the complaints process and who is responsible for each piece.

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Complaints-Handling Brochure for Clients (Opportunity Bank)

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Opportunity Bank Serbia has shared with the Campaign a client brochure detailing exactly where and how to lodge a complaint. The brochure provides clients with a list of steps for introducing a complaint or suggestion through various means and next steps and what to do if the client is not happy with the outcome.

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Smart Note: Building Institutional Culture Around a Code of Ethics at Compartamos

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Compartamos trains all new recruits on the Code of Ethics. The Smart Campaign encourages institutions to download and review this documents as an example of a well-organized, concise overview of a detailed Code of Ethics document.

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Smart Lending: Client Protection in the Individual Loan Process

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This guide is designed to help microfinance institutions with individual lending operations integrate good client protection practices at the intersection points throughout the credit process. At each point in the individual lending process, the guidelines explain how MFI staff should incorporate client protection into policies and operations.

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Security is the Key: Pocket Guide to Financial Security for Clients

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Finamerica provides a pocket-size brochure with tips about how to protect one’s security and prevent identity theft, robberies, and other possible threats to the privacy of their personal information.

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How to Develop an Institutional Code of Ethics

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Most microfinance institutions already have a Code of Ethics, but many of these Codes are not “living” documents that carry significance within the organization. This short guide provides concrete suggestions for creating or remaking an institutional Code of Ethics. 

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Best Practices in Collections Strategies

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ACCION International explains the collections process it employs and draws on its experiences with collections programs throughout Latin America and with new collaborations in India. Read more about the best practices that a microfinance institution should consider when attempting to successfully implement collections activities.

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How to Talk to a Bank: A Brochure for Consumers

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This brochure by Procredit Bank explains to Serbian consumers how banking operations work and how to communicate with bankers. MFIs can create brochures similar to Procredit’s to ensure that their clients know how to ask about the terms and conditions of the services that are being marketed to them.

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Calculating Transparent Prices Tool from MicroFinance Transparency

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MicroFinance Transparency offers a basic tool to help microfinance institutions understand the factors that influence the “effective interest rate” or the APR. MFIs can use this tool to for calculating their own effective interest rates, thereby demonstrating transparent for the pricing of their loan products to anyone who asks.

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Debt Management Guide

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The National Credit Regulator (NCR) of South Africa publishes a debt management guide that provides basic information about how to identify over-indebtedness, tips on how to avoid and deal with over-indebtedness, consumers’ rights, how to access a debt counselor and tips on how to avoid and deal with money-scams, repossessions and surrenders.

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Client Protection and Ethics Codes: Examples for Getting Started

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A number of organizations have already adopted either client protection or ethics codes and charters. Following are links to some organizations who have shared their internal codes with the Campaign.

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Due Diligence Checklist for Investors

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This Checklist for Investors is the product of collaboration between CGAP, The Smart Campaign, and many investors. It draws on investor practice and experience. This checklist is not designed as a standalone due diligence tool. Instead, it is designed to lower transaction costs by presenting questions to add to common due diligence topics.

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Swadhaar FinServe Pvt. Ltd. Earns Honors in Smart Campaign’s Call for ‘Appropriate Collections Practices’

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The Smart Campaign applauds company’s policy on respectful practices in loan recovery

Washington, DC, March 18, 2011 — The Smart Campaign, a global initiative to incorporate strong client protection principles across the microfinance industry, today recognized Swadhaar FinServe Pvt. Ltd. (SFPL) for its outstanding efforts to ensure that clients are treated with dignity, even when they fail to meet their contractual commitments.

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Smart Note: Transparent and Responsible Pricing at Mi-Bospo

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New SmartNote Now Available! Read an interview with Mi-Bospo Executive Director Nejira Nalic on how her institution puts Principle 2—Transparent and Responsible Pricing—into practice.

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