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Foreword
1. Introduction to the Guidelines
2. User Instructions
3. Preparing and Appraising Investment Project
4. Financial Management of Executing Agencies
5. Reporting and Auditing
6. Financial Institutions
6.1. Introduction and Overview
>> 6.2. Reviewing FI Financial Management
6.3. FI Investments
6.4. Assessing FI Performance
6.5. Appraisal Checklist
6.6. FI Reporting and Auditing Issues
7. Knowledge Management
Financial Management and Analysis of Projects : 6. Financial Institutions

6.2. Reviewing FI Financial Management

6.2.1. General Operational Issues

6.2.1.1. State-owned FIs resemble their commercial cousins in that frequently they have been formed to address the needs of a particular community, or category of commerce or industry, or branch of human activities, such as lending very small sums to urban and rural poor through microfinance. Some state-owned FIs are very large, such as the Industrial Development Bank of India (IDBI) or the Agricultural Bank of China (ABC). Other state-owned FIs can be very small and are sometimes operated by volunteers under a manager seconded from a commercial bank. So, as there is no generic model, each FI must be identified and prepared for a project, and appraised as to its capabilities and capacities to deliver a proposed project.

6.2.1.2. The objective of reviewing FI operational performance is to assess its ability to: (i) deliver subloans to achieve defined country/sector economic objectives, (ii) efficiently recover subloans, and (iii) cover all operating costs and make a reasonable profit on the invested capital. FIs have numerous forms of performance indicators that can provide analysts with an understanding of past and ongoing performance.

6.2.1.3. Where an existing FI is the subject of a proposed project, or of a continuing ADB lending operation, the financial analyst (or investment officer) should begin by closely studying the FI's most recent annual financial statements and associated auditors' reports and opinions.

6.2.1.4. For an ongoing project, this review should be conducted against the objectives and recommended operational performance set out in the most recent RRP. After drawing conclusions as to past and current performance, the financial analyst (or investment officer) should discuss their findings in detail with the project officer and the FI management and, if appropriate, with the proposed or actual borrower, and an apex institution (where participating). Every effort should be made to reach agreement on these initial findings; particularly on management deficiencies, system defects, and performance shortcomings or failures.

6.2.1.5. This first step is essential to ensure that the FI management understands and is likely to fully support the likely objectives of a proposed project, or revision of objectives (where necessary) for an ongoing project, as the ADB mission continues its work of preparing or supervising a project.

6.2.1.6. Full collaboration by FI management and their complete endorsement of a mission's proposals is critical for the investment's success. Any reservations by FI management or the borrower should be confirmed in the Aide Memoire and reported to the MRM.

6.2.1.7. It is particularly important to monitor the implementation and fulfillment of the stakeholders responsibilities, and the impact of their obligations on: (i) their respective national economies; (ii) performance of the institution as a borrower; (iii) national influences on regional operations (where present), and (iv) selected enterprises in representative regions of countries as subborrowers.

6.2.2. Policy Framework for FIs and FI Loans

6.2.2.1. The design and timing of FILs should take account of the prevailing and expected macroeconomic environment, including the exchange rate regime and international capital mobility, as well as conditions in real sectors. Given the critical importance of the macroeconomic and sectoral framework for financial sector sustainability and efficiency, ADB considers FILs only in the context of a satisfactory macroeconomic framework. Within this framework, ADB uses its lending and nonlending services to focus on improving the incentive environment for FIs.

6.2.2.2. ADB involvement in the financial sector of countries through FILs: (i) supports improvements in the incentives structure for market participants, including elimination of impediments to efficient resource mobilization and allocation; (ii) supports development of infrastructure, including creation and strengthening of sound and competitive financial institutions and markets, and improvements in financial and prudential regulations, banking supervision, and accounting and auditing standards; and (iii) aims to remove or substantially reduce subsidies, whether provided through interest rates, directed credit, institution-building grants, or otherwise. (Institution-building TA grants and other non-interest rate subsidies may be provided in a variety of ways, for example, as preferential income-corporate tax treatment, free use of facilities, consultancies, guarantees, training, and subsidized staff costs and overheads).

6.2.3. Treatment of Interest Rate Distortions

6.2.3.1. The level and structure of interest rates are critical determinants of: (i) the economic efficiency with which resources are allocated in an economy, and (ii) financial sector viability.

6.2.3.2. By definition, interest rates reflect the opportunity cost of capital in undistorted markets. Interest rate distortions may lead to a misallocation of resources, resulting in forgone national income. Therefore, the removal of interest rate distortions in a country is an important objective of financial sector reform programs supported by ADB-funded FILs.

6.2.3.3. When there are major interest rate distortions in a country (e.g., large interest rate subsidies, pervasive interest rate controls, or policies that cause extremely high interest rates), ADB does not support a program until the country establishes agreed programs to remove or substantially reduce the distortions during implementation of the FIL.

6.2.3.4. Interest rate reforms should be appropriately phased to minimize adverse impacts on the solvency and liquidity of FIs and enterprises.

6.2.3.5. In determining whether there are major interest rate distortions, the following factors should be considered: (i) whether domestic interest rates are administered, are determined noncompetitively, or are affected by the government's fiscal tax/subsidy and regulatory policies; and (ii) when capital markets are open, whether there are significant differences between domestic interest rates and interest rates payable on borrowings of foreign capital (that cannot be explained by prevailing economic conditions).

6.2.3.6. However, under certain circumstances, ADB may support programs that include directed credit or subsidies.

6.2.4. Treatment of Directed-Credit Programs

6.2.4.1. ADB-supported FILs also aim to remove or substantially reduce the use of directed credits, that are similar to interest rate subsidies, as these lead to resource allocation outside market mechanisms.

6.2.4.2. Directed credit programs supported by ADB may be channeled through specialized FIs, particularly those that concentrate their lending in certain subsector market niches for business strategy reasons.

6.2.4.3. In many countries, increasing access to credit by specific sectors (e.g., micro-finance institutions or the rural sector) is a major government policy objective, and some use directed credit to pursue this objective.

6.2.4.4. An ADB FIL may support directed-credit programs to promote sustainable financing for such sectors, provided that the programs are accompanied by reforms to address the underlying institutional infrastructure problems and any market imperfections that inhibit the market-based flow of funds to those sectors.

6.2.4.5. Such reforms include measures to: (i) address obstacles that impede the flow of funds to the credit recipients, or (ii) enhance the creditworthiness of the intended beneficiaries through appropriate approaches such as mutual group guarantees. When such targeted lending is commercially oriented, it is not considered to be directed credit.

6.2.4.6. It is good practice to routinely monitor the contribution of directed credits and their associated concessional terms to the growth of the targeted sector(s) and poverty reduction, taking into account any adverse impact on other parts of the economy.

6.2.5. ADB Policy on Subsidies

6.2.5.1. In some cases, subsidies may be an appropriate use of public funds (e.g., poverty-reduction programs). ADB supports programs involving subsidies only if they:

  • are transparent, targeted, and capped;
  • are funded explicitly through the government budget or other sources subject to effective control and regular review;
  • are fiscally sustainable;
  • do not give an unfair advantage to some FIs over other qualified and directly competing institutions; and
  • are economically justified, or can be shown to be the least-cost way of achieving poverty reduction objectives.

6.2.5.2. Subsidies that do not meet these tests should be phased out, or are substantially reduced, during the course of a FIL.

6.2.6. Eligibility Criteria for FIs

6.2.6.1. ADB requires assurances that FIs, acting as onlenders using FILs and other investment operations, are financially efficient and viable institutions. In particular, they must:

  • be financially sustainable-as represented by adequate profitability, capital, and portfolio quality, as confirmed by financial statements prepared and audited in accordance with accounting and auditing principles acceptable to ADB;
  • have acceptable levels of loan collections;
  • have appropriate capacity, including staffing, for carrying out subproject appraisal (including environmental assessment) and for supervising subproject implementation;
  • have the capacity to mobilize domestic resources;
  • have adequate managerial autonomy and commercially oriented governance (particularly relevant when state-owned or state-controlled FIs are involved); and
  • have appropriate prudential policies, administrative structure, and business procedures.

6.2.6.2. Using these criteria, ADB determines the eligibility of a proposed FI, or it may require an apex institution or other appropriate entity to do so.

6.2.6.3. New and existing FIs that do not meet all the eligibility criteria for being intermediaries may participate in an ADB-funded FIL if they agree to an institutional development plan that includes a set of time-bound monitorable performance indicators and provides for a midterm review of progress.

6.2.6.4. When an FIL includes such FIs, the size and complexity of the FIL should be commensurate with the FIs' implementation capacity; and the FIL may include an institution-building component that the borrower may pass on in the form of grants. Such FIs' continued participation in the FIL is subject to their satisfactory implementation of their institutional development plans; when progress is not satisfactory, ADB considers appropriate remedial action, including suspension.

6.2.6.5. FIs whose performance in relation to eligibility criteria has been unsatisfactory for an extended period of time are required to take substantial corrective measures and to demonstrate improvement before they are permitted to participate in a FIL under an institutional development plan as described above.



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6.3. FI Investments

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