Policy Research Institute OF Bangladesh (PRI)

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Table of Contents

List of Tables...................................................................................................................................i

List of Figures..................................................................................................................................i

Abbreviations................................................................................................................................iii

Fostering Better Financial Inclusion in Bangladesh Through a More Competitive Mobile Financial Services..............................................................................................................1

Introduction................................................................................................................................................................1

Global Progress with Financial Inclusion..................................................................................................................1

Mobile Financial Services Market Structure..............................................................................................................3

Rapid Expansion of Mobile Financial Services in Bangladesh in Recent Years.......................................................4

Reconciliation of Global Findex Data with Mobile Financial Services Data............................................................6

Product Diversification of Mobile Financial Services...............................................................................................6

Bangladesh Regulatory Environment for Mobile Financial Services........................................................................7

Lessons from the Bangladesh Experience.................................................................................................................8

Lessons from the International Experience................................................................................................................9

Recent Reforms Undertaken by India......................................................................................................................10

Regulatory Challenges in Establishing a Competitive Mobile Financial Services Market.....................................11

The Way Forward....................................................................................................................................................12

Institutional Coordination........................................................................................................................................13

References.....................................................................................................................................14

List of Tables

Table 1: Bangladesh Progress with Financial Inclusion in International Comparison, 2014....................................2

Table 2: Mobile Money Schemes: Successes and Failures......................................................................................10

List of Figures

Figure 1: Percent of adults having a financial account..............................................................................................1

Figure 2:The Economics of Mobile Financial Services.............................................................................................3

Figure 3: Gross Number of Agents (000)..................................................................................................................4

Figure 4: Growth of Mobile Money Accounts...........................................................................................................5

Figure 5: Gross Monthly Transactions (mil US$).....................................................................................................5

Figure 6: Mobile Money Account Penetration (%)...................................................................................................6

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Figure 7: Product Composition (%)...........................................................................................................................7

Figure 8: Market Share of Mobile Financial Services Providers (%)........................................................................8

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Abbreviations

BB Bangladesh Bank

BTRC Bangladesh Telecoms Regulatory Commission

BDBL Bangladesh Development Bank Limited

CICO Cash-In/Cash-Out

DBBL Dutch Bangla Bank Limited

GSMA GSM Association

G2P Government to People

ICT Information and Communication Technology

KYC Know‐Your‐Customer

MFS Mobile Financial Services

MFI Microfinance Institutions

MNOs Mobile Network Operators

OTC Over-The Counter

P2P People to People

RBI Reserve Bank of India

USSD Unstructured Supplementary Service Data

USAID United States Agency for International Development

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Fostering Better Financial Inclusion in Bangladesh Through a More Competitive Mobile Financial Services

Introduction

Financial inclusion plays a critical role in reducing poverty and achieving inclusive growth (World Bank 2014; and Curl, Ehrbeck and Hole 2014). Research shows that when people participate in the financial system, they are better able to start and expand businesses, invest in education, manage risks and absorb shocks. Access to bank accounts, savings and payment mechanisms increases savings, empowers women and boosts investment and consumption. Greater access to financial services for firms and individuals may help accelerate growth and reduce income inequality (Demurgic-Kunt and Levine 2009).

In recognition of the critical role of inclusive finance, an increasing number of national governments have taken measures to improve access to and use of financial services. Among bank regulators in 147 jurisdictions a survey found that some 67% have mandate to promote financial inclusion (World Bank 2014). International organizations (such as the World Bank and G20) are formulating strategies to promote financial inclusion.In recent years, more than 50 countries have set ambitious goals and targets for financial inclusion (World Bank 2014).

Global Progress with Financial Inclusion

Measurement is key to understanding financial inclusion, identifying barriers and building on opportunities. The Global Findex Database launched in 2011 has enabled a systematic approach to measuring progress with financial inclusion. The 2011 Global Findex defines financial inclusion as having an account that can be used to store money and receive payments. The growth in global financial inclusion between 2011 and 2014 is shown in Figure 1.

Figure 1: Percent of adults having a financial account

2011 20140

10

20

30

40

50

60

70

51

62

Source: Global Findex 2014

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In many low-income economies financial inclusion through a financial institution (formal banking, credit union, cooperatives or micro finance institutions) is constrained by the availability of infrastructure or cost of service of the financial institution, especially in remote rural areas. With the advent of the ICT revolution and rapid adoption of mobile telephone services, financial inclusion is now possible through mobile phones. In recent years, Mobile Financial Services (MFS) has increasingly become a potent source of low-cost financial inclusion in many countries.

MFS is still at an evolutionary stage. Globally, 62% of the adults reported having a financial account in 2014. Some 98% reported having a financial institution account; 1% reported having both a financial and mobile money account; and 1% reported having only a mobile money account (2014 Global Findex Database). According to the 2014 Global Findex, while only 2% of adults reported having mobile money account globally, in sub-Saharan Africa 12% do. Of this half are mobile money accounts only. All 13 countries in 2014, where the share of adults with mobile bank accounts are 10% or more, belong to sub-Saharan Africa. In 5 of these 13 countries (Cote d’Ivore, Somalia, Tanzania, Uganda and Zimbabwe), more adults reported having a mobile money account than an account at a financial institution.

More recent data suggest that MFS is catching up in Asia, especially in Bangladesh. According to Global Findex 2014, the level of financial inclusion in Bangladesh is modest by international standards. While more recent data, especially in light of recent growth in MFS, might show stronger performance, the scope for progress with financial inclusion is large.

Table 1: Bangladesh Progress with Financial Inclusion in International Comparison, 2014Countries/Regions Percent of adults

with financial account

Percent women with financial

accounts

Adults in poorest 40% of households

(%)Bangladesh 31 26 23 India 53 43 44 Nepal 34 31 24 Pakistan 13 5 11 Sri Lanka 83 83 80 South Asia 46 37 38 East Asia 69 67 61 High Income 94 94 91 World 62 58 54

Source: The Global Findex Database

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Mobile Financial Services Market Structure

MFS delivery relies on two service platforms: (1) Electronic money platform that connects senders and receivers; and (2) Agent platform that enables people to physically put in cash or take out cash from mobile money accounts (cash-in/cash-out or CICO platform). This delivery system involves three actors: senders, receivers and agents. It also involves availability of appropriate technology: mobile phone; mobile phone connectivity; and the data link (typically, the Unstructured Supplementary Service Data or USSD facility).

The Demand Side

The MFS market operates on the principle of easy and low cost access to financial services. Much of the clients are low income in rural and remote areas who need to have easy access to agents and can engage in low-cost financial transactions through their mobile phone. Accordingly, the regulatory requirements for mobile account have to be simple and the financial cost of transaction low. Attracting customers to use mobile money account therefore hinges critically on low-cost transaction options (the ease and low cost electronic money platform). For example a recent USAID sponsored study (Parvez et. al., 2014) found that 91% of MFS users in Bangladesh cite low transaction costs as the most important factor driving the use of MFS services.

The Supply Side

Given the market structure, a typical MFS service provider must have a substantial network of agents spread all over the country and especially in rural areas to provide easy access (the Agent platform challenge). It must also have very low service charge to attract mobile money account users. The platform requires substantial investments. To reconcile this with low unit cost of transactions, the scale of transactions must be large enough to justify the investment. In economist’s parlance, the MFS market is characterized by a decreasing cost curve and a perfectly elastic demand curve at very low unit price of service (Figure 2).

Figure 2:The Economics of Mobile Financial Services

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Critical Role of Ease of Doing Business

A critical link between demand and supply coordination is the ease of doing business, reflected in the MFS Regulatory Requirements. The simpler and less restrictive that the entry/exit rules are, the better are the incentives for service providers to invest and the lower will be the transaction costs. Similarly, the simpler and easier the registration requirements are for customers and agents, the lower will be the transaction costs.

Technology

The technology requirements for growth of mobile money accounts are relatively simple: availability of mobile phones; mobile phone connectivity; and the data platform for transmission of mobile money transactions. The adoption of ICT technology globally has greatly facilitated the availability of low-cost mobile phones and related services in remote parts of the globe. Because of competition among service providers, both voice and data services are now available at a low cost. For mobile money transmission, there are a number of technical options. But the USSD is the most commonly used technical platform. Proper pricing of USSD services and open, unrestricted access to USSD are important regulatory matters to enable a competitive mobile money market.

Rapid Expansion of Mobile Financial Services in Bangladesh in Recent Years

Financial inclusion got a big boost in Bangladesh from the recent surge in mobile financial accounts and transactions, especially since mid-2014. This progress reflected in all three indicators of MFS growth: rapid expansion in number of agents (Figure 3); growth in the number of mobile money accounts (Figure 4); and the increase in monthly mobile money transactions (Figure 5). The growth of gross monthly transactions is truly impressive.

Figure 3: Gross Number of Agents (000)

2nd

Qua

rter

,13

3rd

Qua

rter

,13

4th

Qua

rter

,13

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uart

er,1

4

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,14

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,14

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,14

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er,1

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,15

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,15

0

100

200

300

400

500

600

Source: Bangladesh Bank

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Figure 4: Growth of Mobile Money Accounts

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,13

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35

No. of accounts No. of active accounts

Millions

Source: Bangladesh Bank

It is important to note two important caveats: First, the data on the number of agents is derived as an aggregation of agents reported by MFS providers. These agents are not necessarily exclusive to the reporting MFS provider. Indeed it is quite common for an agent to work with multiple entrepreneurs (at least 2). A second major caveat is that the transaction volume reflects transactions through registered accounts as well as through over-the counter (OTC) transactions. In 2014 an estimated 75% of transactions were OTC type (Parvez et. al. 2014). The Bangladesh Bank rightly discourages OTC transactions as the risk of money laundering, transfers of theft money etc. can be quite serious. Converting OTCs to mobile account based money transactions is a major challenge moving forward.

Figure 5: Gross Monthly Transactions (mil US$)

2nd

Qua

rter,1

3

3rd

Qua

rter,1

3

4th

Qua

rter,1

3

1st Q

uarte

r,14

2nd

Qua

rter,1

4

3rd

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rter,1

4

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4

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uarte

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5

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5

- 200 400 600 800

1,000 1,200 1,400 1,600 1,800 2,000

Source: Bangladesh Bank

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Reconciliation of Global Findex Data with Mobile Financial Services Data

The Global Findex result showing a financial inclusion index of 31% for Bangladesh in 2014 has come under criticism from the Bangladesh Bank in light of the rapid growth of mobile money accounts. There are two ways of reconciling the two: First Global Findex counts only unique accounts. Multiple accounts (adults having bank account, micro finance account and mobile money account) will only be counted once. Second, the survey for Global Findex was conducted in early 2014 and misses out on the rapid growth of mobile money account over the past 18 months (13 million new accounts between March 2014 and September 2015). Assuming that some 80% of the new mobile accounts since the survey are mobile accounts only with no access to any institutional financial accounts (i.e. 10. 4 million accounts, which is a very generous assumption), financial inclusion index rises to 42%.

Bangladesh made remarkable progress in penetrating the mobile financial market (Figure 6). According to GSMA data, some 41% of mobile phone owners (unique subscribers) had a mobile money account in 2015, growing from a low of 22% in 2013. The progress has been particularly rapid between 2013 and 2014. Yet, some 59% of mobile owners do not have a mobile money account, showing the scope for future expansion. When measured against a target of 100% mobile phone coverage of adults (age 15 plus), total mobile money accounts amount to only a modest 27%. According to Bangladesh Bank (BB) data, some 60% of the accounts are inactive (defined as accounts with no activity over a 3 month period). These results clearly show that there is a large unfinished agenda for the MFS.

Figure 6: Mobile Money Account Penetration (%)

2013 2014 201505

1015202530354045

22

3841

Source: BB and GSMA

Product Diversification of Mobile Financial Services

The MFS is still at its infancy stages in terms of product composition. As of November 2015, some 96% of transactions involved money transfers, of which 79% were cash in/ cash out type transactions and 17% were people to people (P2P) transactions (Figure 7). Other products include private salary payments (0.9%); utility payments (0.7%); and others (2.4%). A tiny

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volume (0.03%) also represented inward FE. There are no government to people (G2P) transactions yet.

Figure 7: Product Composition (%)0.025

78.977

17.294

0.9450000000000010.6670000000000052.093

Inward FE

Cash in/Cash Out

P2P

Salary Dis-bursement

Utility Payments

Others

Source: Bangladesh Bank

Bangladesh Regulatory Environment for Mobile Financial Services

The Bangladesh Bank provided a supportive regulatory environment for MFS through the MFS Regulations of 2011. It developed simple and easy to implement guidelines to balance prudential requirements with ease of mobile money account operations. But it also imposed an important regulatory constraint: Only banks are allowed to provide MFS. However, they are allowed to have minority non-bank, non-MNO shareholders. To ensure low-cost transactions it used its moral suasion authority to facilitate the pricing of the mobile phone facility use (USSD) as a certain small percentage of MFS revenues from actual transactions. By preventing Mobile Network Operators to enter the MFS market it also de-facto encouraged unrestricted access to USSD.

Service Providers and Competition

Presently MFS service provision is concentrated among two suppliers (Figure 8). First, BRAC/BKASH is the overwhelmingly large provider accounting for some 81.4% of the total transactions. The second important player is the Dutch Bangla Bank, accounting for 16.8% of the current transactions. The market dominance by BRAC/BKASH partly reflects the dynamism shown by the BKASH who runs the MFS as a BRAC subsidiary. But it also reflects the underlying market structure for MFS and the regulatory environment guiding MFS.

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Figure 8: Market Share of Mobile Financial Services Providers (%)

16.8

81.4

1.8

DBBLBRAC/BKASHOthers

Source: Bangladesh Bank

Several factors explain the rapid growth of BKASH:

Strategic partnership: BKASH was established as a subsidiary of BRAC bank that has a strong rural presence including involvement in MFI.

BKASH is a dedicated BB licensed MFS entity and not a side business of a traditional commercial bank.

BKASH mobilized a large number of internationally reputed equity holders under the management of an innovative and dynamic team with good understanding of both the market and the technology.

BKASH offers a simple easy to use technology that can work with all mobile carriers. The service fee charged is attractive for customers. BKASH has built up a well trained network of distributors and easy access retail outlets. BKASH uses an aggressive marketing strategy that has drawn the attention of rural

customers.

The enabling environment established by BB was especially conducive to the growth of non-MNO led service providers through low-cost and easy access to USSD.

Lessons from the Bangladesh Experience

Within a 4-year period (2011-2015) Bangladesh has experienced a dramatic growth in the expansion of MFS. A combination of enabling regulations by BB and innovative business entrepreneurship by BRAC/BKASH has contributed to this growth. Yet, there is a huge untapped market for MFS. The challenges moving forward include:

First, as noted earlier, only 41% of mobile phone owners have a mobile money account. The scope for further growth is huge.

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Second, the OTC transactions are still dominant and the transition to registered mobile money account needs to be substantially strengthened.

Third, the MFS product penetration is at its infancy stage with heavy concentration of cash-in/cash out and P2P transactions. The full range of financial service potential of mobile money involving savings, service payment transactions, G2P payments etc. remain mostly untapped.

Fourth, the level of activity of existing accounts is also much below potential, with the ratio of active to inactive accounts at only 40%.

Fifth, service provision is concentrated in one large player BKASH (81% market share) and a second smaller player BDBL (17% market share), suggesting that there is scope to foster a faster growth of MFS accounts, services and product diversification with greater competition by removing all entry barriers.

These challenges underscore the strong need for a second phase of MFS reforms.

Lessons from the International Experience

Before embarking on the Second Phase of MFS reforms, it is instructive to look at the international experience. The literature of review of international experience is large. A very competent and useful summary is contained in the Gates Foundation sponsored research done by the University of Chicago researchers (Evans and Pirchio 2015). The other relevant development is the most recent policy reforms undertaken by the Reserve Bank of India in August 2015.

The Evans and Pirchio paper reports results of effectiveness of mobile money programs in 22 developing countries. Results show that MFS programs in 8 countries took off; MFS has made modest progress in 3 countries; failed to take off in 8 countries; and it is too early to call for 3 countries. The sample included 14 from Africa; 5 from Asia and 3 from Latin America (Table 2). The 4 key findings are:

• Heavy regulation, and in particular an insistence that banks play a central role in MFS, together with burdensome KYC and agent restrictions, is generally fatal to the ignition of MFS.

• MFS is more likely to succeed in poorer countries that lack the basic financial infrastructure.• The growth of send/receive and cash-in/cash-out platforms must go together.• Ignition and explosive growth occurs quickly or not at all.

The Research emphasizes that the first result on the regulatory framework is the most robust and important finding.

Key Regulatory Features for Success:

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1. No restriction on MFS ownership, except in Bangladesh that requires bank-led MFS.

2. All countries except Bangladesh allowed mobile network operators to take the lead in MFS

3. Simple regulations for KYC.

4. Minimal restrictions on who could serve as an agent

Key Regulatory Features for Failure:

1. All but one country in this failed group imposed heavy regulations on mobile money schemes.

2. All but one required that banks take the lead role in operating the MFS and prohibited mobile network operators from doing so.

3. Stringent KYC requirements.

4. Stringent restrictions on who could serve as an agent.

Table 2: Mobile Money Schemes: Successes and FailuresIgnition with Explosive Growth

Ignition with Weak Growth

Failed to Ignite Too Soon to Assess Ignition

No basis

Bangladesh Ghana Burkina Faso Democratic Republic of Congo

Paraguay

Cote D’Ivore Philippines Haiti Sri Lanka  Kenya Pakistan India    Rwanda   Indonesia    Somaliland   Madagascar    Tanzania   Mexico    Uganda   Nigeria    Zimbabwe   South Africa    

Source: Evans and Pirchio 2015

Recent Reforms Undertaken by India

In September 2013 the RBI appointed a committee to propose measures for achieving greater financial inclusion and increased access to financial services. This Committee on Comprehensive Financial Services for Small Business and Low Income Households submitted its final report on December 31, 2013. The main recommendation that has implications for the MFS industry concerns the proposal to set up Payments Banks whose primary purpose will be to provide

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payments services and deposit products to small businesses and low income households. These banks will be restricted to holding a maximum balance of Rs 50,000 (US$ 758) and will require minimum entry capital of Rs 50 crore (US$ 7.6 million). The RBI issued guidelines for Payment Banks in November, 2014. RBI granted “in principle” approval for 11 applicants, including 5 mobile operators. In issuing approvals, RBI has rightly focused on innovative models and financial strength of entities rather than on the line of business of parent companies. RBI expects this flexible approach to financial inclusion to greatly increase financial service access and in particular to ignite the MFS services that have been floundering in India. This deregulation by RBI sets up possibly the most flexible and liberal regulatory environment for MFS globally.

The establishment of the payments banks and providing equal access to all potential investors has been generally welcomed by business and research (Kumar and Raman, 2015). To protect non-mobile service providers from any predatory behavior of mobile operators in terms of pricing and access to USSD, the Telecom Regulatory Authority has already issued regulatory guidelines for access to USSD with a pricing cap. Regulations also require that SMSes related to financial services are priced at the lowest tariff offered to any SMS.

While the proof of the pie is in eating, the initial expectation is that the reform will hit the ground running. According to Kumar and Raman (2015), Paytm has over 120 million wallets with average transactions of Rs 10. The payments bank license will allow Paytm to extend to smaller cities and rural areas with a digital model. Reliance will combine the roll out of its low cost smart phones and data coverage with banking services.Telenor has partnered with a new commercial bank to focus on mobile money services in the hard-to-reach northern areas. Almost every new payments bank is hiring data scientists to develop models that will allow lending through mobile phones.

Regulatory Challenges in Establishing a Competitive Mobile Financial Services Market

The Bangladesh experience with MFS has so far been very positive, but as noted earlier there are important challenges in terms of (a) coverage relative to potential; (b) account use; (c) product diversification; and (d) concentration of service provider. The enabling environment provided by BB in 2011 has been highly supportive of this first phase of growth of MFS but needs revisions to address the above concerns and push to the next phase of MFS development. International experience shows that the more flexible the entry regulations, the better the chances of growth and success. The need for greater competition is particularly important to take better advantage of the large untapped MFS market, promote product diversification and innovation, and reduce cost.

Mobile Financial Services Market Structure and Comparative Advantage of Mobile Network Operators (MNOs)

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The review of the MFS market structure highlighted the following important characteristics for the success of MFS operations:

• Ease of electronic money platform• Ease of agent platform• Access to low-cost USSD (or other relevant data transmission mechanism)• A minimal scale of operations to break-even in view of the decreasing cost industry and

highly elastic demand anchored at a very low service price.

Given these features, MNOs have a natural comparative advantage in providing MFS services given that they already meet all these criteria.Commercial banks are not organised to provide dedicated MFS and must partner with a specialized service agency (like BKASH) or partner with MNOs.

Entry Challenges Posed by the Existing Guidelines

While the experience of BKASH in Bangladesh shows that non-MNOs can very much succeed with the right kind of organization, investment and entrepreneurship, by restricting the role of MNOs in the provision of MFS, the present regulations needlessly hamper the further growth of MFS and entry of other viable MFS operators. There is no reason why Bangladesh should not take advantage of the comparative advantage of MNOs and provide a bigger push to the adoption of MFS services, improve competition, and support greater product diversification. Regulations should be enabling rather than disabling. Regulatory focus should be on allowing the different players the flexibility to team up together to optimize on the relative comparative advantages of the banking sector, other specialized enterprises like BKASH and the MNOs, while ensuring a level playing field for all.

The Way Forward

Reforming Mobile Financial Services Entry Regulations

The present BB regulations require bank-led MFS model on fiduciary grounds. International experience shows that fiduciary concerns can be addressed in the context of a more flexible model where besides bank-led, it could also be specialized enterprises (BKASH) or MNO-led MFS. The India reform cleverly blends the fiduciary concerns with flexible service delivery arrangements. Nevertheless, at this stage it may be prudent to stay with the bank-led arrangements but allow bank MFS license holders to partner with any non-bank operator including MNOs in providing MFS services. These partnerships should be market driven based on negotiations between an MFS license holder bank and non-bank service provider. Regulations must not be used to micro-manage this process by imposing equity restrictions on the partners.

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Addressing the USSD and Pricing Issues

The main reason why countries including Bangladesh have restricted the entry of MNOs is a worry that they may have a conflict of interest in that they own the electronic platform (USSD or otherwise) that allows MFS transactions to happen. The fear is that MNOs may take undue advantage of this by either restricting USSD access or setting a high price for this access for non-MNOs, thereby crowding them out of the market. This is an important concern but international experience shows that this is best addressed by the Telecoms Regulatory Authority as a regulatory requirement rather than a reason to restrict the entry of MNOs to a business where they have a comparative advantage.

Presently the Bangladesh Telecoms Regulatory Commission (BTRC) does not regulate either access or pricing of USSD. Instead, these are negotiated arrangements between the service provider and the user. This unregulated approach may come in conflict once MNOs are allowed entry in the MFS market. To protect non-MNO interests, this important regulatory challenge must be addressed upfront. There is considerable international experience on this, including from India, that BTRC can draw upon. The main points are:

The access regulation must ensure unhindered USSD access for all non-MNO service providers.

The USSD pricing should be based on cost-based pricing to the extent technically possible to ensure that MNOs have an incentive to provide adequate quantity of USSD.

A cross-check with pricing in other neighboring countries will help establish a reasonable price.

The established USSD price must be non-discriminatory and apply to all MFS service providers irrespective of whether they are based on MNO or non-MNO ownership.

A grievance redressal mechanism must be established to swiftly resolve any USSD related disputes with provisions for hefty penalty for well-established predatory MNO behavior if any.

Institutional Coordination

The MFS provision involves important regulatory role of both BB and BTRC. The MFS expansion agenda will considerably benefit from adequate institutional coordination between BB and BTRC with BB taking the lead on financial matters and associated fiduciary issues, while BRTC taking the lead on telecomm related issues. This coordination will become especially important when MNOs are allowed access to the provision of MFS. The BB and BRTC may also periodically hold joint consultation meetings with MFS providers to find out industry regulatory concerns and get them resolved on a timely basis.

References

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1. Bangladesh Bank (2011). Guidelines on Mobile Financial Services (MFS) for Banks. Bangladesh Bank, Dhaka.

2. Cull, R. , T. Ehbeck, and N. Holle (2014). “Financial Inclusion and Development: Recent Impact Evidence”. Focus Note 92, CGAP, Washington DC.

3. Demurgic-Kunt, Asli, Leora Klapper, Dorothe Singer and Peter Van Oudheusden. (2015). The Global Findex 2014 Database, Policy Research Working Paper No. 7255, World Bank, Washington DC.

4. Demurgic-Kunt, Asli and R. Levine (2009). “Finance and Inequality: Theory and Evidence.” Annual Review of Financial Economics 1: 287-318

5. Evans, David S. and Alexis Pirchio (2015). “An Empirical Examination Why Mobile Money Schemes Ignite in some Developing Countries but Flounder in Most.” Working Paper, The Coase-Sandor Institute for Law and Economics, The University of Chicago Law School, March 2015.

6. Kumar, Kabir and Anand Raman (2015). “Did India’s Central Bank get Payments Bank Approvals Right?” CGAP, August 27, 2015.

7. Parvez, Jaheed, Ariful Islam and Joseph Woodward (2015). Mobile Financial Services in Bangladesh. USAID, Dhaka.

8. World Bank (2014). Global Financial Development Report 2014: Financial Inclusion. World Bank, Washington DC

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