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Presentation
on
Unsecured Personal Loan(UPL)Market
Nomsa Motshegare NCRCEO
andJohn Symington Compliance & RiskResources (Pty) Ltd
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M k t id ti M k t h t d
S i l f V l
t d
Introduction
Ideal market conditions Need for Research Macro marketconsiderations
Credit market analysis
Credit supply factors
Social factors
Observations
Regulatory andsupervisory tools
Market changes reportedGrowth in UPLChanges in UPL product Term
ValueReview of impact on consumersDetermine what action to take
The study has focused specifically on unsecured personal loansUnsecured personal loans (UPL) - This refers to loans which are repayable over a period of time
in installments, where there is no security that the credit provider can rely on to recover their debt if
repayments are not made.
For the purposes of this study, other forms of unsecured credit (such as credit cards or overdrafts)
have not been considered.
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Research
NCR workshops Portfolio Committee 2 May
Written findings report May 2012
Facilitate understanding of the
findings Survey reports
Detailed
Summary
Desk top research
Interviews with credit providers -10, multiple
sessions
Consumers
Other Regulators 1 workshop
Industr associations 3 worksho sFocus groups - reliance on other research
Referencing of other surveys conducted
Analyses of other recognised data
Project Overview
Information to follow for report in May 2012 4 Credit Providers batch extracts of the customers credit bureau profiles with the assessments and
data held on file FinScope National Surveys 2008 to 2011 analyses
Credit agreements analyses
Disaggregate factors and drivers
Further study planned
Retail and smaller lenders
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Eff i l i
IdealMarketConditions
Condition Considerations
Healthy suppliers Credit roviders reflectin ositive rowth rofit and reserves Product mix
Healthy competition, betweencredit providers and sectors
Variety of suppliers and market niches/segments
Broad geographical footprint
Access to fundin for smaller credit roviders
Scale of operations large vs. small
Informed consumers Numerous information and education initiatives Challenges in achieving real changes in consumerbehaviours
Effective regulation NCA inplace Some gaps in regulations being addressed
Effective supervision NCRin place and consumer protection mandate established
Gearing ofNCRto next phase ofdevelopment
Improving credit health ofconsumers
Increased employment and improving household income to debt ratios
Substantial level of impaired performance reflected at credit bureaus not
only a function ofdebtservicing
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Cred
it
Portfoli
o
Considerations
CreditProduct
Overallgrosslendingbook
Considerations
Steady increase over the last year to Dec 2011 = 9.0% (NCR statistics)
Higher than inflation growth Structural change with growth in unsecured lending
Mortgages book Constrained growth over the last year to Dec 2011 =4.0% (NCR statistics)
Mortgage lending less attractive to credit providers Legal uncertainty in terms of risk mitigation options Debt review process challenges Housing market demand, no title deeds in informal, prices, Loan to value ratios risk of equity less than outstanding mortgagebalances Basel III Capital and liquidity considerations Contracting for long terms 20 years, at fixed, invariable price with limitedscope to
reassess and reprice for current and changing risk profiles
100% now not generally provided
Unsecured personal loans book
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Stron
g growth over the last year to Dec 2011 = 53.1% (NCR statistics,includes credit providers not previously reported)
Growth off a small base Higher margin than secured products Effective pricing for risk, shorter terms Ease of loan advance
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Mortgages growth
Unsecured credit growth
UPL can not be
Structural change in the market
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Cred
it
Marke
t
Analysis
Mortgages remain thedominant credit category
Business opportunities in UPL
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Cred
it
Marke
t
Analys
is
UPL
Year on Year Growth
Number 3.1%
Rand value 52.1%
0% 20% 40% 60%
Strong growth in loan values granted
Growth in number of accounts relatively low
Indication of average balance of loans granted increasing Consolidation of loans impact not quantified as yet
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s
Millio
ns
Cred
it
Marke
t
Analys
is
UPL
4.0
Number UPL Applications vs Approvals
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0.0
Mar 10 June 10 Sept 10 Dec 10 Mar 11 June 11 Sept 11
Applications
Approved
Demand for credit reflected in the applications for UPLs
Different profiles according to different organizations Business models / strategy Ratio of approvals to applications made overall increase over the year
Loan approval to application trend 55% in Q1 2010 to 57% in Q4 2011
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Some credit providers increasing others decreasing
Note: not all approvals are taken-up8
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R100k
Cred
it
Marke
t
Analys
is
UPL
Majority of UPL still in < R15k category
Steady decline in < R15k category as a proportion of overall
UPL book - Growth in other categories
Spike in R60k R100k Recent relatively strong growth
Lending in > R150k not significant
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Billio
ns
Cred
it
Marke
t
Analysis
UPL
2.5
Analysis of UPL Granted According to Loan Size Across TermCategories
2.0
1.5
1.0
0.5
0.
0 < 6 712 1318 1924 2530 3136 3748 4960 >60
R0R15 R16KR30 R31R45 R46KR60 R70K R100 R101K R150 R151K R180 > R180K
Shorter term made up of smaller loans
Longer term made up of larger loans
Majority of loans written in R31k to R180k categories
Growth in larger loans
Installment affordability focus of consumers
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Cred
it
Marke
t
Analys
is
UPL
Rates reflect gross income without cost allocation
Range of prices offered by credit providers
Low end average Upper end average
Pricing for risk
Determinants of risk
Price insensitive product in some categories
Consumer considerations
30.0%
25.0%
20.0%
15.0%
10.0
%5.0%
0.0% Interes
t
Ratesp
er
Loan Size
25.7% 26.2%23.1%
21.7%19.7%
16.1% 15.8%
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R fl j it f i t t
13.7%
23.5%
Revenue
flowsmajority
frominterest
Significant contributions from
Initiation fees
Service fees
Significant contribution from credit life
Cross subsidization
Consolidation
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Compliance & Risk Resources
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Cred
it
Marke
t
Analys
is
UPL
Caution in relying on the above picture Credit provider statistics on the basis of what consumers
indicate at the time of entering into an agreement
Range of responses from credit providers
Indications are that credit is used for both consumption and wealth creation purposes
Usage varies at different levels of the market Consumer level research will be required to determine usage profile
Consolidation could be due to positive lower cost alternate as well as debt stress
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40%
75.2
%
73.9
%
74.9
%
76.1
%
74.8
%
72.6
%
71.2
%
73.3
%
73.4
%
74.8
%
75.7
%
76.9
%
76.2
%
75.9
%
75.4
%
UP
L
Performanc
e
Book
90%
Unsecured credit book
90%
80% 80%
70% 70%
60% 60%
50% 50%
40% 40%
30% 30%
20% 20%
10% 10%
0% 0%
Rand Value Number
.6%
.7%
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70.
78.
UPL Book Reported as Current 13Compliance & Risk Resources
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s Overdue >120 dayss Overdue >120 days
R16k
Billio
ns
Billio
ns
UP
L
Performanc
e
Book
R30
R25
R20
R15
Age Analysis per AgreementSize
Overdue >120
days Overdue120 days
Overdue 90
days
R40
R35
R30
R25
R20
Age Analysis per Income ofClients
Overdue >120
days Overdue
120 days
Overdue 90
days
R10
Overdue 60 daysR
15
Overdue 60 days
R 5 Overdue 30
days
R 10 Overdue 30 days
R 5R 0 CurrentR
0
Current
September 2011 statistics
Level of overdues in smaller loan categories
< R15k R16k R30k
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Analysis of income categories
Overdues relatively high highest in R3,5k to R15k
categories
Longer term balances relatively low
New credit granted lag effect
Education campaign should focus on middle to lower income
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Cred
it
Suppl
y
Factors
Factors Considerations
Compliance Structure and operational culture Agreements, disclosures, affordabilityassessment
Credit Provider
Categories
Infrastructure andresources
Scale Access tofunding
Traditional Bank
Micro-Lending
Risk management frameworks and processes andsophistication
Bank
Busine
ssmotive
Paymentsystem
Marketing
to consumers Footprint
Return on
investment /equity, foreignfunding sources Business model bank, microlending bank,microlender, other Advent of NCAand trend settingled the way tofurther business re
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Risk management frameworks and
L l l i
UPL
Distinctionbetweenpoverty
andaffordability isrequired
Categoriesof credit
provider affected differently by payments system Pin and card practice Implications of debt review process with payments viaPDAs
Marketing activity on unsecured lending Volume of credit bureau enquiries
Micro-Lender
Retail Lender
Small Lender
Unregistered
Informal
Level playing
field
considerations
require attention
Credit Comprehensive current credit information at credit bureausassessment andextension
Validation of consumer income and expenses Ability of credit providers to provide information to credit bureaua
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Interi
m
Findings
Findings to Date Commentary
Credit growth: Overall gross debtors book reflects steadygrowth 9%
yony, which is higher than inflation Strong growth in UPL off a small base, nowrepresents8% of overall lending book
Restrained growth in secured lending dueto structuralconsiderations
Increasing level of UPL values reported ascurrent
Information furnished by credit providers has notbrought immediate overall industry level lendinggrowth concerns to light
The diversified lending portfolios of large banks is arisk mitigant at organisational level
Differentiation between categories of credit providersis required to understand category determinants
Monitoring of consumer indebtedness where UPLs areadvanced at the margin to provide credit marketindicators
Changing Market: Project has focused attention of stakeholders in anintegrated
Complex market drivers
The responsibilities of regulatory /supervisoryauthorities overlap
Reactive and disparate response tochanging market
Savings versus credit use
approach to understanding and addressing appropriate
response
Integrated regulatory / supervisory response frameworkwill promoteholelistic view of the market
Review of savings incentives is required
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Restrained growth in secured lending due to structural understand category determinants
C l k d i
C dit li d f lti l i tit ti i
Credit supply: Different organizations, business modelsand deliveryplatforms
UPLs offered have contributed to access to
credit Credit supplied from multiple institutionsincreasesthe risk of default
Commercial credit not suitable for allconsumers
Segmentation of credit providers is needed to assesscredit supply from a consumer protection perspective
Analysis of supply and demand factors according tostrata and recommendations for appropriate accessand relevant interventions
Consideration should be given to alternate supportmechanisms guarantee fund, support, social lending
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17omp ance s esources
Findings to Date Commentary
Credit is being used for bothconsumption and asset/wealthbuilding
credit survey to determine consumer creditusage and the implications thereof
Loan term:There has been some lengthening of the term
over which
Consideration should be given to introducingconsumer protection where lending is undertaken atthe margin
Consumer demand: Knowledge levels and inappropriateconsumerdecision drivers contribute to unhealthycredit uptake
Lack of understanding of the implications of
Segmentation of consumers is needed to assess thecredit supply and usage thereof
Segment appropriate education, starting at school level Monitoring for consumer protection will provide ongoingindication ofconsumer behaviour
Financial burden: Factors beyond credit consumptioncontribute to
Factors that impact consumers that take out creditat the margin should be monitored Creditperformance, write offs, ageing
Reckless lending: Input provided by industry stakeholders
indicates thatreckless lending is a factor that requires
ongoing focus
Limited review of credit agreements indicates that thecredit providers that participated in the study applied
A study into the overall level of consumerindebtedness would provide the macro viewneeded
Rules based guidelines are not recommended A
Interi
m
Findings
affordability, but these are not consistent across credit
providers
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Interi
m
Findings
Findings to Date Commentary
Cost of credit: Disclosure of cost of credit requires attention Cost of credit positively impacted by low
repo rate
Installment focus by consumers as opposedto thecomponents of cost of credit Interest, fees,credit life
Risk based pricing is offered by creditproviders
UPL lending at the margin represents ahigher risk
Where consumer behaviours is purely driven by theamount of the instalment on a loan, this is notoptimal
Integrated efforts across regulators / supervisors andindustry would be needed to change consumerbehaviour
Further research is needed to establish the factorscontributing to the
from a supervisory perspective tipping point into over indebtedness
Marketpractices: Compliance culture and market practices Consumer complicit in taking on too muchcredit Some disclosure much improved followingNCA
Credit life:
Credit life insurance generally required inrespect ofUPL applications
Both UPLs and credit life products are provided by thesame staff members of credit providers
Cost of credit life insurance to consumers a significantcomponent of the overall cost of credit in respect ofUPL
Credit life cost is disclosed separately from other costsof credit
Credit life products are used to mitigate risk by creditproviders
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S di l h i d f ll i NCA
Analysis and monitoring, combined withcomprehensive consumer education
Consider developing method to addressensuring sufficient buffer
Revenue streams from credit life productsincrease access to credit in that creditproviders
Enhanced disclosure of credit life costs wouldprovide consumers with clearer
understanding of the overall cost of credit Level of credit life insurance taken up byconsumers requires consideration
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NC
R
Regulatory/Supervi
sory
Tools
Laws Build on NCA mandate
Regulations
Directives and
guidelines
Supervisoryrequirements
Enhanced supervisory approach
Address loopholes iron reckless lending
Risk based framework
Cooperation with other stakeholders
Review regulatory frameworkCompliance reports
Assurance engagements
Corporate governance
requirements Treating
Customers Fairly initiative
Investigations and
inspections Enforcement
Moral suasion Market
surveys Stakeholder
engagements
Consumer communication and education
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l i
Priorities consumer surveys
Enhanced consumer education
National conversation
regarding lifestyle spending
and consequences of over-indebtedness
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Project Journey
Review of supply side information has not raised unexpected concernsReport on project work during May 2012 Further review work in progress
Further review of consumer related factors is required
Thank You.
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