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The
Central Bank of Nigeria recently issued a 76-page “Prudential
Guidelines for Deposit Money Banks in Nigeria”. Effective May 1 2010,
the guidelines are a key part of the apex bank’s efforts at
strengthening the financial services industry, in the wake of several
shortcomings that have come to light since the global financial and
economic crisis set in. On one measure, the CBN has made a good first
of this goal. The document replaced by the new rulebook,

“Prudential
Guidelines for Licensed Banks”, was only 10 pages thick. So, in terms
of sheer reading effort, the new guidelines do call for considerable
expenditure. Beyond its heft, though, the new guidelines include
provisions on other dimensions of the industry’s operations (risk
management, corporate governance, anti-money laundering, etc.) that
were not even alluded to previously.

One could quibble
at the fact that a number of the additions to the new-look prudential
guidelines are a re-hash of policies the CBN has enunciated of late in
respect of its concern to ensure that banks in the country are properly
run, i.e. in the interest of depositors’ funds. Besides, if the
assignment of ensuring the safety of depositors’ funds and the
stability of the financial system is constructed narrowly enough, then
the main task for prudential regulation is to set proper limits on the
risk appetites of deposit-taking institutions. And this, the old rules
did with some success. So what new things have the new guidelines put
in place?

Basically, the new
guidelines recognise two loan loss provisioning regimes, where before,
there was just one. The “Other Loans” category essentially replicates
the provisions of the old guidelines, with 90 days remaining the
cut-off period for recognising facilities with unpaid principal and/or
interest. However, the new guidelines ease financing conditions for
specialised lending purposes.

Outstanding
obligations are now expressed as proportions of the amounts due, and
the loan-loss recognition periods have been considerably extended. In
this sense, the CBN has only acted to recognise the peculiar life cycle
of the project types that fall under its specialised lending category –
project, object, SME, agriculture, and mortgage financing. All of these
have long gestation periods between when investments are made, and when
they begin to earn revenue, with which they may rightfully meet their
loan commitments. Incidentally, these are also sectors in which the
country has the greatest need, and whose successful financing could
have the greatest multiplier effect on the economy.

That said, I’m not
quite sure the apex bank intended an additional outcome of the new
prudential rules. It would seem that risk managers in the industry had
hoped to obtain some gain from the new guidelines. This would have
happened, if for instance, the apex bank had extended the period for
recognising loan losses across all risk asset classes. Then, a number
of current provisions done in the spirit of the tougher old rules may
have been written back in aid of banks profits. Given the many comfort
arrangements that the CBN has put in place to help banks’ balance
sheets, and the fact that the industry still labours from a liquidity
glut, this was a fair hope. But it turns out that “specialised loans”
are a small portion of the industry’s current loan portfolio. So, the
hoped for gains from extending the period for recognising impaired
loans would be a lot smaller.

Nonetheless, would
these easier terms, not boost the flow of credit to these sectors of
the economy? A re-balancing of credit in favour of project financing
would be consistent with the economy’s need for new investment in
infrastructure, while better mortgage and agriculture financing should
ultimately address needs that are peculiar to the more vulnerable
segments of the economy. Still, it helps to consider why banks have not
felt a need thus far to put their monies in these very useful sectors
of the economy. When a market fails for the provision of any good or
service, it is often because the neighbourhood effects arising from
investing in the provision of such service or good are too dispersed to
generate useful returns for the investing entity, or that too large a
portion of the externalities arising from the investment are negative.

In this case, we
should worry about two things. A legal and infrastructure environment
that remains unhelpful to business, and the banks’ capacity to lend to
these sectors.