Marketing Topical Research Paper

Global Marketing Topical Research Paper Chu Nguyen Binh – DBA Hanoi NorthCentral University (NCU), USA National University of Hanoi (Vietnam) August 2009 Research title: Where would be the market for foreign banks in Vietnam after joining WTO? ABBREVIATION BTABilateral Trade Agreement CARCapital Adequacy Ratio FBBForeign Bank Branch FIBForeign Invested Bank JSCBJoint Stock Commercial Bank JVBJoint Venture Bank MOFMinistry of Finance NPLNon-Performing Loan SBVState Bank of Vietnam SOCBState Owned Commercial Bank SOEState Owned Enterprise SMESmall and Medium-sized Enterprise SSCState Securities Commission WBWorld Bank WTOWorld Trade Organization TABLE OF CONTENTS ABBREVIATION ABSTRACT 1. INTRODUCTION1 2. VIETNAM BANKING SECTOR – A SUMMARY1 3. CHARACTERISTICS OF THE VIETNAMESE BANKING INDUSTRY3 3. 1. Very Low Market Penetration3 3. 2. Rate of Growth in Both Loans and Deposits Far Exceeding GDP Growth3 3. 3. A Highly Concentrated but Highly Fragmented Banking Market4 3. 4. Heavy Handed Regulation with Restrictions on Foreign Banks5 3. 5. Lack of Transparency Concerning Quality of Lending6 3. 6. Heavily Undercapitalized7 3. 7. Narrow Revenue Base and Few Product Offerings7 3. 8. Unknown Quantity of Non-performing Loans8 4. BUSINESS ENVIRONMENT FOR THE BANKING SECTOR9 4. 1. The Government’s Strategy9 4. 2. State Bank of Vietnam – Freeing the Tiger9 4. 3. Regulatory Environment – Meeting International Standards10 4. 4. Developing the Capital Markets11 5. PROSPECTS FOR BANKING SECTOR GOING FORWARD12 5. 1. Non-Performing Loan Ratios to Rise, But Risks of Bank Failures Looms12 5. 2. Further Development Inhibited by Low Capital and Technology12 6. CONCLUSION14 REFERENCES15 ABSTRACT Vietnam’s banking system is dominated by five state-owned banks, with around 70% of system assets at end-2008. Around 38 private banks comprise roughly another 25%, with the balance substantially accounted for by a host of foreign banks. In recent years, the private banks, being more commercially oriented, have grown rapidly at the expense of the state-owned banks’ market share. The foreign banks have also grown, as opportunities improved for them after Vietnam entered a bilateral trade agreement with the US in 2001 and acceded to the World Trade Organization (WTO) in 2006. The Research Paper will examine the Vietnam’s banking sector as a whole, including general characteristics of the Vietnamese banking market. It then analyzes the proportion in term of loan and deposit of state-owned, joint stock, joint venture and foreign banks. In the second part, the report lists opportunities for foreign banks to penetrate the Vietnam market under new legal requirement of the Vietnamese Government. They can establish 100% foreign bank entity, purchase stake in local banks or set up joint venture with Vietnamese partners. Finally, it will examine strengths and difficulties in terms of technology, expertise and experience, service quality, risk appetite, etc. f the foreign banks when operating in Vietnam market. 1. INTRODUCTION There are a lot of banks in Vietnam. Too many in fact. Currently there are five state-run commercial banks, 38 joint stock commercial banks, four joint-venture banks, 29 foreign bank branches, 45 foreign bank representative offices, five finance companies and nine finance leasing firms operating in Vietnam. Since 1992, Vietnam has moved to a diversified sys-tem in which state-owne d, joint-stock, joint-venture and foreign banks provide services to a broader customer base. However, the four main state-owned commercial banks – the Bank for Investment and Development of Vietnam (BIDV), the Bank for Foreign Trade of Vietnam (Vietcombank), the Industrial and Commercial Bank of Vietnam (Incombank) and the Bank for Agriculture and Rural Development (VBARD) account for around 70% of all lending activity. In a trade agreement with the United States signed five years ago, Vietnam fully committed to allow in foreign banks by 2010 at the latest, and to expose the banking sector to foreign competition. Under WTO entry rules the door may have to be opened even sooner than that. This has prompted foreign banking groups to closely scrutinize the Vietnamese banking sector as a business opportunity in itself. 2. VIETNAM BANKING SECTOR – A SUMMARY Vietnamese banking market is currently dominated by the five major State-Owned Commercial Banks (SOCBs), with 38 semi-private so-called joint stock commercial banks (JSCBs) gradually eating into their market share by better catering to the needs of small and medium-sized enterprises (SMEs) and retail clients. Years of lax monetary policy focused on supporting export-led GDP growth has flooded the banking system with money, pushing up redit growth to an annual average of 36. 4% over the past five years (2003-2007), hitting a peak of 54. 9% last year according to World Bank figures. High liquidity and a scramble for market share have resulted in a degree of aggressive lending, in particular to investments in the real estate and stock markets, which both experienced rapid downturns in 2007 and early 2008. State-Own ed Commercial Banks: The five SOCBs – Agribank, Bank for Investment and Development (BIDV), Vietcombank, Vietinbank and Vietnam Development Bank – hold roughly two thirds of banking assets according to IMF sources. The SOCBs are still encumbered by their previous role as instruments for implementing government policy. Indeed, the strong links between senior bank executives and the ruling Communist Party of Vietnam, and other state-owned enterprises (SOEs) have impeded much-needed corporate restructuring. Hence, SOEs still receive preferential treatment in loan allocation, resulting in the SOCBs running up high non-performing loan (NPL) ratios. The SOCBs are currently reporting NPL ratios of around 3%, but we are expecting this figure to rise to 5% before the end of 2008. However, we carry doubts about the reliability of official figures and suspect the real ratios could be significantly higher. Joint-Stock Commercial Banks: The 38 JSCBs presently control roughly 20-25% of banking assets in Vietnam, but are quickly eating into the market shares of the larger SOCBs by providing superior services to SMEs and retail savers. The JSCBs are generally better managed and more profitable than the SOCBs, but suffer from low capitalisation, which has made them vulnerable to Vietnam's domestic ‘credit crunch', prompted by the SBV's rapid tightening of its monetary policy. Foreign Banks: HSBC and Standard Chartered and a number of other foreign banks are already present in the Vietnamese market through joint ventures with JSCBs. HSBC increased its stake in Techcombank to 20% in August and Standard Chartered raised its stake in Asia Commercial Bank (ACB) to 15% in May 2008, but foreign banks have been prevented from increasing their stakes by restrictions on foreign ownership of domestic banks. Vietnam currently limits the shareholding a foreign bank can take in a domestic counterpart to 20%, with the total foreign ownership limited to 30%. 3. CHARACTERISTICS OF THE VIETNAMESE BANKING INDUSTRY . 1. Very Low Market Penetration There are only about six million bank accounts in Vietnam, five million of them for individuals which amounts to a penetration rate of about 6%. In reality, the effective potential market size is about 20 million or trebles the current penetration level. That is the size of the AB socioeconomic class in Vietnam. Even so, if we comp are this to the internet and mobile penetration rate of 14% and 12% the number is rather low. The reason is simple: the distribution and infrastructure of banking services is very poor relative to the telecommunications industry, which has virtual national coverage. By contrast, banks are almost unheard of in secondary cities and rural areas. With a low urban population of about 29%, banks simply don’t have easy access to over 70% of the population. There are other reasons, of course. Until recently the government had encouraged a cash economy by paying state employees in cash; there is a traditional distrust of banks; the banks themselves have done a poor job of providing services to the retailing public; and small businesses too are poorly served by banks unwilling to give them large loans unless they have the collateral to back it up. Of course the banking industry is growing rapidly with both deposits and loans expanding at high, double-digit growth rates per annum. And some banks such as Vietcombank, ACB, Sacombank, and Techcombank are making a determined effort to court the retail market. 3. 2. Rate of Growth in Both Loans and Deposits Far Exceeding GDP Growth Credit growth in Vietnam has been expanding at a breakneck speed these last few years. Not surprisingly given heady GDP growth. Nonetheless, the sustained rate of increase over several years has raised eyebrows at international bodies such as the IMF and World Bank. They like their credit growth at room temperature, rather than piping hot. Well piping hot is what they’ve got. In fact, the state-owned banks saw credit grow at an annual average rate of 24% over the past five years. Given the inability of some bankers to distinguish a good credit risk from a bad one (assuming they have a choice) this is not entirely a good thing. Hence the international sigh of disbelief that such stellar credit growth has been accompanied by a falling NPL ratio. According to some economists a 7% GDP growth rate can accommodate an annual credit growth rate of about 14-20%, roughly a factor of two without generating a lending bubble. However, credit growth rates above that level for any extended period of time are unhealthy for an economy. Admittedly credit growth rates have been falling for the last year down to about 15% as the central bank has tried to rein in credit departments. So far this year in fact lending has expanded at only about 16% nationwide. Going forward the speed of credit growth may well start expanding again as WTO becomes a reality. One bank has forecast that credit could grow at 35% per annum over the next five years given sufficient access to capital. While the better banks could probably cope with this, the temptation for others to take on too much risk is high. 3. 3. A Highly Concentrated but Highly Fragmented Banking Market Five state banks have carved up 70% of the loan market while forty-odd joint-stock banks and a host of foreign banks scrap for the remaining 30%. Compare this with the US where the ten biggest commercial banks control only 49% of the country’s banking assets, up from 29% a decade ago. Thus, at the top tier, the market acts like an oligopoly, while beneath the surface there is a holy war going on as mite-sized private sector banks scrap for the rest. Since the market itself is growing so fast this may not seem so bad. The state banks are also slowly bleeding market share. Even so things look very lopsided. Enter the State Bank of Vietnam (SBV), concerned about the fragmented nature of the private sector banks. They will introduce new regulations to force another round of consolidation in the near future. One way of doing this is to set high hurdles for any new established bank before it can get a license. All banks will need to have chartered capital of VND 1 trillion ($62. 8 million) which is exceeded by the existing capital of only the very biggest JSCB’s such as ACB and Sacombank. All other existing banks fall far short and will need to scramble for new capital or merge in order to meet the new requirements. And that is just the first round. From next year the SBV has circulated a draft proposal to raise the minimum capital level to about US$300 million. And there you have the consolidation trigger. 50% of the JSCB’s face merger or takeover. They will also have to demonstrate experience in banking governance. Banks will need to commit to Basel 2 standards from 2010. One of the key issues is the regulation of key stakeholders, such as a bar on lending to stakeholders or their affiliates. This is to prevent corporations from using their own banks as private piggy-banks. Currently a corporate of family can own up to 40% of a joint-stock commercial bank. 3. 4. Heavy Handed Regulation with Restrictions on Foreign Banks The government still exerts strong control on the banking sector in two ways. Directly, through various regulations and restrictions which govern how they conduct business and strictly licensing the type of businesses they can enter; and indirectly through the interference of a myriad of agencies and ministries, both local and national, who want to have a say on how scarce credit resources are allocated. The state-owned banking system is trying to shift from directed policy lending to a commercial system. But the transition is proving slow and painful. Given the legacy of state control at both national and local level it’s hardly surprising that the state-owned banks routinely complain about interference in their lending decisions and overall management. It seems that banking is too important to be left to bankers. The culture of social and political lending is still dominant amongst local officials and bureaucrats, as is the idea of consensus building and consultation before decisions are taken. To be fair, the problem has been recognized and things are getting better. With the proposed re-organization of the SBV for example, fewer local branches should reduce the amount of day-to-day noise coming in to credit departments. Local authorities will have less leverage in leaning on banks without the local central bank office to back them up. And the recently announced decree allowing for 100% foreign-owned bank branches will finally set the stage for a level playing field for foreign banks. However, without eliminating limits on branch openings and mobilization of Dong deposits (currently limited to 350% of total capital for foreign banks) some painful shackles will remain. . 5. Lack of Transparency Concerning Quality of Lending Lending decisions in Vietnam are still based more on relationships than cash flow. The assessment of loan customers is usually driven by the relationship with the bank and the size of the collateral being offered. Cash flow driven assessment and qualitative analysis is reserved for large private sector customers only. Amongst t he large banks only ACB bank uses DCF analysis across their entire customer base. The problem is partly due to outside interference in the decision making process and partly due to a lack of professional guidance. The absence of IT infrastructure to support professional credit analysis is another major factor. Another issue is exposure. Most banks lend a lot of money to a fairly narrow base of customers. The top 30 state-owned corporations probably account for over half of the state banks lending books. The private sector joint-stock commercial banks (JSCBs) are no different. 3. 6. Heavily Undercapitalized One of the legacies of state ownership is a severe shortage of capital at the state banks, a quality shared by private sector commercial banks as well. Government restrictions on equity holdings combined with a bond market that hardly functions has made raising chartered capital very difficult for banks. Average capital adequacy ratios (CAR) in amongst Vietnamese banks stood at 4. 5% at the end of 2007. This compares with an average CAR of 13. 1% in Asia Pacific and 12. 3% in South-East Asia. Admittedly with large scale raising of capital this year this number is improving. With most of the state banks well below the minimum 8% capital adequacy ratio for Tier 2 capital, lack of access to the international capital markets has constrained their growth. And this valuation is anyway based on a vary generous reading of their NPL’s. The JSCBs are in only a slightly better state with a handful able to cross the 8% hurdle rate. The rest are pitiful. And given that the domestic capital markets are still in the fledgling stages, raising new capital has been the biggest headache for all banks. The stronger JSCBs have responded partly by selling shares to foreign strategic partners. Further down the line, where profitability is lower and capital particularly skimpy the options are more limited. The SBV is chary of allowing smaller anks to raise capital from foreign investors. Going forward all of the banks have substantial appetites for raising further capital, to shore up their Tier 2 capital base to bring them over the 8% CAR hurdle by 2010. 3. 7. Narrow Revenue Base and Few Product Offerings Most Vietnamese banks make money from loans. And that’s basically it. Compare that to Western banks that make about a quarter of their income from fees – credit card fees, lending fees, arranging fees, etc. – and most have branched into wealth management. Well, not in Vietnam. To be fair this is tied into the lack of availability of credit history: banks don’t like lending to strangers they know nothing about. The state banks are generally geared to the large corporate and state-owned sector, providing syndicated loans for utilities, infrastructure projects, heavy industry and property developers. JSCBs are geared mainly towards lending to small and medium sized enterprises (SMEs) and the wealthier retail customers. However given their low penetration and limited branch network they only reach a fraction of their potential customer base. Car loans, mortgages and house improvement loans are retail staples. And small business loans using property as capital is the basic model for the SME market. In general, the Vietnamese banking model is best described as relationship-based rather than product-based as in international banks. 3. 8. Unknown Quantity of Non-performing Loans If you were to believe the State Bank of Vietnam (SBV) statistics the non-performing loans problem has been largely dealt with since 2000. Amongst the state-owned banks, non-performing loans (NPLs) have fallen steadily from 12. % in 2000 to 8. 5%, 8. 0% and 4. 47% in 2005, 2006 and 2007, respectively. Under a new stricter definition, the official number in 2008 has risen to about 7. 7%. Overall, about half of the NPL’s are on the watch list, which is the second of five lending categories in the new SBV scoring system. The other half fall into the three categories below watch list which are of greater concern. For private sector JSCBs, average NPLs were said to be around the 1% level at the end of 2007. Of course few believe the official numbers. International bodies carried out a similar exercise using Ernst & Young and found that NPL’s in the system using international accounting standard definitions came to about 15-20% of outstanding loans in the state-owned sector. This number is conservative due to limited data; a figure between 20-25% is probably a fairer estimate. In this respect the slow development of the banking industry is a blessing in disguise, things could be a whole lot worse. The worry is that the gap between the official version and the real picture is large and may indeed be growing. Most NPLs are generated by state-owned enterprises (SOEs) refusing to pay their obligations to state-owned banks. Pre-equalization is a favorite time to write off or simply clear out these loans. That way SOEs can start their new life in the private sector unencumbered by debts. So apart from asking the government to honor the SOEs’ commitment and trying to seize collateral there is precious little banks can do. There is not yet an effective secondary market for bad debt, although attempts to kick-start one are ongoing. There are very few NPLs sale and purchase transaction taking place. 4. BUSINESS ENVIRONMENT FOR THE BANKING SECTOR 4. 1. The Government’s Strategy After a long period of hesitation and hints of action the government has come up with a fast-track roadmap to liberalize the financial sector by 2010. Under the roadmap, the state will retain a controlling stake in the banks but its holdings will be quickly reduced to 51%. Foreign ownership will account for a maximum of 30% of total shares, while each strategic foreign institutional investor currently allowed to hold 10-20% at most. The 20% limit may be eventually erased but the 30% cap will stay for the time being. Basel 1 will be in effect until 2010, when the stricter Basel 2 standards for corporate governance will be introduced. The government will have to introduce further legislation before then to force banks’ compliance, particularly at the ownership level. This may create some buying opportunities amongst the JSCBs as families are forced to reduce their stake. 4. 2. State Bank of Vietnam – Freeing the Tiger In theory the central bank enjoys a wide remit. In practice it can’t do much without a legion of agencies and ministries throwing in their penny’s worth of advice. The central bank, the SBV, currently acts as the sole supervisory and regulatory body for the banking sector. It also owns the state-owned banks and sets interest rates. There is a clear need to separate the various roles of the SBV and give it increased autonomy in those areas such as monetary policy and regulation of the banking sector, which are clearly in its remit. The SBV also needs to be free of its role as custodian of the state’s shareholdings in the banking sector. The SBV sees several key roles for itself in the future: compiling and executing monetary policy, ensuring stability of the credit institutional system, act as a regulator to the banking system. In order to achieve this it needs legislative backing to clearly define its relationship with the National Assembly, government and all government agencies. In simple terms stop the incessant interference from other parties so that the SBV can get on with the job. After all, if the central bank is not allowed to set interest rate policy and regulate the banking sector without being leaned on, what hope is their for individual banks to lend money without getting the same treatment. Another issue is the lack of cooperation with the MOF on key issues such as bad debt and bank equitisation. MOF has often written off state-owned companies’ bad debt without consulting the banks. And the State Securities Commission (SSC), the stock market regulator often stalls on issuing licenses for banks to list. The two don’t play well together. 4. 3. Regulatory Environment – Meeting International Standards There are a myriad of regulations and decrees covering almost every aspect of the financial sector but we would like to look briefly at just three topics: progress removing restrictions from foreign banks, meeting international banking standards and the treatment of NPLs. With regard to meeting international banking standards, the government has appeared to follow WB recommendations to provide the necessary framework for an integrated financial system as required under WTO rules. And so in the last few years some of the necessary legislation has been pushed into place. On the NPL’s, the central bank issued Decision No. 93 to reclassify bad debts and risk reserves closer to international norms. So far, three state-owned banks (SOBs) claim to have successfully reduced their bad debt ratios to less than 5% in accordance with the new rules. Too successfully in fact, but more on this later. Overall the regulatory authorities are making an effort to converge with international stand ards in the financial sector, but with WTO membership and the 2010 deadline looming, time is not a friend. And foreign banks are still allowed to raise Dong deposits only to a ceiling of 350% of their chartered capital. In effect this locks them out of the domestic deposit market and is the most important impediment for their expansion plans. 4. 4. Developing the Capital Markets Banks need more tier 2 capital and bonds will provide the bulk of that. However with the bond market in its infancy there are still major constraints on the banks’ ability to raise sufficient capital quickly to reach the 8% capital adequacy ratio they crave. The infrastructure for developing the bond market is still not in place. HSBC is only now offering to provide a pilot rating scheme to enable potential investors to gauge the creditworthiness of various bond issuers. Fitch and Moody’s have also dipped their toes in the market, rating Sacombank and BIDV respectively. However rating services are horribly expensive and there needs to be a domestic agency to offer these services at prices most banks can afford. Another key hurdle lies with interest rate guidelines in place at all maturities along the yield curve. This prevents risk weightings and effectively bars smaller or weaker banks from coming to the market to issue capital whilst compensating for the higher risk by offering higher coupons. 5. PROSPECTS FOR BANKING SECTOR GOING FORWARD . 1. Non-Performing Loan Ratios to Rise, But Risks of Bank Failures Looms It is likely that there will be an increase in non-performing loan (NPL) ratios from the present 4-5% as an increasing number of companies and households default on their loans on the back of higher interest rates and slowing economic activity. A complicating factor in assessing the risk posed by deteriorating loan portfolios is that Vietnamese banks are currently applying a new system of internal credit rating schemes and debt classification systems in accordance with international standards. Implementation has so far been diverse between banks, making intra-sector comparisons a complicated business. Consultancy Ernst & Young has estimated that the application of the new standards is likely to lead to an increase in disclosed NPL ratios of 2-3 times, i. e. to the IMF estimates of 15-20%. While the new standards will make the NPL figures more internationally comparable, the resulting increase in the ratios is likely to create uncertainty about the proportion which can be attributed to the new standards and how much is down to an actual deterioration of loan portfolios. However, it can be believed that the effects on the overall economy from possible bank failures can be contained by larger JSCBs taking over smaller banks pushed to the brink by loan defaults and low capitalisation. Nonetheless, there might be possibility that the government or central bank will need to intervene to force mergers between banks and possibly also recapitalize those in worst health. 5. 2. Further Development Inhibited by Low Capital and Technology Consolidation should be a positive for the banking sector by decreasing excessive competition and increasing capitalization levels. Nonetheless, capital shortages, low technology and a shortage of skilled staff, especially at higher levels, will continue to inhibit the development of the banking sector. This will leave domestic banks exposed to the might of international banking giants such as HSBC and Standard Chartered, which are initially committing US$183 million and US$61 million respectively to their Vietnamese subsidiaries, placing them well in league with the larger JSCBs. Increased competition from foreign players will thus constitute a potent threat to domestic banks, which will be forced to improve services if they want to maintain their market share. Further expansion will need regulatory approval from the State Bank of Vietnam. The IMF has, in its annual review of the Vietnamese economy, set improvement of financial supervision as a prime task for the government in its reform agenda. The government raising the foreign ownership ratio to 25% for individual banks and 35% in total in 2009-2010 in order to maintain foreign banks' interest in holding stakes in domestic players, thus assisting in technology transfer. With the current system in place, there is a risk of a severe divide between better-capitalised, more technically advanced and better-managed foreign banks and a still relatively undeveloped domestic sector suffering from both a shortage of capital and low efficiency. Vietnamese banks are still primarily focused on taking deposits and lending and thus completely inexperienced in asset management and other financial services tipped to be the main growth areas in the Vietnamese banking market going forward. Domestic players, in particular the larger SOCBs, may have an advantage through their established branch network and client base, but this factor can be rapidly eroded as HSBC and Standard Chartered extend their operations. The threat from foreign banks will be particularly potent for the SOCBs, where reform has been slow in spite of the government's intention to place them foremost in the queue in the so-called ‘equitisation' process of transferring SOEs to private hands. It is unlikely that the government will find takers for its offers of 10-20% stakes in SOCBs for strategic foreign players if it does not radically review its privatisation procedures. With the state-owned banks constrained by politicised decision-making and the private banks suffering from a severe lack of capital, HSBC, Standard Chartered and other regional players will gain the upper hand over time as their extensive experience, superior technology, and readier access to capital work in their favor. It is unlikely that foreign players will dominate the Vietnamese banking sector in 10-15 years time, with the larger JSCBs being majority-owned by foreigners and the role of the once-impressive SOCBs reduced to supporting inefficient state-owned companies and agricultural households. 6. CONCLUSION In Vietnam, there is only less than 10% of Vietnamese currently use banks for financial services, instead largely relying on extended families and neighbourhood associations for lending and saving. However, a rising number of younger Vietnamese are now using banks for financial services, opening up great expansion opportunities in retail banking. The Vietnamese banking sector is a veritably good destination for early entrants as poorly-capitalised and inefficient domestic banks are ill-prepared for the opening of the banking market to foreign entrants as pledged in Vietnam's accession to the WTO in January 2007. With bank penetration at less than 10% and the Vietnamese economy forecast to grow by an average 7. 8% annually over the next ten years, the growth opportunities are great for foreign players. Top of Form REFERENCES Johny K. Johansson (2006). GLOBAL MARKETING Foreign Entry, Local Marketing, & Global Management. McGraw-Hill, Fourth Edition, International Edition. ISBN 007-124454-9. Vinacapital. Vietnam Equity Research. August 15, 2006 Fitch Ratings, Vietnam Special Report – Vietnamese Banks: Focus on Asset Quality – Three Stress Scenarios. February 25, 2009 at: www. fitchratings. com Vietnamese Banks: A Home-Made Liquidity Squeeze? May 2008 Jaccar Equity Research, Vietnam. Banks and Financial Services. The Bubbles did not Burst but Turned Grey. May 18, 2009 at www. jaccar. net Fulbright Research Project, The Banking System of Vietnam: Past, Present and Future. Nam Tran Thi Nguyen, 2001. at: www. iie. org/fulbrightweb/BankingPaper_Final. pdf retrieved on 27 Feb 2009.