The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) REPORT NO.: RES29394 RESTRUCTURING PAPER ON A PROPOSED PROJECT RESTRUCTURING OF MALAWI - FINANCIAL SECTOR TECHNICAL ASSISTANCE PROJECT APPROVED ON MARCH 24, 2011 TO MINISTRY OF FINANCE, ECONOMIC PLANNING AND DEVELOPMENT FINANCE & MARKETS AFRICA Regional Vice President: Makhtar Diop Country Director: Bella Bird Senior Global Practice Director: Gloria M. Grandolini Practice Manager/Manager: James Seward Task Team Leader: Thilasoni Benjamin Musuku, Efrem Zephnath Chilima The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) ABBREVIATIONS AND ACRONYMS ASWAP Agriculture Sector-wide Approach Project ATS Automated Transfer System CAS/CPF Country Assistance Strategy EFT Electronic Funds Transfer FSAP Financial Sector Assessment Program FSDT Financial Sector Deepening Trust FSTAP Malawi Financial Sector Technical Assistance Project IFMIS Integrated Financial Management System IP Overall Implementation Progress MCCCI Malawi Confederation of Chambers of Commerce and Industry MFI Microfinance institutions MFSDS Malawi Financial Sector Development Strategy MNO Mobile Network Operators MOF Ministry of Finance MSE Malawi Stock Exchange PAD Project Appraisal Document PDO Project Development Objective PIU Project Implementation Unit RBM Reserve Bank of Malawi TPH Transactional Processing Hub The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. BASIC DATA Product Information Project ID Financing Instrument P122616 Specific Investment Loan Original EA Category Current EA Category Not Required (C) Not Required (C) Approval Date Current Closing Date 24-Mar-2011 31-Aug-2017 Organizations Borrower Responsible Agency Ministry of Finance, Economic Planning and Development Reserve Bank of Malawi Project Development Objective (PDO) Original PDO The project aims to increase access to finance for the currently unbanked, but bankable, population of Malawi. OPS_TABLE_PDO_CURRENTPDO Summary Status of Financing Net Ln/Cr/Tf Approval Signing Effectiveness Closing Commitment Disbursed Undisbursed IDA-48970 24-Mar-2011 02-Nov-2011 22-Dec-2011 31-Aug-2017 28.20 25.09 1.18 Policy Waiver(s) Does this restructuring trigger the need for any policy waiver(s)? No The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Note to Task Teams: End of system generated content, document is editable from here. I. PROJECT STATUS AND RATIONALE FOR RESTRUCTURING Access to finance remains one of the biggest obstacles to private sector development in Malawi, according to enterprise surveys conducted in 2008 and 2014. The Malawi Confederation of Chamber of Commerce and Industry (MCCCI) conducted its own surveys in 2015 and 2016, and the results mirror this finding, indicating that access to finance continues to be a challenge in Malawi. In 2008, World Bank Financial Sector Assessment Program (FSAP) noted this fact and recommended expansion and improvements in the financial sector to increase access to finance in Malawi. Out of this, the Malawi Financial Sector Development Strategy (MFSDS) was developed and the Financial Sector Technical Assistance Project (FSTAP) was designed to respond to and implement its recommendations. FSTAP was approved by the World Bank Board on March 24, 2011, for a total credit of SDR 18.1 million (US$28.2 million equivalent). The project is implemented by the Reserve Bank of Malawi (RBM). Initially, the project was scheduled to close on August 31, 2016, but was extended to August 31, 2017. While significant progress in implementation has been achieved, including the development of a strong regulatory framework, the formal financial sector remains small, concentrated and services a narrow clientele. On June 9, 2017, the Government formally requested an extension of the project in order to complete some of the activities that require added implementation time beyond the current project closing date. Implementation Progress FSTAP has registered some significant progress in all its four key components. The performance ratings under the last implementation status report were Satisfactory and Moderately Satisfactory for Overall Implementation Progress (IP) and Progress towards achievement of PDO, respectively. Overall, most of the activities that were planned for the project’s lifespan are implemented. However, three key activities are not completed, they are in advanced stages of supply and installation. One major activity (Financial Sector Deepening Trust) was dropped at the first restructuring of the Project. Component 1: The component aims at assisting RBM to strengthen the national financial regulation and supervision framework. Through this component, the project supported the development of regulations, supervision manuals; and the development of regulatory framework for bank supervision, capital markets, MFIs/SACCOs, and the pensions system. The project also supported bank diagnostics, and the development of macro-prudential analytical tools and non-interest banking framework. In addition, the project supported development of the Malawi Stock Exchange (MSE) trading system. At the moment, contracts for the supply of a Central Securities Depository (CSD) and Automated Trading System of the MSE are at signing stage. Component 2: The component aims at assisting RBM to update the basic financial infrastructure for payment services. Through this component, the project has supported the modernization of Real Time Gross Settlement (RTGS) system, the The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) development of interoperable national switching system, and the formulation of relevant legal framework (such as for mobile banking and electronic payment systems), as well as developing capacity at the RBM. These three key activities under this component are outstanding and are discussed below. The project supported the feasibility study, and development of technical specifications and business model of the Microfinance Transactional Processing Hub (MFI TPH). Progress on implementation of the MFI TPH was slower than initially envisaged, in part due to changes in the operational model and implementation modalities midway through the procurement/implementation process at the insistence of industry stakeholders, following a study tour sponsored under the Project. The designs for the MFI TPH are now in place, and the contracts with vendors to provide the hardware and software have been initialed. The RBM has submitted to the Bank a request for No Objection to sign the contracts and proceed with implementation. It would take an added five to seven months after August 2017 for the MFI TPH to be installed and the system commissioned. Through this component, the Project also supported the designing, procurement and development of national switch system. So far, all banks have been connected, and there is progress in connecting Government systems to the new payment infrastructure. The project also aimed at linking the new payment infrastructure to MFIs (through the MFI TPH) and mobile money services thereby enabling low cost access to financial services, particularly for the rural poor and facilitating better integration of MFIs in the formal financial sector in Malawi. The process of integrating mobile network operators providing mobile money services to the national switch is at advanced stage. In 2013, a massive public finance mismanagement scandal dubbed “cashgate” was uncovered which involved theft of public funds by issuing fraudulent cheques. The prevalent usage of cheques highlighted the need for a more robust and modern electronic funds transfer systems for government transactions and strengthening the role of the financial sector and national payments system in government payments. Through this component, FSTAP has supported the risk assessment of Government’s electronic funds transfer system that resulted in the development of the Electronic Funds Transfer (EFT) Roadmap. Implementation of the roadmap has commenced but is not yet concluded. The roadmap supports strengthening of the integration of the Ministry of Finance systems -- the Integrated Financial Management System (IFMIS) – and Reserve Bank of Malawi systems – the Automated Transfer System (ATS). The implementation plan of the roadmap goes beyond the project closing date of August 31, 2017. Component 3: This component aims at supporting efforts to strengthen legal and regulatory framework and institutional arrangements for financial sector consumer protection program as well as developing consumer awareness and financial literacy programs. The project supported the establishment of mechanisms for handling consumer complaints. Financial Sector Appeals Committee and Alternative Dispute Resolution framework were established, and financial Ombudsman Bill was drafted. A Financial literacy campaign, including school radio programs, was conducted. Nation-wide financial literacy survey was conducted, but a follow up survey which was planned to be conducted at the end of the program was not done. Request for this was submitted to the Bank for No Objection and indications are that this activity could take about six months to complete. Component 4: This component aimed at strengthening the capacity of the Ministry of Finance to coordinate the analysis, formulation, implementation and monitoring of financial sector policies. The project financed development of framework The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) for leasing, feasibility study for establishment of a development bank, assessment and options for bond issuance, and the restructuring of MSME. Financial strategy and financial literacy programs were developed, and implementation of the later is awaiting conclusion of the FSAP. In summary, the following three key activities have not been completed and require more time for completion. These activities are critical for the project to achieve its PDO.  Implementation of Transaction Processing Hub for microfinance and financial cooperatives sector: Based on their findings from the study tour to Kenya and Rwanda in September 2016, RMB decided to switch the modality of the Hub from their originally-planned outright purchase model to the pay-as-you-go model, which is used by Kenya and Rwanda and is a more effective modality. Additional time for the implementation of this activity has become necessary due to the decision to change the modality. Preparatory work has been completed. Key activities remaining are the signing of contracts with vendors, and the supply, installation and commissioning of the solution. The implementation is expected to take eight months, with the product going live in May 2018. The activities include, data cleaning for the first 20 pilot MFIs in November, 2017, procurement of starter-pack and installation in January, 2018, data migration in February, 2018, user acceptance testing in April, 2018, and going live in May, 2018.  Integration of Mobile Network Operators (MNOs) and Transaction Processing Hub into the national payments infrastructure: This activity is an essential part of the project and would enable low cost access to financial services, particularly for the rural poor and facilitate better integration of MFIs in the formal financial sector. The project will provide expertise and supervision to this process. RBM is expected to issue an Interoperability Directive in September 2017, which will mandate all MNOs to integrate into the National Switch within 6 months. Key activities on this activity will include, development of interface from October to December, 2017, system integration testing in January and February, 2018, user acceptance testing in March, 2018, and product launch in April 2018.  Support to address government payments weaknesses: The project would continue to provide interim support to enable government to fully roll out electronic fund transfer (EFT). ToRs for vendors to develop interfaces between the Government payments system (IFMIS and Human Resource Management System) on one hand, and RBM’s Flexcube and Automated Transfer System (ATS) on the other hand, are already drafted and submitted to the Bank for No Objection. Integration/Interfacing would commence in October, 2017. Product development and testing will be done from November to December, 2017, and full roll out of EFT would be in January 2018.  Other activities and expected completion dates: Implementing automated trading system and Equities Central Securities Depository for Malawi Stock Exchange (March and May 2018, respectively), follow-up survey to the project’s financial literacy baseline survey (May 2018); and implementation of National Pensions Database (April 2018). The activities highlighted above are key to putting in place of a sound financial system infrastructure that is foundational to advancing access to finance by individuals, small businesses and government. There is need to ensure that these outstanding activities are fully implemented in a timely manner, thereby ensuring satisfactory attainment of the PDO There are three options considered: 1. Closing the project on August 31, 2017 and leaving out the remaining activities as they are: With the above three main activities remaining incomplete, the PDO would not be fully achieved as large number of people who would The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) otherwise be integrated into the financial system through low cost infrastructure services under the MFI Hub and national switch would be left out. Also, without the interim support on the government payment system before EFT is fully rolled out, there is a risk that the ongoing efforts by the Government to strengthen its core public finance management system such as IFMIS, would be curtailed prematurely. Further, the reputational consequence would extend to the client (RBM) and Government, as well as industry players, which have high expectations of implementation of the Hub. Some MFIs and financial cooperatives were in the process of automating but were stopped to allow effective implementation of the MFI Hub (under this project) to optimize benefits across the sector. 2. Closing the project on August 31, 2017 as planned and allow another program to take over the activities. This could be a PforR program or any follow up lending operation. However, this could leave an implementation gap and momentum could easily be lost. The PforR instrument is new in Malawi, and could take a while before gaining the momentum required to see these results in a timely manner. Also, because of industry dynamics, some of the projects such as the MFI Hub would be difficult to restart and implement. Extend the project for 10 months (other than 18 months as requested) to allow for completion of the remaining work. The project team recommends this option to ensure full implementation of the remaining key activities. A main challenge with providing a second extension of 18 months as requested by the client would unnecessarily prolong the duration of activities and would lead to a loss of momentum. To counter this, the team recommends granting the extension for 10 months so that current momentum is sustained and all relevant stakeholders ensure that activities are fully implemented by the new closing date. There is a new management team at the Ministry of Finance (new Secretary to the Treasury) and RBM (new Governor), that are keen to take clear leadership to ensure timely implementation of the outstanding activities and have been behind the request from Government to extend closing date of the project. Furthermore, most of the key activities are at an advanced stage, with the majority past the time-consuming procurement stage. The client has developed a timetable for completing those remaining activities within 10 months, which maps out steps to complete the activities within a reasonable timeline. II. DESCRIPTION OF PROPOSED CHANGES The proposed change is an extension of the closing date for a period of ten (10) months from the current August 31, 2017 to June 29, 2018. There will also be changes in the Results Framework, the Disbursement Estimates and the Implementation Schedule. Finally, a condition of disbursement for Category 2 under the Financing Agreement (Schedule 2, Section IV.B.1(b)) will be deleted, as it was supposed to be deleted during the first restructuring and was inadvertently omitted. The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Note to Task Teams: The following sections are system generated and can only be edited online in the Portal. III. SUMMARY OF CHANGES Changed Not Changed Change in Results Framework ✔ Change in Loan Closing Date(s) ✔ Change in Disbursement Estimates ✔ Change in Legal Covenants ✔ Change in Implementation Schedule ✔ Change in Implementing Agency ✔ Change in DDO Status ✔ Change in Project's Development Objectives ✔ Change in Components and Cost ✔ Cancellations Proposed ✔ Reallocation between Disbursement Categories ✔ Change in Disbursements Arrangements ✔ Change in Overall Risk Rating ✔ Change in Safeguard Policies Triggered ✔ Change of EA category ✔ Change in Institutional Arrangements ✔ Change in Financial Management ✔ Change in Procurement ✔ Other Change(s) ✔ Change in Economic and Financial Analysis ✔ Change in Technical Analysis ✔ Change in Social Analysis ✔ Change in Environmental Analysis ✔ IV. DETAILED CHANGE(S) OPS_DETAILEDCHANGES_RESULTS_TABLE The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) RESULTS FRAMEWORK Project Development Objective Indicators PDO_IND_TABLE PDO Indicator One: Increase in the percentage of the adult population that use formal financial institutions. Unit of Measure: Percentage Indicator Type: Custom Baseline Actual (Current) End Target Action Value 19.00 33.00 40.00 Revised Date 24-Mar-2011 30-Jun-2017 29-Jun-2018 PDO Indicator Two: Increase in the proportion of women within the adult population that is formally banked. Unit of Measure: Percentage Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action Value 17.00 28.00 40.00 Revised Date 24-Mar-2011 30-Jun-2017 29-Jun-2018 PDO Indicator Three: Agency banking regulations operational Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Regulations Value 0 None Revised implemented Date 03-Dec-2012 30-Jun-2017 29-Jun-2018 PDO Indicator Four: Transactions volume and value processed by new payments systems (ATS, National Switch, MFI TPH) Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Value Volume: 159,625; Value: Cumulatively; 4,176,075 Volume by 10%; Value Revised MK 4,253 Billion and MK11,362 Billion are by 5% the volume and value of transaction that have passed through the ATS since it went live on 1st December 2015. The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) For April 2016 National Switch transactions, volume was at 129,787 and valued at K 2.15 billion. Date 30-Sep-2011 27-Jan-2017 29-Jun-2018 PDO Indicator Five: Proportion of financially literate population Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action TBD (To be determined by new Financial Inclusion Strategy that has been Value 3.6% 3.6% finalized by GoM but Revised whose M&E matrix is to be finalized). This End target will be updated in next ISR. Date 29-Aug-2014 27-Jan-2017 29-Jun-2018 PDO Indicator Six: Proportion of financially literate women in the population Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action To be fully updated Value 3.4% 3.4% after follow-up survey Revised on the baseline. Date 29-Aug-2014 27-Jan-2017 29-Jun-2018 Intermediate Indicators IO_IND_TABLE Indictor One: Key regulations and supervision manuals issued to support implementation of the 10 new financial laws which have beenpassed recently or to be passed over the life of the project. Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Value Existing regulatroy All key regulations for None. Revised The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) framework needs to be the passed laws are upgraded in order to either issued or are at support the the gazetting stage implementation of the 7 new laws passed in the last 2 years, in addition to the 3 news bills that are expected to be passed later. Date 24-Mar-2011 30-Jun-2017 29-Jun-2018 Indicator Two: Automated tools for offsite surveillance and macro-prudential analysis designed, acquired and implemented. Unit of Measure: Text Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action Offsite and macro- Analytical tools for prudential analysis offsite monitoring Enhancement of is not supported by and analysis used the BSA to include automated in day-to-day non-bank financial Value analytical tools work. Revised institutions was using Stability Report completed in June comprehensive updated and 2017. reliable and timely published at least data Annually Date 24-Mar-2011 30-Jun-2017 29-Jun-2018 Indicator Three: RBM staff trained in uses of analytical tools and regarding new regulations Unit of Measure: Text Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action No automated In Progress analytical tools are (training is ongoing available and staff No training Value and figures to be Revised do not have hand- planned. provided in next on experience ISR) using them Date 24-Mar-2011 27-Jan-2017 29-Jun-2018 Laws reviewed and drafted Unit of Measure: Text The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action Advisor on pensions commented on the current Pensions Reviewed Act and proposed Pensions Act Value Descriptive New amendments. approved by Workshops to Cabinet review the Act were held. Date 24-Mar-2011 30-Jun-2017 29-Jun-2018 Indicator Seven: Modern financial infrastructure deployed and operational Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action ATS and National Switch live and operational. Contracts for MFI Hub Installation, Outdated financial are at signing stage. The commissioning and Value Revised infrastructure. solution will be provided stabilization of MFI through software as a TPH solution. service and hardware as a service. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Eight: Increased number, value, volume of POS, ATMs and Mobile payments Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action See sub-indicator See sub-indicator Value See sub-indicator below No Change below below Date 31-Dec-2012 27-Jan-2017 31-Aug-2017 Sub Indicator (a): Number,value, volume of POS Unit of Measure: Text Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action Value 2012 figures; 2016 cumulative End 2017 Targets No Change figures; being developed The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Number: 679 Number: 1,228 as part of new Volume: Volume: 544,586 Financial Sector Value: Value: 24,122.8 Development K307.9million million Strategy Date 31-Dec-2012 27-Jan-2017 31-Aug-2017 Sub Indicator (b) Number, value, volume of ATMs (interbank) Unit of Measure: Text Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action 2017 cumulative figures; 2013 figures; End 2017 Targets Number: 501 Number: 368 being developed Volume: Volume: 1,590,121 as part of new Value 1,055,334,582 Revised Value: K17.49 Financial Sector Value: billion Development 231,068,808,077 Strategy million Date 31-Dec-2013 30-Jun-2017 29-Jun-2018 Sub Indicator (c): Number, value, volume of mobile payments Unit of Measure: Text Indicator Type: Custom Breakdown Baseline Actual (Current) End Target Action 2017 cumulative End 2017 Targets Volume: 188,928 figures; being developed (2012) Volume: as part of new Value Value: K761 million Revised 61,952,942 Financial Sector (2012) Value: Development 156,640,398,161 Strategy Date 31-Dec-2012 30-Jun-2017 29-Jun-2018 Indicator Nine: Number of participating members of all 3 payments systems Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Value Proposed ATS, National All Banks participating in At least 50% of MFIs Revised Switch and MFI TPH not ATS and all integrated and Financial yet operational on National Switch. Only Cooperatives The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) 5 banks are live on POS. participating in MFI Hub solution not yet TPH. operational. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Ten: Approved road-map for implementation of government EFT payment program Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Implementation of EFT Roadmap has started No roadmap for with the development of 100% of Government implementation of ToRs for the Value EFT Action Plan Revised government EFT development of various implemented. payment program interfaces to secure the government payment stream. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Eleven: Legal and regulatory framework for consumer protection prepared and presented to Cabinet Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Transparency and Disclosure Directives drafted for insurance, investment, pension and savings products. Fair The Financial Services treatment of financial Act includes some consumers Directives major provisions on drafted. Advertisement consumer protection, of financial products and Value and gives the RBM No target Revised services Directive authority to regulate drafted. Complaints and supervise handling consumer protection procedure/guideline issues in financial reviewed and printed. Market conduct guidelines drafted awaiting review of internal stakeholders. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Twelve: Institutional arrangements for consumer protection in all financial services implemented The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action RBM's consumer protection unit (CPU) The ADR Bill has been has been created (but drafted by a consultant ADR Bill sent to Value Revised not staffed) within the and is undergoing Cabinet. microfinance and consultations. capital markets unit Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Thirteen: Increased awareness of rights as financial consumers among population reached by financial literacy campaign Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action Consumer rights in Developed strategy on financial services is an financial literacy. ascent concept and Developed secondary Consumer rights measurement of school financial awareness: Baseline awareness of the rights education source books. +10% Financial Value needs to be developed Intensified mass media Revised literacy campaign: throughBaseline financial literacy 30% of targeted survey.No systematic programs. Conducted population reached financial literacy secondary school campaign has been financial capability conducted in Malawi survey. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 Indicator Fourteen: RBM institutional capacity has been enhanced for consumer protection supervision. Unit of Measure: Text Indicator Type: Custom Baseline Actual (Current) End Target Action No training or All existing staff Value developed processes In Progress Revised trained. and procedures. 2 staff. Date 22-Dec-2011 30-Jun-2017 29-Jun-2018 OPS_DETAILEDCHANGES_LOANCLOSING_TABLE The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) LOAN CLOSING DATE(S) Original Revised Proposed Proposed Deadline Ln/Cr/Tf Status Closing Closing(s) Closing for Withdrawal Applications IDA-48970 Effective 31-Aug-2016 31-Aug-2017 29-Jun-2018 29-Oct-2018 OPS_DETAILEDCHANGES_DISBURSEMENT_TABLE DISBURSEMENT ESTIMATES Change in Disbursement Estimates Yes Year Current Proposed 2011 0.00 0.00 2012 1,631,295.93 0.00 2013 4,244,049.75 0.00 2014 5,349,370.00 0.00 2015 4,930,000.00 0.00 2016 7,945,284.32 0.00 2017 3,600,000.00 0.00 2018 500,000.00 1,180,000.00 OPS_DETAILEDCHANGES_LEGCOV_TABLE LEGAL COVENANTS Loan/Credit/TF Description Status Action Finance Agreement :Schedule 2 Sec.IV.B1(b) of FA | Description :The project implementation funds that have been budgeted for the consultancy costs Marked for IDA-48970 for the proposed Financial Sector Deepening Trust will Complied with Deletion only be disbursed after the Trust has been established. | Frequency :Quarterly Finance Agreement :-Schedule, Sec.IA.1(b) of PA | IDA-48970 Complied with No Change Description :By not later than 12/31/11 establish and The World Bank Malawi - Financial Sector Technical Assistance Project (P122616) operationalize the FSTAP PIU, and thereafter ensure that the responsibilities carried outby the BESTAP PIU are efficiently transferred to the PIU. | Due Date :31-Dec-2011 Finance Agreement :Schedule 2 Sec.1.E of FA | Description :No withdrawal shall be made for payments prior to the date of the FA; and for consultant services IDA-48970 Complied with No Change for the MFDT unless and until it has been established referred to in Sec.I.E of Sch.2 fo the FA | Frequency :Quarterly Finance Agreement :Sec. II. B1 of PA | Description :Maintain adequate financial management system and IDA-48970 records; prepare financial Complied with No Change statements of operations, resources and expenditures of the project. | Frequency :Quarterly Finance Agreement :Sec. II. B2 of PA | Description :Submit to the Bank audited financial statements not IDA-48970 Complied with No Change later than 6 months after the end of the project. | Frequency :Yearly Finance Agreement :Sec. II. B2 of PA | Description :Furnish unaudited interim financial reports (IFRs) no IDA-48970 Complied with No Change later than 45 days after the end of each accounting quarter. | Frequency :Quarterly Note to Task Teams: End of system generated content, document is editable from here.