on-lend the savings of loan clients, even though this is not usually enforced. The author argues that a three-tier system should be established to regulate microfinance activities: in the first tier the
majority of NGOs should be permitted to accept savings from loan clients; in the second, the larger NGOs should be permitted to offer deposit accounts to the general public; and in the third, normal MFIs
should be set up with private investment. The first tier should be supervised by a coalition of three second-tier institutions, PKSF, CDF and ADAB; the two further tiers should be supervised by the central
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