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Microfinance Investments and IFRS: The Fair Value Challenge 95 the International Accounting Standards Committee, 8 and IFRS issued by the IASB. Standards and topics range in scope and depth from the presentation of financial statements to financial reporting in hyperinflationary economies. The standard relevant to valuing investments in MFIs is IAS 39, entitled “Fi- nancial Instruments: Recognition and Measurement.” The objective of IAS 39 is “to establish principles for recognising and measuring financial assets, financial liabilities and some contracts to buy or sell non-financial items.” It requires that a financial asset or liability be recognised at fair value at initiation, including related transaction costs. 9 Thereafter, equity instruments and embedded derivatives 10 should be stated at fair value whereas debt instruments are usually held at amor- tised cost depending on their classification into one of the categories defined in IAS 39.9 (see box 3). There is an important exception that is relevant to microfi- nance: “equity investments that do not have a quoted market price in an active market and whose fair value cannot be reliably measured ….” 11 Box 3: IFRS and Debt Investments Debt investments are usually classified as loans and receivables, and according to IFRS are therefore stated at amortised cost. When debt investments are held at amortised cost, the fair value of the investment may be referenced in the balance sheet notes for informational purposes. In certain circumstances IFRS does allow for the valuation of debt instru- ments at fair value (see IAS 39.9 for more detail). For example, if an investor holds both a debt investment and an equity investment in the same entity, or if the investor holds a convertible bond, it may make sense to report the debt investment at fair value, rather than amortized cost. This approach would treat both debt and equity in the same manner and any changes to the fair value of either the debt or equity investment at remeasurement would flow through the income statement. Whether held at amortized cost or at fair value, debt investments are subject to impairment tests. 8 The International Accounting Standards Committee is no longer in existence and has been effectively replaced by the IASB. Most of the standards issued by the International Accounting Standards Committee were adopted, either in original or revised form, by the IASB. See the IASB web site at www.iasb.org for more details. 9 IAS 39.43: Transaction costs are excluded in the case of financial assets or liabilities at fair value through profit or loss. 10 IAS 39.11. 11 IAS 39.46 ( c ). 96 Mark Schwiete and Jana Hoessel Aberle IASB states its mission as “developing, in the public interest, a single set of high quality, understandable and enforceable global accounting standards that require transparent and comparable information in general purpose financial state- ments.” 12 Indeed, great progress toward this goal has been made: seventy-four countries, about two-thirds of which are developing countries, require domesti- cally-listed companies to report according to IFRS. 13 Standard setters, including the IASB and FASB, have made significant efforts to align standards. A good example of recent efforts is the convergence of defini- tions of fair value, listed below. • IAS 39: The amount for which an asset could be exchanged, or a liability settled, between knowledgeable, willing parties in an arm’s length trans- action. 14 • International Private Equity and Venture Capital Valuation Guidelines (IPEVCVG): The amount for which an asset could be exchanged between knowledgeable, willing parties in an arm’s length transaction. 15 • Global Investment Performance Standards (GIPS): The amount at which an asset could be acquired or sold in a current transaction between willing parties in which the parties each acted knowledgeably, prudently, and without compulsion. 16 • Financial Accounting Standards Board (FASB): An estimate of the price that could be received for an asset or paid to settle a liability in a current transaction between marketplace participants in the reference market for the asset or liability. 17 In a November 2006 press release, the International Private Equity and Venture Capital (IPEV) Valuation Board reported that changes to its guidelines “will en- 12 From IASB’s web site, www.iasb.org. 13 See Deloitte and Touche’s IAS Plus web site: www.iasplus.com. 14 IAS 39, IN18, IAS 32.11. 15 IPEVCA were developed by the Association Français des Investisseurs en Capital (AFIC), the British Venture Capital Associate (BVCA) and the European Private Equity and Venture Capital Association with input and endorsement from numerous international private equity and venture capital associations. 1 January 2005. Available online at http://www.privateequityvaluation.com/documents/International_PE_VC_Valuation_ Guidelines_Oct_2006.pdf. 16 Global Investment Performance Standards. Revised by the Investment Performance Council and Adopted by the CFA Institute Board of Governors. February 2005. Available online at www.cfainstitute.org. 17 Financial Accounting Standards Board. Fair Value Team. Minutes of the June 29, 2005 Board Meeting – Definition, Transaction Price Presumption, and Hierarchy. Available online at http://www.fasb.org/board_meeting_minutes/06-29-05_fvm.pdf. Microfinance Investments and IFRS: The Fair Value Challenge 97 sure full consistency of the IPEV Guidelines with both FASB and IASB stan- dards.” 18 Moreover, in the amended version IPEV explicitly notes that their defini- tion of fair value is “…congruent in concept with alternately worded definitions such as ‘Fair Value is the price that would be received for an asset or paid for a liability in a transaction between market participants at the reporting date’.” Yet much work remains: alternative accounting standards, such as U.S. GAAP, continue to be used around the globe. Though differences in standards are not as large or numerous as they once were, differences remain, and they create ambigu- ity for those responsible for financial reporting. The fair value case provides a salient example: while standard setters share similar views of the definition of fair value, the recommended methodologies which may be employed to calculate fair value for investments which lack an active market are inherently subjective and are specified differently among standards. These are discussed in detail below. Market Prices and Microfinance Investments Determining fair value at investment initiation – when the first funding transac- tion is made for a de nove entity – is usually a simple task: according to IFRS, the transaction price is normally considered the fair value of an investment. The initial transaction price for a debt, equity or mezzanine investment in an existing microfinance institution or the subscription price for an equity stake in a greenfield transaction would be considered fair value. At remeasurement, the determination of fair value can be more complicated and a fair value hierarchy, discussed below, must be applied. Market prices, when available, are considered the best gauge of fair value. Ac- cording to IFRS, “The existence of published price quotations in an active market is the best evidence of fair value and when they exist they are used to measure the financial asset or liability.” 19 Usually the current bid price in the most advanta- geous market is used as a basis, adjusted for necessary considerations such as differences in the credit risk profile of the counterparty. Yet market prices require active financial markets, which creates a problem in valuing MFI Investments. Markets for MFI investments are neither active by any definition, nor do transactions occur on an arm’s length basis. (See below for more detail on microfinance secondary markets.) According to IFRS, “A financial market is quoted in an active market if quoted prices are readily and regularly available from an exchange, dealer, broker, industry group, pricing service or regulatory agency and those prices represent actual and regularly occurring market transactions on an arm’s length basis,” 20 this term referring to independent third-party transactions. 18 International Private Equity and Venture Capital Valuation Board Press Release, “Valuation of Private Equity Investments: Changes Ensure Consistency with Recent Fair Value Standard”, Brussels, November 15, 2006. http://www.privateequityvaluation.com/. 19 IAS 39.71. 20 IAS 39.7. 98 Mark Schwiete and Jana Hoessel Aberle KfW’s internal definition of a market price in an active market provides addi- tional guidance: • Investment shares are available from a stock exchange, or through a broker or trader. • The share price reflects the arm’s length principle (e.g that parties to the transaction are equal and independent and there is a market price). • The free float of the shares comprises a minimum of 5% of total share capital. • There are no restrictions on the maximum turnover or trading volume of the shares. • On at least one-third of the trading days in the last year trades were registered, and on at least five days in each calendar month shares were traded. 21 In cases where current market prices are unavailable, the task of determining fair value becomes more complicated. In such a case, the starting point for determin- ing fair value is the price of the most recent transaction – providing that no “sig- nificant change in economic circumstances” has taken place since that transac- tion’s settlement. 22 If such a change has occurred, or if the reporting organisation can prove that the price of the most recent transaction does not accurately repre- sent fair value, then the market price is adjusted accordingly to arrive at fair value according to IAS 39. The initiation price of the investment itself may be used as the fair value, or the price of a recent investment in the same entity by a different investing party may be used. The International Private Equity and Venture Capital Valuation Guide- lines (IPEVCVG) provide specific guidance as to events which may materially reduce current fair value in relation to the investment initiation value: (1) the per- formance or prospects of the underlying business has significantly deteriorated relative to expectations at investment initiation; (2) a significant adverse change in the underlying business or business milieu has occurred; (3) market conditions have declined; and (4) the underlying business is raising capital and evidence ex- ists that future financing will take place under conditions materially different from the investment in question. 23 KfW has chosen to define the “recent” prices which may be used under IAS 39 as prices of transactions taking place within one year of the valuation date. In order to use the price of the last transaction as the “fair value,” none of the follow- ing conditions can be true: 21 KfW Internal Draft Document. “Konzernvorgaben zur Bewertung von Finanzinstrumenten (‘Investments’) durch Geschäftspartner der KfW-Bankengruppe für den Bereich Beteili- gungsfinanzierung” (“KfW banking group valuation directives for investments in partici- patory financing”). 22 IAS 39.72. 23 Paraphrased from IPEVCVG. Page 15. Microfinance Investments and IFRS: The Fair Value Challenge 99 • Parties to the transaction were exclusively management or employees of the investment entity investing their own funds. • A minimum of one investor is a related party of the investment entity. • Restructuring financing has been undertaken by existing investors. • The last transaction was a strategic financing round (defined below). KfW guidelines also provide for extraordinary events which alter the value of the investment and preclude the use of the last market transaction as a basis for deter- mining fair value. 24 The above caveats to the use of recent transaction prices are loosely based on those of IPEVCVG: 1. “a further Investment by the existing stakeholders with little new Investment; 2. different rights attached to the new and existing Investments; 3. a new investor motivated by strategic considerations; 4. the Investment may be considered to be a forced sale or ‘rescue package;’ or 5. the absolute amount of the new Investment is relatively insignificant.” 25 The third point is of particular importance to microfinance investments and is relevant to both new and existing investors. Many microfinance investors are mo- tivated by strategic considerations, including sustainable development and more specific social goals in addition to profit. If, as pundits predict, MFIs tap into pri- vate capital markets in the future, more profit-oriented investors may join the ranks of the current social/mixed or dual objective investors in MFIs. In the future, profit-driven equity holders in a particular MFI may have to adjust for the dual or mixed goals of other investors in the same MFI when considering using the most recent transaction price as the fair value. Markets for MFI investments are neither active by any definition, nor do trans- actions occur on an arm’s length basis: though the number of microfinance inves- tors is growing, the number remains limited and many transactions take place between “related parties”. Data on transactions among related parties, clearly vio- lating the “arm’s length” principle, cannot be used as a basis for determining the fair value of a “comparable” transaction. The lack of an active secondary market for MFI investments precludes the use of published price quotations or recent transactions as a basis for calculating fair value. 24 KfW Internal Draft Document. “Konzernvorgaben zur Bewertung von Finanzinstrumenten (‘Investments’) durch Geschäftspartner der KfW-Bankengruppe für den Bereich Beteiligungsfinanzierung.” 25 Quoted directly from IPEVCVG, Page 14. 100 Mark Schwiete and Jana Hoessel Aberle Estimating Fair Value: Valuation Methodologies According to IFRS, and confirmed by other standard setters such as FASB and EVCA, in the absence of an active market an alternative valuation technique must be used to determine fair value. 26 FASB has outlined a three-level system for de- termining fair value, referred to as the “fair value hierarchy”. This hierarchy, sup- ported by IASB as well, is depicted in the following diagram. Whenever the information is available Level 2 If unavailable, use observable (quoted) market prices for similar assets and liabilities Level 3 If unavailable, use other valuation techniques Level 1 Fig. 1. Use quoted prices for identical assets or liabilities in active markets. Source: From “How Fair is Fair Value?” published by Ernst & Young, adapted from Exposure Draft, Proposed Statement of Financial Accounting Standards, Fair Value Measurements, FASB, June 2004. International Private Equity and Venture Capital Valuation Guidelines (IPEVCVG) do not have a valuation hierarchy per se, but specify that in the absence of an ac- tive market, fair value must be estimated using one of the specified valuation methodologies. Given the lack of market prices formicrofinance investments, how then can one determine “what the transaction price would have been on the measurement 26 IFRS. IAS 39. AG74. Page 1778. Microfinance Investments and IFRS: The Fair Value Challenge 101 date in an arm’s length exchange motivated by normal business considerations”? 27 IAS 39 guidance on methodologies for calculating fair value in the absence of an active market begins with the idea that a valuation “incorporates all factors that market participants would consider in setting a price” and that it “is consistent with accepted economic methodologies for pricing financial instruments.” 28 A valuation methodology which is used for measuring the fair value of an unquoted equity instrument is considered reliable when “the variability in the range of rea- sonably fair value estimates is not significant for that instrument” or “the prob- abilities of the various estimates within the range can be reasonably assessed and used in estimating fair value.” 29 When a valuation methodology is not deemed reliable, the unquoted equity instrument shall be measured at cost. 30 Valuation options set out in IAS 39 include those based on recent transactions, the current fair value of a similar investment, option pricing models, or discounted cash flow analysis (DCF). 31 While not discussing the methodologies in detail, IAS 39 outlines inputs to valuation techniques that should be taken into consideration, including the time value of money, credit risk, foreign currency exchange prices, commodity prices, equity prices, volatility, prepayment risk and surrender risk, and the servicing costs for a financial asset or a financial liability. 32 More specific guidance on the methodologies for calculating the fair value of equity investments are contained in the IPEVCVG. 33 These guidelines emphasise the role of judgement in choosing a valuation methodology, rather than setting out a hierarchy of preferred methodologies as in GIPS. Factors to be considered when choosing a methodology include the following: “the relative applicability of the methodologies used given the nature of the industry and the current market condi- tions; the quality, and reliability of the data used in each methodology; the compa- rability of enterprise or transaction data; the stage of development of the enter- prise; and any additional considerations unique to the subject enterprise.” 34 The methodologies set out in the IPEVCVG include: 1. price of recent investment, 2. earnings multiple, 27 IAS 39.75. 28 IAS 39.76. 29 IAS 39.80. 30 IAS 39.46 ( c ); in this case an entity shall assess at each balance sheet date whether there is any objective evidence that this asset is impaired (IAS 39.58 ff.). 31 IAS 39. 48A. 32 IAS 39.82. 33 These guidelines were developed by AFIC, BVCA and EVCA with input from international venture capital and private equity associations. The guidelines were endorsed on June 28, 2006. 34 IPEVCVG. Page 13. 102 Mark Schwiete and Jana Hoessel Aberle 3. net assets, 4. discounted cash flows or earnings (of the underlying business), 5. discounted cash flows (from the investment), and 6. industry valuation benchmarks. 35 Considering the methodologies used to value microfinance investments, half may be quickly disregarded. We have already considered that based on the price of recent investment in the previous section. Industry valuation benchmarks will not be further considered here as the use of this methodology is extremely limited and applies to industry-specific indicators, such as “price per subscriber” in the tele- communications industry. A similar argument holds for the net assets approach, which values a business by its underlying assets when the liquidation value of the business is greater than its value as a going concern, which is not applicable to MFI investments and is not discussed further. The earnings multiple approach merits consideration. Its greatest problem is the lack of comparable data in microfinance. Equity and quasi-equity transactions tend to be discrete and highly structured, and MFIs vary significantly in terms of busi- ness model, geography, source of revenue and maturity, among other factors. The dearth of published transaction data as well as the lack of reliable earnings data, impede the use of recent transactions as a reference for determining the appropri- ateness of a multiple. Even if reliable data were available, a multiples approach is often backward-looking and more appropriate for businesses with steady, predict- able earnings. For a young growth industry like microfinance, earnings tend to be highly volatile, and will be affected by organisational and staff changes, reorgani- sation and consolidation phases, and changes in provisioning policies, to name just a few discontinuities. This volatility will thwart attempts to predict earnings even within a given range. Finally, in using this approach, the IPEVCVG recommends that a marketability discount be considered. This may be challenging for all microfinance investments, but may pose particular challenges for investments lacking an exit strategy. 36 Ac- cording to IPEVCVG, “…if the underlying company were not considered saleable or floatable at the reporting date, the questions arise of what has to be done to make it saleable or floatable, how difficult and risky that course of action is to implement and how long it is expected to take ….” 37 These considerations compli- cate the subjectivity of any valuation based on earnings multiples. 35 IPEVCVG. Page 14. 36 For a more detailed discussion of exit strategies within the context of microfinance investments see Doris Köhn and Michael Jainzik, “Sustainability inMicrofinance – Visions and Versions for Exit by Development Finance Institutions.” In Ingrid Matthäus-Maier and J.D. von Pischke, eds., Microfinance Investment Funds: Leveraging Private Capital for Economic Growth and Poverty Reduction. (2006). 37 IPEVCVG. Page. 19. Microfinance Investments and IFRS: The Fair Value Challenge 103 Is DCF the Solution of Last Resort? The final option, with two variations, is the discounted cash flow method (DCF). DCF can be based either upon the projected cash flows of the underlying business or on the projected cash flows of the investment (though for pure equity invest- ments the two would yield the same net present value). DCF based on projected cash flows from the investment may be more reliable relative to those based on the projected cash flows from the underlying business when investment pricing is fixed or when there is only a short period of time until the investment exit. How- ever, DCF based on projected investment cash flows yields a more reliable fair value for MFI equity investments with fixed exit strategies – especially for mez- zanine investments, which typically have more structured terms and conditions including fixed maturities and exit conditions. Flexibility is the primary benefit of DCF: it “enables the methodology to be ap- plied in situations that other methodologies may be incapable of addressing.” 38 Yet the flip side of flexibility is subjectivity. DCF requires a choice of inputs: cash flows for the underlying business or investment must be projected; the terminal value of the business or investment must be estimated; and the discount rate, in- cluding the risk-free rate and the market risk premium at which to discount the cash flows must be specified. The variables most relevant to our discussion are the discount rate (r), com- prised of a risk-free rate plus a risk premium, and the terminal value of the in- vestment. The sensitivity of a DCF model to small changes in these variables is quite high. For example, in a recent DCF MFI model, a 1% change in the discount rate yielded a 6.3% change in the net present value of the MFI being valued. In applying DCF to microfinance equity investments, the challenge regarding the discount rate lies in estimating the risk-free rate. In developed markets, the risk-free rate is commonly estimated using the interest rate of a sovereign bond of the country of investment. The risk-free rate should not reflect reinvestment risk, therefore the yield of a sovereign bond of similar maturity to that of the expected cash flows should be used as a benchmark rate. The risk-free rate for emerging market countries is in some sense a misnomer. In contrast to developed markets, even emerging sovereign bonds carry default risk, as the cases of Russia in 1998 and Argentina in 2002 demonstrate. For foreign investors in emerging markets, the reference instrument from which the risk-free rate is estimated should be denominated in the same currency as the expected cash flows (often in EUR or USD), and it should match the maturity of the expected cash flows. The rates of Euro-denominated bonds or Brady bonds would be the first choice as a reference rate to estimate the risk-free rate for for- eign investors in emerging markets receiving Euro or dollar cash flows. Interest rates are the market prices of bonds. Price quotations are reliable indi- cators of current bond value only if markets are active – and many emerging mar- 38 IPEVCVA. Page 21. 104 Mark Schwiete and Jana Hoessel Aberle ket countries lack active sovereign bond markets and some lack any sovereign bond market at all. Another obstacle is the problem of similar maturities. Moreover, using spreads of a similarly-rated country (the “an AA is an AA” approach) to estimate the risk-free rate is not a fully satisfactory substitute. Even if one could assume that two countries rated “AA” have the same default probabil- ity, their spread over that of a AAA-rated sovereign bond may differ because of differences in their loss given default. 39 The default risk in emerging market sovereign bonds raises an important ques- tion regarding the market risk component of the discount rate. Might an MFI pierce the “sovereign ceiling”? Experience suggests that in many cases, a 1 st tier MFI is a better risk, ceteris paribus, than the sovereign risk of the country in which it is located. IAS 39 allows reference to the interest rates of the highest-rated cor- porate bonds of a particular country in estimating the risk-free rate for cases where “the central government’s bonds may carry a significant credit risk and may not provide a stable benchmark interest rate for instruments denominated in that cur- rency.” Yet in emerging market countries, corporate bond markets are even less active than sovereign bond markets. In addition, the debate continues as to whether “real sector” corporates and financial institutions alike can and should pierce the sovereign ceiling The second variable is the “terminal value”, which is required in a DCF model to calculate the present value of future cash flows. While mezzanine investments may have a specified time horizon and defined terminal value (the future value of the investment at the end of the time horizon), pure equity investments do not. Calculating the “terminal value” for an equity investment requires an assumption of the indefinite future growth rate beyond the time horizon for which cash flows are forecasted. A DCF model relies upon assumptions regarding the macroeconomic environ- ment, interest rates, exchange rates, markets and business development. Getting the assumptions for the DCF model “right” for an institution in a young growth industry characterised by highly volatile earnings located within highly volatile markets is, to say the least, a difficult task. Besides the lack of earnings history or reliable earnings data as a basis for extrapolation, macroeconomic conditions in volatile markets are notoriously difficult to predict, as is forecasting cash flow in a accurate and robust way. Cash flow planning, and business planning more generally, is another chal- lenge. Few MFIs have the capability and resources at hand to develop a detailed and systematic business plan including cash flow forecasts – not only for the next few months, but for a period of five years. In one recent case, the attempt to calcu- late the fair value of an MFI failed because management simply lacked the experi- 39 The earlier mentioned cases of Russia and Argentina showed that defaults don’t lead to complete losses for investors but to partial losses (loss given default). As LGD exerts a significant influence on spreads, the latter differs between countries even if default probabilities are similar. [...]... (2006): “Sustainability inMicrofinance – Visions and Versions for Exit by Development Finance Institutions”, in: Matthäus-Maier, Ingrid and von Piscke, J.D., eds., Microfinance Investment Funds: Leveraging Private Capital for Economic Growth and Poverty Reduction, Berlin/Heidelberg/New York: Springer International Accounting Standards Board (IASB) Website: www.iasb.org IASB (2006): International Financial... clientele, typically providing loans but increasingly also savings or other financial products; they can be unregulated, regulated within specific microfinance legislation, or licensed as a bank or a non-bank financial service provider Remittance Money Transfers, Microfinance and Financial Integration 115 Financial integration of remittances has two distinct but related aspects: One is the integration of the... But the information is fairly consistent and indicates the following effects: • increases in savings • indirect links to loans • direct packaging e.g with mortgage finance 9 For examples, see Migrant Remittances 2(2), 2005 10 Author’s interviews with MFP managers; see also experience of WOCCU’s IRnet, e.g in Migrant Remittances 2(2) 2005 Remittance Money Transfers, Microfinance and Financial Integration... Scoring requires information infrastructure capable of handling large data bases and works best when behaviour is highly predictable, which is not necessarily the case inmicrofinance However, scoring may help at the margin and may be useful as a guide, as Schreiner acknowledges CHAPTER 7: Remittance Money Transfers, Microfinance and Financial Integration: Of Credo, Cruxes, and Convictions Cerstin... the future cash flows of the investment This estimate for determining fair value requires assumptions, but to a much lesser extent and for a different purpose than in a DCF model While IFRS poses a challenge formicrofinance equity investors today, this may not be the case in the future The industry is developing quickly More and more MFIs are improving their business planning capacity, both through.. .Microfinance Investments and IFRS: The Fair Value Challenge 105 ence and know-how in business planning to provide business forecasts plausible enough for a DCF valuation Moreover, if business plans are available, their cash flows projections are often outdated within a few months given the industry’s fast development Projections for business plans generated in early fall of one year are often inaccurate... Philippines It also does not identify where within those markets the senders and receivers live – for instance Kenyans in the United States cluster partly in Minneapolis, Indians in the UK cluster in London and in the Midlands (Manchester area) As money transfer is a volume business – requiring high transaction volumes to generate profits out of often narrowing fee margins as competition grows – being... pooling and intermediating funds through loans which facilitate investments Attracting migrants and their families as clients of financial services beyond money transfer is thus a useful goal For the client the benefits can include safety, interest accrual, income smoothing through use of savings, and access to a broader range of basic financial services For the service provider the benefits can include... for cross-selling of products and, if licensed to take deposits, access to the typically lowest cost refinancing for lending For the financial market, the transparent flow of funds as well as greater intermediation contributes to stability and leveraging of capital for investments Commercial banks however, mostly show limited interest in this client segment and its opportunities Banks, especially in. .. Turkish banks in Germany In addition, a very active market in future flow securitisations of remittances originated by Turkish banks to refinance their lending business indicates the contributions of these funds to capital market development and financial intermediation 8 See, for example, Migrant Remittances 1(1), 2004; an internet search also yields numerous examples 116 Cerstin Sander Microfinance providers . “Sustainability in Microfinance – Visions and Versions for Exit by Development Finance Institutions.” In Ingrid Matthäus-Maier and J.D. von Pischke, eds., Microfinance Investment Funds: Leveraging Private. Beteiligungsfinanzierung” (“KfW banking group valuation directives for investments in participatory financing”). Köhn, Doris and Jainzik, Michael (2006): “Sustainability in Microfinance – Visions. new Investment is relatively insignificant.” 25 The third point is of particular importance to microfinance investments and is relevant to both new and existing investors. Many microfinance investors