BRH/IMF/2026/2 Circular Governing Liquidity Management for Microfinance Institutions

Bank of the Republic of Haiti
CIRCULAR

CIRC.: BRH/IMF/2026/2

TO MICROFINANCE INSTITUTIONS

Pursuant to Article 36 of the Decree of June 5, 2020 on the organization and functioning of microfinance institutions (MFIs), the latter are required to comply with the following provisions regarding minimum liquidity requirements.

1. Definitions

The following definitions apply to this circular:

a) Unencumbered assets: assets free from legal (statutory, regulatory, or contractual) or other restrictions limiting an institution's ability to liquidate, sell, transfer, or allocate them.

b) Demand deposits: any sum immediately available deposited in a demand account at a microfinance institution.

c) Savings deposits: any sum deposited in a savings account at a microfinance institution.

d) Time deposits: any sum deposited at a microfinance institution for a defined maturity period.

e) Group of interrelated depositors: depositors who have legal or contractual links between them on one or more deposit accounts at a microfinance institution. All accounts held by these persons within the same microfinance institution shall be considered under this circular as belonging to a single depositor. This may include, in particular:

1. Joint account holders: several persons having equal rights on a deposit account opened in their names.

2. Authorized agents: any person who has received power from a deposit account holder to carry out operations on said account.

3. Designated beneficiary: person designated as having the right to receive funds from an account in the event of unavailability or after the death of the main account holder.

4. Sole signatory on a corporate deposit account: deposit accounts of a company and those held by any person having sole signing rights on the accounts of said company within the same microfinance institution must be considered as belonging to a single depositor or the same group of depositors.

5. Group of related or affiliated legal entities: the following are considered to constitute a group of related or affiliated legal entities:

1. persons who have capital links such that one of them exercises, directly or indirectly, exclusive or joint control power or significant influence over the others, in the sense of the international accounting consolidation standards published by the International Accounting Standards Board (IASB);

2. persons who are linked in such a way that financial difficulties encountered by one or some of them would necessarily lead to serious financial difficulties in the other or others. Such links are presumed to exist between two or more natural or legal persons in the following cases:

• one of them has, vis-à-vis the others, the right or power to appoint or remove the majority of the members of the management or supervisory bodies;

• their administrative, management, or supervisory bodies are composed predominantly of the same persons or they are under a single direction, by virtue of a contract, statutory clauses, or in fact;

• one of them has, vis-à-vis the others, the right or power:

  • to exercise dominant influence pursuant to a contract or provisions of agreements or articles of association,
  • to decide on their strategy or direct their activities, coordinate their management, or decide on crucial transactions, such as the transfer of profits or losses;

• these persons have financial dependency links, such as the existence of inter-company accounts, guarantees, or sureties issued by one of them in favor of another;

• these persons maintain predominant business relations between them, notably through subcontracting or franchise contracts;

• these persons are local authorities or public establishments and have financial dependency links between them.

f) Medium and long-term assets: any asset item whose recovery time or realization time is greater than or equal to one (1) year, except those that are deducted from regulatory capital in accordance with the circular on minimum capital requirements for MFIs, and, for amortizable assets, to the extent of the outstanding principal at the end of the next twelve (12) months. These items include:

1. net fixed assets after depreciation and provisions, excluding assets given under lease in the context of finance lease operations;

2. equity investments, excluding investments deductible from regulatory capital;

3. the portion repayable in more than one year of investment securities, government bonds, and state securities held, except for securities negotiable on liquid markets;

4. the portion of non-performing loans, as defined in the circular on loan classification, the establishment of provisions for doubtful debts, and the recognition of accrued interest on loans, not covered by provisions;

5. 100% of the outstanding balance of more than one year for loans classified as current and to be reported;

6. 100% of the outstanding balance of more than one year for finance lease operations;

7. the portion repayable in more than one year of advances to banks and other institutions;

8. any other asset whose recovery cannot be obtained before a period of at least one (1) year.

g) Fixed assets: all physical fixed assets (operating and non-operating), tangible and intangible, equity investment securities, and other financial instruments with an equity character as defined in the circular on regulatory capital.

h) Credit line: credit facility granted by a microfinance institution to economic agents granting them access to financing within the limits and conditions set.

i) Available stable financing: Resources consisting of the following elements:

1. Regulatory capital;

2. 40% of demand and savings deposits;

3. 100% of time deposits without the possibility of early repayment in less than one year and with a residual maturity greater than or equal to one (1) year;

4. 40% of time deposits with an amount less than five (5) million gourdes and a residual maturity of less than one (1) year;

5. 25% of time deposits with an amount greater than or equal to five (5) million gourdes and a residual maturity of less than one (1) year;

6. the portion of resources obtained from banks and other financial institutions with a residual maturity greater than one (1) year;

7. the outstanding balance repayable in more than one (1) year in residual maturity of bond issues and other borrowings;

8. any other resource with a residual maturity greater than one (1) year.

j) Cash and equivalents: cash (banknotes and coins), balances at the BRH and in local banks available on demand or with a maximum horizon of one month, securities mobilizable without condition at the BRH, securities negotiable on an active and liquid market.

2. Minimum Liquidity Requirements

2.1. Maximum Limit per Depositor or Group of Interrelated Depositors

The balance of accounts of a depositor or a group of interrelated depositors may in no case exceed 5% of the total deposits of a microfinance institution.

The aforementioned limit is determined after deducting the deposit amounts pledged as collateral by the account holder(s).

This limit does not apply to shareholders of the microfinance institution provided that their deposits are subject to the same conditions or less favorable conditions than those of other depositors.

2.2. Immediate Liquidity Ratio (ILR)

All microfinance institutions are required to hold, in the form of liquidity, an amount corresponding to at least 20% of liabilities due within thirty (30) days. The ILR is calculated as follows:

ILR = Cash and equivalents / Liabilities due within 30 days >= 20%

For the calculation of the immediate liquidity ratio, the following elements are to be considered:

1. Cash and equivalents which is composed of:

• Cash (banknotes and coins);
• On-demand availability and balances maturing within 30 days at the BRH;
• Demand deposits at financial institutions;
• Unencumbered investments and time deposits maturing within 30 days including BRH and Treasury bills;
• Cheques to be collected;
• Irrevocable and on-demand financing guarantees received from a public institutional lender (bilateral or multilateral);
• 80% of receivables within 30 days;
• Other unencumbered liquid assets (to be specified) maturing within 30 days.

2. Demand liabilities, with a maturity of 30 days or less, which consist of:

• 20% of demand and savings deposits less than 5 million gourdes held by the same client;

• 40% of demand and savings deposits greater than or equal to 5 million gourdes held by the same client or group of interrelated depositors;

• Client time deposits maturing within 30 days or containing an early repayment option within a 30-day horizon;

• Cheques received for collection;

• Operating expenses payable within 30 days;

• 50% of the unused portion of credit lines;

• Any other liability with a maturity of 30 days or less.

2.3. Stable Financing Ratio (SFR)

To avoid excessive transformation of on-demand and/or short-term resources into medium and long-term assets, MFIs must finance all their fixed assets as well as their other medium and long-term assets with stable resources. The long-term structural liquidity ratio or stable financing ratio (SFR) aims to ensure that the institution maintains a financing profile in line with the composition of its assets and off-balance sheet commitments. This ratio corresponds to the ratio between the amount of available stable financing and that of medium and long-term assets.

The SFR must be at least equal to 100% for microfinance institutions.

It is calculated as follows:

SFR = Available stable financing (Resources) / Medium and long-term assets >= 100%

2.4. Fixed Asset Coverage

Microfinance institutions are required to comply with a maximum fixed asset coverage ratio of 75%, defined as the ratio between net fixed assets and regulatory capital.

FACR = Net fixed assets / Regulatory capital <= 75%

Fixed assets are retained after deducting depreciation and value losses, intangible fixed assets, equity investment securities, and other financial instruments held

by a microfinance institution and which are deducted from its regulatory capital. Assets given under lease in the context of finance lease operations are also excluded.

2.5. Other Provisions

The BRH may require a microfinance institution to maintain higher ILR and SFR ratios if it deems its liquidity risk to be particularly high, notably due to deposit concentration or other reimbursable financing sources.

3. Availability of Information for the BRH

Microfinance institutions must keep at the disposal of the BRH all working files related to the preparation of the reports required under this circular.

4. Reporting

Microfinance institutions must send to the BRH, within 21 days following the end of the quarter or 15 days following the end of the month, through the banking supervision software (BSA), the following reports prepared as of the monthly or quarterly closing date, as applicable:

• quarterly report on the ten (10) largest depositors (Annex 1)
• monthly report on the immediate liquidity ratio (Annex 2)
• quarterly report on the structural liquidity ratio (Annex 3)
• quarterly report on fixed asset coverage (Annex 4)

5. Sanctions

In the event of non-compliance with the obligations defined in this circular, a microfinance institution is subject to the following penalties:

a) Information Reliability
At all times, the amounts declared in the reports provided for in section 4 must be those appearing in the accounting and auxiliary books of the microfinance institution.

Failure to comply with this directive may result in the BRH imposing, after an investigation into the circumstances and nature of the violation, a penalty of 10% of the difference between the amounts declared in the reports and the amounts appearing in the accounting and auxiliary books of the financial institution.

b) Exceeding Regulatory Liquidity Limits
Any exceedance of immediate or structural liquidity limits is subject to a penalty, per day of violation, corresponding to 0.1% of the amount of capital necessary to bring the ratios back within the set limits. The penalty period begins on the reporting date where the violation is observed and ends on the compliance reporting date showing the situation has been regularized. In the event of simultaneous exceedances, the penalty applies to each exceedance.

c) Calculation Discrepancies in Liquidity Limits Observed During BRH Inspection Missions Calculation discrepancies in liquidity limits may be observed during inspection missions carried out by the BRH compared to the declarations made by the microfinance institution.

Inspection missions evaluate the constituent elements of the liquidity ratio components and compare them to the declarations transmitted by the microfinance institution. At the end of this exercise and after discussion with the institution's management, a discrepancy may arise.

A period of thirty (30) days is granted to the financial institution to correct the discrepancy. After the thirty (30) day period, a penalty of fifty thousand gourdes (50,000.00 HTG) per day of violation applies until the discrepancy is regularized, and a warning is notified to the concerned institution by letter.

d) Availability of Information
Failure to provide the information stated in section 3 of this circular subjects the financial institution to a penalty of fifty thousand gourdes (50,000.00 HTG) per day of violation. The penalty period extends from the day of the violation (the date set by the BRH for submitting the information) until the day the information is provided to the BRH.

e) Late Submission of Compliance Reports
Failure to submit, within the required timeframe, the compliance reports provided for in section 4 of this circular subjects the microfinance institution to a penalty of fifty thousand gourdes (50,000.00 HTG) per day of violation. The penalty period extends from the day of the violation until the effective transmission date of the reports to the BRH.

Any penalty under the provisions of this section will be debited to one of the accounts of the defaulting institution at the BRH.

6. Transitional Provisions

From the publication of this circular, a period of one year is granted to existing microfinance institutions to comply with the limits prescribed by sections 2.1, 2.2, 2.3, and 2.4 concerning the ratios of:

• balance of a depositor's accounts relative to total deposits;
• immediate liquidity (ILR);
• Available stable financing (SFR);
• Fixed asset coverage (FACR).

7. Entry into Force

This circular enters into force on April 1, 2026.

Port-au-Prince, February 11, 2026

Ronald Gabriel
Governor

List of Annexes

• Annex 1: Monthly report on the ten (10) largest depositors
• Annex 2: Monthly report on the immediate liquidity ratio
• Annex 3: Quarterly report on the structural liquidity ratio
• Annex 4: Quarterly report on fixed asset coverage

Annex I: Report on the List of the Ten (10) Largest Depositors (Individual or Group of Interrelated Depositors)

Financial Institution ____________________ Month: ____________________ Reference Rate: .......HTG/USD

Monthly Report on the Ten (10) Largest Depositors
	Deposits (HTG)			Deposits Converted to HTG			Total in HTG
First and Last Name of Depositor or Group of Interrelated Depositors	DAV	DE	DAT	DAV	DE	DAT
Group #1 (to be identified) or Depositor #1_
Depositor A
Depositor B
Depositor C
.........
Group # 2
Depositor A
Depositor B
Depositor C
.........
Group # 10
Depositor A
Depositor B
Depositor C
.........
Total

Total Deposits of the Institution (in HTG) | |

DAV: Demand Deposits; DE: Savings Deposits; DAT: Time Deposits

Authorized Signatures ________________________________________

Annex II: Report on the Monitoring of Immediate Liquidity

Financial Institution ________________________________________ Monthly Report on Immediate Liquidity (in HTG) Month ____________________

Elements of Cash and Equivalents	Balance	Proportion	Retained Amount
Cash (banknotes and coins)		100%
Availability and balances at the BRH maturing within 30 days or less		100%
Demand deposits at financial institutions		100%
Unencumbered investments and time deposits maturing within 30 days including BRH and Treasury bills		100%
Cheques to be collected		100%
Receivables within less than 30 days		80%
Irrevocable and on-demand financing guarantees received from a public institutional lender		100%
Other unencumbered liquid assets (to be specified) maturing within 30 days		100%
A. Total

Elements of Demand Liabilities	Balance	Proportion	Retained Amount
Demand and Savings deposits less than 5 million gourdes held by the same client		20%
Demand and Savings deposits greater than or equal to 5 million gourdes held by the same client or group of interrelated depositors		40%
Client time deposits maturing within 30 days or containing an early repayment option within a 30-day horizon		100%
Cheques received for collection		100%
Operating expenses payable within less than 30 days		100%
Unused portion of credit lines		50%
Other liabilities maturing at 30 days or less (specify)		100%
B. Total

Prudential Ratio: (A/B >= 20%) | | | |

Authorized Signatures ________________________________________

Annex III: Report on the Coverage of Medium and Long-Term Assets

Financial Institution: ____________________ As of: ____________________ Quarterly Report

Line	Stable Resources	Balance	Proportion	Retained Amount
	Regulatory Capital (Circular on capital requirements)		100%
1	Demand and Savings Deposits		40%
2	Time Deposits with residual maturity greater than 1 year		100%
3	Time Deposits with residual maturity less than 1 year and amount less than five (5) million gourdes		40%
4	Time Deposits with residual maturity < 1 year and amount greater than or equal to 5 million gourdes		25%
4	Resources from other financial institutions with residual maturity > 1 year		100%
5	Bond issues and other borrowings - outstanding balance repayable in more than one year in residual maturity		100%
6	Other Resources (to be specified) with residual maturity > 1 year		100%
7	(A)- Total of Stable Resources
8	Medium and Long-Term Assets
9	Net Fixed Assets (Annex 1, total C)		100%
10	Equity Investment Securities (line 11 - line 12)
11	Net book amount
12	Investments deductible from regulatory capital
13	Investment securities, government bonds, and state securities (line 14 - line 15 - line 16)		100%
14	Total outstanding balance
15	Securities negotiable on a liquid market
16	Other securities - Portion repayable within a maximum period of one year
17	Non-performing loans net of provisions for doubtful debts		100%
18	Current and to-be-reported loans (line 19 - line 20)		100%
19	Net book outstanding balance
20	Outstanding balance with maturity of one year or less
21	Finance lease operations (line 22 - line 23)		75%
22	Net book outstanding balance
23	Outstanding balance with maturity of one year or less
24	Advances to other financial institutions (line 25 - line 26)		100%
25	Net book outstanding balance
26	Outstanding balance with maturity of one year or less
27	Other assets (to be specified) with residual maturity > 1 year		100%
28	(B)- Total of Medium and Long-Term Assets
29	Prudential Ratio: (A)/(B)

Authorized Signatures: ________________________________________

Annex IV: Fixed Asset Coverage

Financial Institution: ____________________ As of: ____________________ Quarterly Report

	Amount
Fixed Assets
Net Fixed Assets on Balance Sheet excluding finance leases
Equity investment securities and other financial instruments with an equity character held
(A)- Total Fixed Assets
Fixed Assets Deducted from Regulatory Capital
Intangible fixed assets
Equity participations in other regulated institutions
(B)- Total Deductions
(C) - Net Fixed Assets after Deductions = (A)-(B)
(D) - Regulatory Capital (Circular on Capital, Annex III, 1/2 line GG)
PRUDENTIAL RATIO (C) / (D)

Authorized Signatures: ________________________________________