and savings products of supervised institutions and they lacked all product data for unsupervised institutions. The web was therefore used to fill in missing information, but since many of the terms were not available online either, they had to be requested directly from the institutions, particularly unregulated ones. The other problem was that financial institutions were not always able to disclose their product portfolio at the time of the study when asked a few months later. This resulted in a product dataset with 1,206 saving and 216 credit products. These data are used to generate Table 1 and to assess the total costs of the products offered to the auditors.

We use data from the questionnaire, and market products dataset to construct variables related to the amount of information provided by the institutions.<sup>15</sup> We first matched the product offered to the auditor during the visit to the actual product in the market product dataset using the commercial name of the product when available. Although auditors were instructed to gather the commercial name during their visits, the staff failed to provide it in more than half of the visits. For visits without recorded product commercial name matching was done based on other product attributes like the type of savings account (transaction vs. investment), the interest rate quoted, and the presence of several fees. Even when a product offered was found in the market products dataset, the match could not sometimes be used because the market products dataset contained missing terms for the product. The resulting sample of matched products consists of 119 savings and 59 credit products.

From the different product terms collected (see Footnote 15) not all are equally relevant or important, because they may not apply or may not be charged. For this reason we develop a “transparency index” that reflects the disclosed cost as a percentage of the total (annual) cost of the product. The index ranges between 0 and 100 percent, where 0 percent indicates that no information about the cost of the product is disclosed and 100 percent means that the full cost of the product is disclosed. The index is thus a ratio where the numerator is the sum of product-relevant costs disclosed by the staff and the denominator is the total cost of the product. For example, if a savings product has a monthly management fee, then the annualized cost will be included in the denominator and will appear in the numerator if the staff mentioned it.<sup>16</sup> Because the total cost may include usage fees, we compute the transparency index with the usage profile suggested by the staff of the Banco de la República and the Financial Superintendency of Colombia and used in Table 1. The transparency index is reported for all costs disclosed orally as well as the costs disclosed voluntarily by the staff, that is, those costs that were not prompted by the auditor. The

> 15 For savings products, the fees include (1) opening fee; (2) management / administration fee; (3) membership fee; (4) debit card fee; (5) the interest rate offered; (6) the total annual earnings (APY); (7) inactivity penalty; (8) account inquiry cost; (9) cash withdrawal cost; (10) debit card replacement fee and (11) early withdrawal fee for investment accounts. For credit products, the fees include (1) interest cost; (2) insurance (e.g. life, default); (3) membership cost; (4) credit acquisition costs; (5) management / administration fee; and (6) late payment.

> 16 In this example, if there was no management fee, then it would not appear in the numerator or denominator although the staff could have mentioned that such a fee was not assessed.

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