For credit products, the “legal requirements” includes in addition an income certificate. The “terms of the account” include the need to (i) be member/client of the institution; (ii) save before the loan can be acquired; (iii) have a checking account in the institution; (iv) the amount lent; (v) the amount disbursed; (vi) the total amount due; (vii) the amount of each installment; (viii) the value added tax; (ix) the interest rate and whether it is fixed or variable; (x) the total annual cost (CAT); (xi) the maturity; (xii) frequency of payments; and (xiii) the number of installments. The “fees and commissions” include: (i) the premium for unemployment and/or life insurance; (ii) administrative commissions; (iii) the cost of the credit bureau check; (iv) the membership fee; (v) early payment fee; (vi) late payment fee and (vii) a fee for the payment of installments in other branches or institutions. Similar to the savings categories, the “legal requirements” and “terms of the account” include requirements and unavoidable costs to obtain the loan while “fees and commissions” are additional costs that can mostly be avoided through usage behavior.

There are therefore up to 16 items of information for savings products and 23 items for credit products we measured that could potentially be provided to auditors by sales staff. Clearly not all are equally relevant or important. For this reason we construct 2 sets of measures for each product offered. The first simply involves counting the items of information in each category. For example, if the staff mentioned that a savings auditor needed to show an official identification number and an address certificate, the variable would take the value 2 (of the possible 2 items). But because certain items of information may be irrelevant if they are not required or do not apply, we also construct a set of variables that reflect the percentage of items of information that are relevant for the product offered by the staff. The numerator in this variable is the number of items mentioned (among those that are relevant for the product) and the denominator is the number of items either required or relevant. For example, if a product has a withdrawal fee, then the item will be included in the denominator for the fees and commission category and will appear in the numerator if the staff mentioned the fee.<sup>18</sup> In addition to the information provided we assess the cost of the product offered and compare it to similar products offered by the institution and the market. Similar to the costs reported in Table 1, we compute the total costs and earnings with unavoidable fees only, using the formulas for total annual cost and total annual earnings (CAT and GAT), and the total costs including the most commonly assessed avoidable fees. In particular, we assume that credit clients will miss one payment and will thus be assessed a late payment fee and that savings clients will either withdraw early for those contracting an investment account or will maintain a balance for 2 months below the minimum.<sup>19</sup>

> 18 In this example, if there was no withdrawal fee, then it would not appear in the numerator or denominator although the staff could have mentioned that such a fee was not assessed.

> 19 These usage profiles come from discussions with CONDUSEF and focus groups about the average behavior of low-income consumers with personal credit products and savings accounts.

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