You are Hernán Cálix Ordóñez, general manager of Caja Rural del Valle, a savings-and-credit cooperative in Choluteca, southern Honduras. The banking supervisor is questioning your remittance-based lending programme and gives you 60 days to prove it meets the standards; this very week you must decide how you answer and how much you spend doing it.
The situation
Monday, 12 January 2026, ten in the morning. You have just signed for a letter from the Superintendency of Banks. The Caja has about 15,000 members, and some members' deposits fund other members' loans. About 8,000 people in the region receive regular remittances from relatives in the United States and are served by no bank: they have no credit history and no collateral. The programme was your idea. You believe twelve months of steady remittances say more about a family's ability to repay than a pile of paperwork.
The pilot started in July 2025: credit lines of up to 3,000 dollars, at 15% a year over twelve months. Today there are 400 clients and a 1.2-million-dollar book, backed by 300,000 dollars of capital. 360 clients are current, 25 are more than 30 days late and 15 are in default, 3.75%. In twelve of those fifteen cases the relative abroad lost a job and the remittance stopped. Annualised, default would be around 7.5%, inside the 5% to 8% range of Honduran banks. Some sixty new businesses opened with these loans, and clients' average income rose from 1,200 to 1,450 dollars a month.
The letter makes four observations: there is no formal assessment of capacity to pay; remittances are not a recognised guarantee; the senders have not authorised the use of their transfers; and the alternative scoring method has not been validated. If the Caja cannot show within 60 days that it complies, the programme may be closed. The response budget can run from 50,000 to 150,000 dollars. Your regulatory adviser, Fanny Midence, wants a complete package benchmarked against international standards. The board's treasurer, Santos Ramírez, does not want to spend on lawyers the capital that backs the loan book. And the board has already heard the big version: reaching all 8,000 people, with a book of about 24 million dollars.