By Ken Carson, JD with the SBER Subcommittee of Harvard Catalyst s Regulatory Foundations, Ethics, and Law Program

Similar documents
Audit and Risk Management Committee Charter

Boettcher Foundation Webb-Waring Biomedical Research Awards Frequently Asked Questions (FAQs)

DATA PROTECTION POLICY FOR PUPILS AND PARENTS

PS October 2007 Page 1

Neighborhood Tool Kit. Office of Neighborhood Vitality City of Mesquite, Texas

FUNDING GUIDELINES PREVENTION GRANTS FOR CULTURALLY AND LINGUISTICALLY DIVERSE COMMUNITIES

You can get help from government organizations that are not connected with us

Templates / Examples of WAP State Plan Leveraging Language (2010 approved plans unless otherwise noted)

How to Count Employees Determining Group Size Under the Medicare Secondary Payer Regulations

UCEA/ECU Age Discrimination Working Group Guidance. Age Discrimination Legislation Guidance Note 1: Pay and Benefits A UCEA Publication

TERMS OF REFERENCE. Audit and Risk Committee (the "Committee") of Wilmcote Holdings Plc (the "Company")

Policy Coversheet. Link Tutors: appointment and responsibilities

DEPARTMENT: Patient & Financial POLICY DESCRIPTION: 501 (c)(3) Charity Care & Financial Assistance Policy & Procedures PAGE: 1 of 7

PSNC Briefing on the NHS Complaints procedure (from 1 April 2009)

THE COMMUNITY NEEDS ASSESSMENT REQUIREMENT FOR THE COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM

A Civil Society Agenda for the OECD

Department of Environment Land, Water and Planning

Small Business Employees Significantly Trail Their Large Company Counterparts in Retirement Savings and Preparedness

Geauga Growth Partnership & Kent State University - Geauga Proposed Consolidation Study. Online Survey Report November, 2015

Collaboration Assessment Worksheets

Community Planning Association of Southwest Idaho FY Strategic Plan Report No Approved by the COMPASS Board, December 16, 2013

TERMS AND CONDITIONS FOR APPOINTMENT OF INDEPENDENT DIRECTOR

Bournemouth Borough Council. Penalty Notice Code of Conduct - For failure to ensure regular attendance at school of a registered pupil

PROJECT SUPPORT FUND OVERVIEW

The Lockwood Foundation Grant Application Instructions

Subject Access Requests

Frequently Asked Questions: Broader Public Sector Procurement Directive

Policy and Procedures Date: April 23, Subject: Policy and Procedures for Establishment of New Schools at Virginia Tech

Draft Governance Working Group Summary of Issues, Research Questions and Possible Recommendations. EALI Governance Goal: Enhance Local Self Governance

CODE OF CONDUCT AND ETHICS POLICY ON CONFLICTS OF INTEREST

YUM! Brands 401k Plan

DEPARTMENT: Patient & Financial POLICY DESCRIPTION: 501 (c)(3) Charity Care & Financial Assistance Policy & Procedures PAGE: 1 of 8

Ramsey Million Partnership

Appendix G. Wisconsin DOT: Q&A from FTA

A Step-by-Step Guide to Staying in Compliance Updated November 2016

CHARTER OF THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adopted May 3, 2018

Emergency Support Function (ESF) 18 Business and Industry

ADMINISTRATIVE REPORT

PROJECT CHARTER PLAN VERSION: 1A (DRAFT) <DD-MM-YY> <SECTION NAME>

What type of Bank is best suited to do BOLI?

Teaching performance assessment (Program Standard 1.2)

Are you ready for the FUTURE of your Quality Management system?

Lecture # 22 Cost-Benefit Analysis

University of Oregon Sponsored Projects Services T32 & IGERT Group Training Grant Charge Guidance. Guidance Purpose and Overview

Chargeable Repairs Policy

St. Paul s Lutheran Grade School Tuition Agreement Form

THE CROWDFUND ACT OF 2012 (TITLE III OF THE JOBS ACT): SUMMARY OF LAW AND MAJOR ISSUES RAISED IN PRE-COMMENTS TO THE SEC

PAE 15: Sustainable Investment

ABORIGINAL ECONOMIC PARTNERSHIPS Program Grant Application Guidelines

School Business Manager

UNCRC REPORTING AND NGO PARTICIPATION BY: SAMNANG MEAS ADVISOR AND FORMER SECRETARY GENERAL OF NOVEMBER 2016

HOC Works Program Requirements

MiFID Supervisory Briefing Appropriateness and execution-only

HOW TO RUN A MEETING

CHARTER OF THE NOMINATING AND CORPORATE GOVERNANCE COMMITTEE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adopted May 3, 2018

ABLE Accounts: 10 Things You Should Know

Financial Wellness Curriculum

Audit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd

Steps toward Retirement

AUDIT, RISK MANAGEMENT AND COMPLIANCE COMMITTEE CHARTER

Corporate Governance Principles

Lecture # Cost-Benefit Analysis

ENVIRONMENTAL STEWARDSHIP AND CLIMATE CHANGE GROUP PROGRAM

Guidelines for submission to the NSW Population and Health Services Research Ethics Committee. Version June 2015

Association Support Officer

Significant Financial Disclosure Policy for Investigators

CALL FOR GARDEN APPLICATIONS Deadline: March 20, 2015

Risk Assessment Guide. Money Laundering and Terrorist Financing. November 24, Vassilios Sparakis. Head of

Partner Agency Application Toque Campaign 2017/18

AMENDMENTS TO NASDAQ RULES ON COMPENSATION COMMITTEES

JOHN L. LITTLE, D.D.S, P.A ACKNOWLEDGEMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES. May Refuse to Sign This Acknowledgement-

TOPIC 12: PART 1 WAYS OF GATHERING AUDIT EVIDENCE

16-18Co(17)97 Appendix 2. Panel Consideration Practice Statement. Introduction. This document has been produced to:

Best Execution & Client Order Execution Policy. October P age 1 6. BE31/10/17 v1

BUSINESS FIRMS Why Do Business Firms Exist?

APPENDIX A TECHNICAL SPECIFICATIONS REWARDS AND RECOGNITION PROGRAM

Employee Benefits Guide. January 1 December 31, 2019

RISK INFORMATION CHURCHES CHURCH RISK MANAGEMENT

INTERNATIONAL COLLEGE OF MANAGEMENT, SYDNEY

We process personal data for some or all of the following purposes depending on our relationship with the individual data subject:

AAFMAA CAP FAQs. Q: What are the requirements for a CAP loan? A: The following items are required to receive a CAP Loan: Eligible military status: o

USDA Forest Service Project-level Objections Process

NCTJ Conflicts of Interest Policy and Procedures

Steering Committee of the Global Nuclear Safety and Security Network (GNSSN)

HIPAA Privacy Rule LINKS AND RESOURCES AFFECTED ENTITIES IMPACT ON EMPLOYERS. Provided by Brown & Brown of Louisiana, LLC

Consumer Buy to Let Mortgage

2018 Healthy Boiler Wellness Incentive Program FAQs

MEASURING IMPACT Impact Evaluation Methods for Policy Makers

NARACOORTE LUCINDALE COUNCIL COUNCIL POLICY 94 PUBLIC CONSULTATION AND COMMUNITY ENGAGEMENT

Local Code Of Corporate Governance

How to Become a Delaware Public Benefit Corporation

NYTD Survey- 19 year olds

MIFID Policy Client classification

Town of Palm Beach Retirement System. Deferred Retirement Option Plan (DROP) Policies and Information for Participants

CONCORD recommendations for a more effective and meaningful participation of Civil Society in the future EU- ACP relations

Producer Statements will be accepted only in accordance with this policy.

Maryland Medicaid Expansion and Safety Net Providers

International Standard on Auditing (Ireland) 265. Communicating Deficiencies in Internal Control to Those Charged with Governance and Management

The Company is a public company incorporated in Bermuda and its securities are listed on AIM.

Grant Application Guidelines

Transcription:

A SOCIAL, BEHAVIORAL, & EDUCATIONAL RESEARCH (SBER) CASE STUDY OF BEHAVIORAL ECONOMICS RESEARCH A MICROFINANCE STUDY By Ken Carsn, JD with the SBER Subcmmittee f Harvard Catalyst s Regulatry Fundatins, Ethics, and Law Prgram OVERVIEW The scial, behaviral, and educatinal research (SBER) case studies prvide educatin and guidance n hw t identify and mitigate risks assciated with SBER. These studies may be used by bth IRB administratrs and investigatrs when reviewing and designing research studies that invlved SBER cmpnents. Case studies fllw a standard frmat that includes: 1) a fact pattern, 2) regulatry, cultural, and ethical issues, and 3) a risk/benefit analysis and risk management ptins. This frmat was created t allw fr flexibility in applying the case studies. By identifying cmmn themes, linking them directly t federal regulatins and guidance, and utlining risk mitigatin ptins, the case studies can be used in a variety f ways, which include: 1) as an educatin tl fr training individuals in human subjects research, 2) as a basis fr develping reviewer checklists/wrksheets, and 3) as a tl in designing research prjects. We encurage yu t reprduce and use these materials freely. In ding s, we require that yu acknwledge Harvard Catalyst as the publisher and that yu give apprpriate credit t the individual authrs. Fr additinal infrmatin, visit http://catalyst.harvard.edu/abut/citingsupprt.html. CASE STUDY SCENARIO/FACT PATTERN: Micrfinance includes the prvisin f credit t thse wh d nt have access t traditinal banking services (i.e., residents f rural villages r, mre recently, urban residents living in pverty). Micrfinance prvides ecnmic researchers the pprtunity t design real life randmized interventins t test ecnmic behavir hyptheses with large numbers f participants. In this case, a team f ecnmics researchers seeks t test the tenet that the framing f default chices affects decisin-making. The researchers plan t structure micrfinance lending peratins with different default repayment schemes. A micrfinance lender, wrking with the researchers, will mve int a previusly underserved area in India. The lender will ffer ne plan in 200 villages, an alternative plan in 200 ther villages, and n plan at all in a cntrl grup f an additinal 200 villages. The first plan will have an autmatic savings depsit feature as a default, the ther will nt; this ther plan will nly include regular cmmunicatins encuraging saving. The lending prgram will exclusively recruit wmen. Visit: http://catalyst.harvard.edu/prgrams/regulatry/sber.html Email: regulatry@catalyst.harvard.edu 1 Behaviral Ecnmics Research

The researchers will evaluate: Lan uptake Delinquency rates Saving behavir The researchers will als lk at mre indirect measures f the impact f micrfinance, such as assessments f changes in family assets and schl enrllment f children. Since the lending prgram recruits wmen exclusively, impacts n intra-family relatins will als be studied. Researchers will btain lan data directly frm the micrfinance lender, and additinal infrmatin frm brrwers and their families thrugh detailed, in-persn surveys (lasting ver ne hur). When cnducting the surveys, the researchers d nt plan t disclse their cnnectin t the micrfinance lender r the new lan fferings. The micrfinance lender s agreements with brrwers will disclse that accunt infrmatin may be prvided t third parties wh are evaluating lending prgrams. N cmpensatin will be ffered fr participatin in the research. The experiment is carried ut against a backgrund f reprts that micrfinance brrwers repayment rates are in the high 90 percent range. Hwever, there have been disturbing news reprts f sme micrfinance lenders engaging in what appear t be predatry lending, taking harsh measures t cllect frm brrwers wh are in arrears. Visit: http://catalyst.harvard.edu/prgrams/regulatry/sber.html Email: regulatry@catalyst.harvard.edu 2 Behaviral Ecnmics Research

A MICROFINANCE STUDY DISCUSSION Questins/Cmments fr the researcher: What rle have the researchers played in develping the tw plans the lender will ffer? D the researchers have any cnsulting arrangements with the lender? Des the lender expect t have access t the survey respnses f individual brrwers? If s, culd lan fficers use the infrmatin in a way that culd prejudice the respndents? Will survey participants ever be tld that the research was cnducted with the cperatin f the micrfinance lender, and that their survey respnses were cmbined with accunt infrmatin prvided by the lender? Wuld the micrfinance lender have the capacity t rll ut the prgram in all 600 villages at nce? If s, what is the justificatin fr withhlding credit access in the cntrl grup f 200 villages? If nt, was the selectin f villages that wuld get the service equitable? REGULATORY, CULTURAL, & ETHICAL ISSUES: Understanding the lcal cnditins is a majr challenge fr a US-based IRB. There may be a questin as t whether the lcal research partner knws the ethnic and cultural make-up f target village grupings. A cmmn cnsent issue in this type f research invlves ensuring that brrwers understand participatin in the research is nt a predicate f their receiving a lan. What are the repercussins f cnducting husehld surveys that are quite lng, and ask highly sensitive questins ( D yu keep cash at hme? Gld? Hw much? Where is it kept?)? Micrfinance lans such as these are typically made t wmen in husehlds, and a cmmn line f research is t vary the way husbands are infrmed abut a prgram. Such research questins highlight an underlying dynamic f micrfinance, namely, the effect f ecnmic empwerment f wmen n relatinships between wife and husband. Is there a heightened risk f dmestic abuse as a result f participatin in this study? Suppse the lans are nt repaid: is bad credit, pst-interventin wrse than n credit in the cntrl arm, in a village setting where there are n frmal credit tracking systems? Questins fr the IRB: Des the withhlding f the infrmatin abut the relatinship between the researchers and the lender qualify as deceptin? If s, can it be justified? What part f this activity is research, and what wuld take place even if the researchers were nt invlved? Hw is the risk arising frm the research prperly characterized? If the risk f defaulting n a lan exists independent f the research, since the lender is ging ahead regardless f the research prject, is there a heightened risk f default in ne treatment arm r the ther? RESOLUTION & DISCUSSIONS: Risk/Benefit Analysis: Researchers will frequently argue that the risk f their research is minimal because the lenders are mving int this area regardless, and all the research is ding is evaluating which apprach helps Visit: http://catalyst.harvard.edu/prgrams/regulatry/sber.html Email: regulatry@catalyst.harvard.edu 3 Behaviral Ecnmics Research

brrwers make the best decisins. Even s, steps shuld be taken t address and mitigate risks assciated with participatin in this type f research. Mitigatin/Management f Risks: The data cllectin and strage challenges can be met by hiring reputable surveyrs frm utside the area. Research institutins assciated with universities may be gd resurces; grups wh d this type f research n a regular basis have established meticulus prtcl prcedures fr cding paper surveys, and securing them n a daily basis. The IRB shuld press the researchers t demnstrate that all survey sectins are intended t supprt the research questins (surveys may get adpted frm earlier studies, and superfluus sectins retained). Agencies and NGOs that prvide supprt fr victims f dmestic abuse must be lcated, in apprpriate cases, and infrmatin abut them prvided. Interim mnitring may als be required. In rder t carry ut their study prgrams, lenders may agree that they will nt take measures t btain repayment f delinquent lans frm participants (thugh participants can t be tld that). Pilt trials may be feasible, depending n the timetable f the lender and the researchers. An anthrplgist, wh has a deep, qualitative understanding f the culture and cmmunity structure, shuld review the prpsal t prvide an pinin n, and suggest changes t, the prject. Researchers shuld engage smebdy frm the area wh is knwledgeable abut the ppulatin and familiar with what is acceptable, t assist the researchers with recruitment (and increase likelihd f participatin) and cnsent prcesses. Alternate Details: Identity f the micrfinance lender and relatinship t the research Lender: a divisin f a fr prfit, publicly traded majr in-cuntry bank, r Lender: a nn-prfit that received initial seed funding frm a fundatin knwn fr internatinal develpment wrk in lesser develped cuntries Lender: either f the abve, but the research is being spnsred by: Wrld Bank USAID In additin t the tw interventins mentined abve (alternative repayment prgrams), the researcher wants t knw whether access t financing increases crruptin: are brrwers wh use the lan prceeds t prduce gds in their hme mre likely t be met with payff demands by lcal fficials, in rder t be able t market their gds? Sme cncerns, nt all by any means: If this issue is prbed in interviews, will it heighten risk fr brrwer subjects? What cnsent disclsure wuld be required; if wrd abut studying bribery traveled at the utset, the results f the study, r even the ability t carry ut the study, might be cmprmised. Visit: http://catalyst.harvard.edu/prgrams/regulatry/sber.html Email: regulatry@catalyst.harvard.edu 4 Behaviral Ecnmics Research

Other Events: On cntinuing review, the researcher reprts that, surprisingly, sme brrwers are using the lans fr unanticipated purpses (pssibly any f the fllwing) Financing the sending f husehld members frm village t a distant large city, t wrk in factries with dangerus wrking cnditins Spending n lcal cmmunal scial activities, e.g. purchasing firewrks r supprting religius hliday ceremnies, that prmte status but dn t directly generate incme While the micrfinance lan prgram has incentives and rules t blster schl enrllment and attendance f brrwers children, brrwers are turning t their extended families and neighbrs t recruit very yung children t d piece wrk fr extremely lw wages, while their wn children attend schl Lan prceeds are used t finance smuggling and sales f cntraband gds REFERENCE(S) Researchers affiliated with the Jameel Pverty Actin Lab at MIT have carried ut imprtant studies using large scale randmized studies t answer ecnmics-based questins in develping cuntries. http://www.pvertyactinlab.rg/methdlgy/what-randmizatin. Visit: http://catalyst.harvard.edu/prgrams/regulatry/sber.html Email: regulatry@catalyst.harvard.edu 5 Behaviral Ecnmics Research