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A Functional Access Index: Mandatory Agent-Liquidity and Usage Reporting Alongside Account Ownership

Build a Functional Access Index (FAI) as a mandatory supplementary field alongside Global Findex account-ownership reporting, constructed from three operator-reportable metrics that already exist inside every licensed mobile money system's

Based on: A Functional Access Index: Mandatory Agent-Liquidity and Usage Reporting Alongside Account Ownership

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Build a Functional Access Index (FAI) as a mandatory supplementary field alongside Global Findex account-ownership reporting, constructed from three operator-reportable metrics that already exist inside every licensed mobile money system's transaction logs: agent cash-out success rate (percentage of attempted withdrawals completed without agent illiquidity failure, sampled monthly by geography), 90-day active usage rate (accounts with at least one non-airtime transaction, distinguishing savings/credit/merchant use from pure remittance pass-through), and median time-to-cash-out in rural versus urban agent points. None of this requires new household surveys — it requires regulators to mandate that licensed mobile money operators report data they already possess internally for their own liquidity management. The mechanism for adoption is regulatory, not voluntary. Central banks and financial regulators already require mobile money operators to hold e-money in trust accounts and report reserve levels for prudential reasons; the FAI would ride the same reporting pipeline, adding three fields to an existing compliance filing rather than creating a new bureaucratic instrument. The World Bank and IMF's Financial Access Survey already ingests operator-level data in aggregate from central banks — the FAI would slot into that channel as an additional required field, and the World Bank Findex team would publish it as a companion index at the next survey wave, explicitly to be read alongside (not instead of) account-ownership rates. The immediate use case: donors and regulators comparing two countries with identical 75% account-ownership rates would be able to see that Country A has 92% agent cash-out success and 61% active non-remittance usage while Country B has 58% cash-out success and 19% active usage — meaning Country A's account-ownership number reflects a functioning system and Country B's reflects box-checking. That distinction changes where the next round of digital financial infrastructure investment should go, and it changes which "success stories" get held up as replicable templates. Sofía Mendoza's objection when I floated this to her was that operators will resist reporting numbers that make them look bad — which is correct, and is exactly why this has to be a licensing condition, not a voluntary disclosure.

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