The recent guideline on digital lending is an attempt to have an enabling framework, balancing competing considerations. Most of the innovations in the delivery of financial services have an inherent aspect of conduct – the choice between exploitative vs responsible conduct. It is important to establish a common denominator of what is 'responsible'.
In the Caribbean, institutions limiting rent-seeking are weak: banker and bureaucrat have more opportunity and incentive to reap private benefits at public cost. Basel 3, for example, presumes that sophisticated and integrated risk management systems are in place, and for the Caribbean this is generally not the case. Thirdly, skills are scarce in the Caribbean.