Strategy, Sustainability and Future BankingIntroduction and ContextRetail and rural banking are no longer defined solely by branch networks, deposit mobilisation and individual lending. They are increasingly shaped by digital platforms, climate volatility, data-based credit assessment, public policy, partnerships and changing expectations about inclusion. A successful bank must therefore pursue two objectives simultaneously: it must remain commercially viable and it must create durable social and environmental value. Strategic banking involves selecting a coherent position, allocating scarce resources and building capabilities that competitors cannot easily imitate. In retail and rural markets, strategy must also address informality, low financial literacy, seasonal income, geographic dispersion, weak infrastructure and vulnerability to shocks. Sustainability extends this responsibility by requiring banks to consider the long-term effects of credit, investment, operations and technology on customers, communities and the environment. This chapter develops an integrated framework for competitive strategy, performance measurement, partnerships, scenario analysis, climate-risk management, green finance, platform banking, central bank digital currencies (CBDCs) and future models of financial inclusion. Learning ObjectivesBy the end of this chapter, a learner should be able to: - Formulate competitive strategies for retail and rural banking using customer, capability and ecosystem analysis.
- Design a balanced performance scorecard and interpret financial and non-financial indicators.
- Evaluate partnership models involving fintechs, cooperatives, business correspondents, governments and digital platforms.
- Apply scenario analysis to strategic and risk decisions.
- Explain climate-related financial risks and the principles of green finance.
- Critically assess platform banking, CBDCs and emerging inclusion models.
- Integrate profitability, resilience, ethics, regulatory compliance and social impact in strategic decisions.
1. Strategic Foundations of Retail and Rural Banking1.1 Strategy as a system of choicesA banking strategy is not a list of aspirations. It is a system of mutually reinforcing choices concerning: - target customer segments;
- value propositions;
- channels and service architecture;
- risk appetite;
- sources of competitive advantage;
- revenue and cost structures; and
- governance and resource allocation.
For retail banking, segmentation may be based on life stage, income, occupation, financial behaviour or digital capability. Rural segmentation should additionally consider landholding, crop cycle, livestock exposure, remittance dependence, local enterprise activity and vulnerability to climate events. A useful strategic question is not merely “How can the bank reach more customers?” but “Which customers can the bank serve sustainably, through which proposition, at what risk-adjusted cost, and with what measurable developmental effect?” 1.2 Competitive positioningThe traditional sources of banking advantage—scale, liquidity, trust and physical presence—are being complemented by data, application programming interfaces (APIs), customer experience and ecosystem access. A bank may pursue one or more of the following positions: | Position | Core promise | Typical capabilities |
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| Relationship bank | Advice, trust and continuity | Skilled staff, local knowledge, customer analytics | | Low-cost digital bank | Convenient and inexpensive transactions | Scalable platforms, automation, cybersecurity | | Specialist rural bank | Context-sensitive agricultural and enterprise finance | Field intelligence, seasonal products, local partnerships | | Ecosystem bank | Integrated financial and non-financial services | APIs, platform partnerships, consent-based data | | Impact-oriented bank | Financial services linked to social and environmental outcomes | Impact measurement, responsible finance, blended capital |
These positions are not mutually exclusive, but an institution cannot excel in all dimensions without clear priorities. Strategic coherence is essential: a low-cost digital model cannot simultaneously depend on expensive manual processes unless those processes are reserved for customers or transactions that generate sufficient value. 1.3 A strategic diagnosisA practical diagnosis combines external and internal analysis. External analysis includes regulation, interest rates, competition, technology, demographics, climate exposure and rural infrastructure. Internal analysis examines capital, liquidity, staff capability, data quality, credit processes, brand trust, systems architecture and governance. The resource-based view argues that sustained advantage arises from valuable, rare, difficult-to-imitate and well-organised resources. In rural banking, a long-standing relationship with farmer organisations, proprietary repayment data and trusted local agents may be more strategically valuable than a sophisticated but poorly adopted mobile application. A strategy should also satisfy three tests: - Value test: Does it solve an important customer problem?
- Advantage test: Can the bank deliver the solution better or more sustainably than alternatives?
- Feasibility test: Are the capital, technology, skills, controls and regulatory permissions available?
2. Performance Scorecards for Strategic Control2.1 From targets to strategic measurementProfit is necessary but insufficient as a measure of banking performance. A bank may report short-term profit while weakening customer trust, underinvesting in cyber controls, mis-selling products or accumulating climate-sensitive credit exposure. A performance scorecard translates strategy into a connected set of financial, customer, process, people, risk and sustainability measures. A balanced scorecard commonly contains four perspectives: financial, customer, internal processes, and learning and growth. For modern banking, risk and sustainability should be explicit rather than hidden within other categories. | Perspective | Illustrative objectives | Possible measures |
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| Financial | Grow risk-adjusted returns | Net interest margin, cost-to-income ratio, return on equity, economic profit | | Customer | Increase trust and useful adoption | Active customers, retention, complaint resolution, customer outcome scores | | Process | Improve speed and control | Turnaround time, straight-through processing, fraud loss, service availability | | Risk | Preserve resilience | Non-performing asset ratio, expected loss, capital adequacy, concentration limits | | Learning and growth | Build future capability | Digital skills, model validation quality, employee retention, innovation pipeline | | Sustainability | Finance transition and inclusion | Green-assets share, financed emissions, rural outreach, vulnerable-customer outcomes |
2.2 Important banking measuresThe cost-to-income ratio is commonly expressed as: Cost-to-income ratio = Operating expenses ÷ Operating income × 100 Operating expenses and operating income must be measured for the same period and under a consistent accounting basis. A lower ratio generally indicates greater operating efficiency, although extreme cost reduction can damage controls or service quality. A simple return on equity measure is: ROE = Profit after tax ÷ Average shareholders’ equity × 100 Average equity is usually the beginning-of-period plus end-of-period equity divided by two. ROE comparisons require caution when banks differ in leverage, accounting policies or risk profiles. Risk-adjusted return on capital (RAROC) can be represented conceptually as: RAROC = (Risk-adjusted income − Operating costs) ÷ Economic capital Risk-adjusted income may include expected loss and relevant funding costs. Economic capital is the capital allocated for unexpected loss at a defined confidence level and horizon. The exact calculation depends on the bank’s risk models and regulatory framework; RAROC should not be treated as a universally standard accounting ratio. 2.3 Scorecard design principlesA scorecard should contain a limited number of indicators with named owners, data sources, reporting frequency, thresholds and corrective actions. Measures should distinguish leading indicators from lagging indicators. For example, rising agricultural insurance coverage and declining overdue field visits may be leading indicators, while rural non-performing assets are lagging indicators. Targets should avoid perverse incentives. If staff are rewarded only for loan disbursement, underwriting quality may deteriorate. A stronger incentive structure combines growth with repayment, customer suitability, complaint outcomes and portfolio diversification. Strategic indicators should also be disaggregated by gender, geography, income category and vulnerability where legally and ethically appropriate. 3. Partnerships and Ecosystem StrategyNo bank can independently provide every capability required for inclusive and sustainable banking. Partnerships may extend distribution, reduce cost, improve information and connect finance with productive activity. 3.1 Partnership models- Business correspondents and agents: provide cash-in/cash-out, account opening and basic service in underserved locations.
- Fintech partnerships: contribute digital onboarding, alternative data, fraud analytics or user-interface capability.
- Farmer producer organisations and cooperatives: aggregate borrowers, support market access and improve monitoring.
- Government partnerships: distribute benefits, guarantees, interest subsidies or disaster assistance.
- Telecommunications partnerships: provide connectivity, identity interfaces and mobile channels.
- Insurance and input providers: combine credit with crop insurance, seeds, equipment or advisory services.
- Development-finance institutions: provide guarantees, concessional funding and technical assistance.
3.2 Partnership governancePartnerships create strategic value but also create dependency, conduct, data, operational and reputational risks. A bank should conduct due diligence on ownership, financial strength, cybersecurity, consumer protection, business continuity, compliance culture and subcontracting arrangements. Contracts should define service levels, data ownership and permitted use, customer-consent standards, audit rights, incident reporting, liability, exit arrangements and complaint handling. Outsourcing a process does not outsource accountability. The regulated bank remains responsible for activities performed on its behalf to the extent required by applicable law. A partnership business case should compare incremental revenue and avoided cost with implementation, monitoring, integration, compliance and expected-loss costs. It should also assess whether the partner improves customer outcomes rather than merely increasing transaction volume. 4. Scenario Analysis and Strategic ResilienceForecasts extend assumptions about the future; scenarios explore how decisions perform under different plausible futures. Scenario analysis is particularly important when uncertainty is high and historical data are unreliable, as in climate events, technology disruption or rapid regulatory change. 4.1 Scenario constructionA robust process includes: - Define the strategic question—for example, whether to expand rural digital lending.
- Identify driving forces, such as rainfall variability, connectivity, competition, regulation and interest rates.
- Select critical uncertainties and create internally consistent scenarios.
- Translate each scenario into customer behaviour, credit quality, funding, costs and capital effects.
- Identify signposts that indicate which scenario may be emerging.
- Choose no-regret actions, contingent actions and actions to avoid.
Illustrative scenarios may include: - Managed digital transition: connectivity improves, regulation is supportive and customers adopt digital services gradually.
- Climate stress: repeated floods or droughts reduce rural income and increase insurance and credit claims.
- Platform disintermediation: large technology firms control customer interfaces and compress bank margins.
- Trust and cyber shock: a major data breach causes customer withdrawal and stricter regulation.
4.2 Quantitative interpretationIf a bank estimates outcomes under several scenarios, an expected value can be calculated as: Expected outcome = ∑(pᵢ × outcomeᵢ) Here, pᵢ is the probability assigned to scenario i, and outcomeᵢ is the measured result under that scenario. Probabilities should sum to one. Expected value is not a prediction; it is a decision aid and can conceal severe downside risk. Therefore, management should also examine the worst case, dispersion of outcomes and capital resilience. For investment appraisal, net present value is: NPV = ∑[CFₜ ÷ (1 + r)ᵗ] − I₀ CFₜ is net cash flow in period t, r is the discount rate per period, t ranges over the project life, and I₀ is initial investment. Cash flows and the discount rate must use the same time unit. NPV is applicable when cash flows can be estimated and the discount rate appropriately reflects risk and funding assumptions. 5. Climate Risk and Green Finance5.1 Climate risk as financial riskClimate risk is not only an environmental issue. It can affect credit, market, liquidity, operational and reputational risk. - Physical risk arises from acute events such as floods, cyclones and heatwaves, and chronic changes such as rising temperatures or water scarcity.
- Transition risk arises when policy, technology, markets or consumer preferences shift toward a lower-carbon economy.
- Liability and reputation risk may arise from misleading claims, inadequate disclosure or financing activities that cause material harm.
For a rural bank, physical risk may reduce farm yields, livestock health, collateral value and borrower cash flow. For a retail bank, it may damage homes, interrupt employment and increase insurance gaps. Transition risk may affect borrowers in carbon-intensive industries or assets that become obsolete. A simplified expected credit loss relationship is: Expected loss = Probability of default × Loss given default × Exposure at default Probability of default is the likelihood that a borrower defaults over the specified horizon; loss given default is the proportion not recovered after default; exposure at default is the amount outstanding or otherwise exposed. Climate variables can influence all three components. This simplified expression omits discounting, scenario weighting and model-specific adjustments used in advanced frameworks. 5.2 Climate-risk managementBanks should map financed exposures to climate-sensitive sectors and locations, assess collateral vulnerability, incorporate climate information into underwriting where reliable, and conduct stress tests. They should avoid automatic exclusion of vulnerable communities: withdrawal of finance can worsen adaptation capacity. A better response may combine adaptation lending, insurance, resilient collateral assessment, moratoria governed by clear policy and technical assistance. Governance should assign board and senior-management responsibility, define risk appetite, establish data standards and require independent model validation. Climate disclosures should be accurate, comparable and proportionate to the quality of available data. 5.3 Green and transition financeGreen finance supports activities with credible environmental benefits, such as renewable energy, energy efficiency, clean transport, sustainable agriculture and climate-resilient infrastructure. Transition finance supports borrowers moving toward lower-impact operations even if they are not already green. Both require transparent taxonomies, eligibility criteria, monitoring and safeguards against greenwashing. A green loan is not automatically sustainable merely because its label contains the word “green.” The bank should verify use of proceeds or performance targets, establish reporting requirements and address social impacts. In rural markets, examples include solar irrigation, efficient cold storage, water-saving equipment, agroforestry and climate-resilient housing. 6. Platform Banking, AI and Data GovernancePlatform banking uses a modular architecture in which banking services are delivered through digital interfaces and connected partners. APIs may allow verified third parties to access permitted services with customer consent. Benefits include broader distribution, faster innovation and integrated propositions. Risks include concentration in dominant platforms, cyberattack propagation, unclear accountability, exclusion of digitally weak customers and misuse of personal data. Artificial intelligence can support fraud detection, customer service, credit assessment and collections. However, models may reproduce historical discrimination, rely on poor-quality alternative data or become unintelligible to customers and supervisors. Good practice includes purpose limitation, data minimisation, explainability appropriate to the decision, human review for consequential decisions, monitoring for bias and model-drift controls. Digital inclusion requires assisted channels, accessible design, local-language support, offline or low-bandwidth functionality and effective grievance redress. A technically advanced service that excludes elderly, disabled, low-literacy or intermittently connected customers is not an inclusive strategy. 7. CBDCs and the Future of InclusionA central bank digital currency is a digital form of central-bank money intended for use by the public or, in some designs, financial institutions. It differs from commercial-bank deposits, which are liabilities of commercial banks, and from privately issued crypto-assets, whose value and governance vary widely. Potential CBDC benefits include efficient payments, programmable disbursement in carefully governed settings, resilience and reduced transaction costs. Possible risks include privacy loss, cyber vulnerabilities, operational outages, bank deposit migration and excessive state or platform surveillance. Design choices concern remuneration, holding limits, offline capability, intermediaries, identity, privacy, interoperability and consumer protection. CBDCs should be evaluated against the problem they are intended to solve. If the problem is expensive remittances, interoperability may matter more than programmability. If the problem is disaster payments, offline access and resilient identity may be more important than sophisticated smart contracts. Inclusion requires alternatives for people without smartphones, stable connectivity or formal identification. Future inclusion models are likely to combine public infrastructure, regulated intermediaries, community institutions, responsible data use, interoperable payments, embedded finance and financial education. Inclusion should be assessed by effective use and improved welfare—not merely by the number of accounts opened. 8. Integrated Strategy FormulationAn integrated strategic plan can follow this sequence: - Diagnose: map customer needs, competition, climate exposure, technology and institutional capability.
- Choose priority segments: identify where the bank can create distinctive and responsible value.
- Design propositions: combine products, advice, channels, pricing, safeguards and partnerships.
- Set risk and sustainability boundaries: define exclusions, concentration limits, data rules and outcome standards.
- Build capabilities: invest in people, architecture, analytics, cyber resilience and local relationships.
- Pilot and learn: test propositions with measurable hypotheses before scaling.
- Measure outcomes: use the scorecard, scenario indicators and customer-impact evidence.
- Review dynamically: revise strategy when signposts, regulation, technology or climate conditions change.
Applied Case: Sunrise Cooperative Bank (Illustrative)BackgroundSunrise Cooperative Bank serves small farmers, rural traders and low-income households across three districts. It has a trusted branch network but rising operating costs, low digital adoption and increasing delinquencies after irregular rainfall. A fintech proposes a digital lending partnership using transaction and merchant data. A development institution offers a partial guarantee for solar irrigation loans. ProblemThe board must decide whether to expand digital credit rapidly, invest in assisted digital channels, or prioritise climate-resilient lending. It is concerned about data consent, over-indebtedness, partner dependence and the effect of drought on repayment. AnalysisThe bank’s diagnosis shows strong local trust and recovery knowledge but weak analytics and fragmented systems. Rapid unsecured expansion could increase adverse selection and conduct risk. Climate exposure is concentrated in water-dependent crops. The guarantee reduces loss severity but does not eliminate borrower cash-flow risk. Management constructs three scenarios: normal rainfall, moderate drought and severe drought. It estimates repayment, operating cost and capital effects under each scenario, then identifies rainfall data, insurance claims and early arrears as signposts. The scorecard includes rural active customers, repayment by crop, complaint resolution, digital completion rates, fraud losses, green-loan performance and staff capability. Approach and solutionSunrise adopts a staged strategy. It pilots digital applications through trained agents, retains human credit review for vulnerable borrowers, and requires explicit consent for alternative data. Loans are linked to solar irrigation only where technical feasibility and repayment cash flow are demonstrated. The development guarantee is used to support, not replace, underwriting. The bank partners with an insurer and farmer organisations, establishes drought-triggered restructuring rules, and limits portfolio concentration by crop and geography. The board receives quarterly scenario updates. Partner contracts include audit rights, incident reporting, data deletion requirements and customer grievance standards. Incentives reward repayment quality and customer outcomes rather than disbursement alone. OutcomeAfter the pilot, application turnaround improves and operating cost falls for routine transactions. However, the bank rejects rapid scale-up because severe-drought stress remains material. It expands assisted digital services and climate-resilient products gradually while strengthening data governance and capital planning. Learning pointsThe case demonstrates that competitive strategy is a portfolio of choices, not a race toward digitisation. Partnerships are valuable when governed actively. Climate adaptation can support both inclusion and risk management. Scenario analysis helps management avoid strategies that appear attractive only under favourable conditions. Challenges, Ethics and RegulationStrategic banking faces several persistent tensions. Digital efficiency may conflict with accessibility; data-driven lending may conflict with privacy; green finance may conflict with short-term profitability; and aggressive inclusion targets may encourage unsuitable lending. These tensions cannot be solved by technology alone. Boards should require clear accountability for customer outcomes, fair treatment, responsible pricing, privacy, cybersecurity and financial crime prevention. Customers should receive understandable disclosures, meaningful consent choices and accessible complaint mechanisms. Vulnerable customers should not be penalised automatically when climate or livelihood shocks occur, but relief should follow transparent rules and preserve repayment incentives. Regulatory compliance should be treated as a baseline, not the complete definition of responsible banking. Banks should maintain capital and liquidity buffers, test operational resilience, validate models, control outsourcing and report material risks accurately. Green claims, impact claims and inclusion claims must be supported by evidence. Best-Practice ChecklistA strategically sustainable retail or rural bank should: - connect every major initiative to a customer problem and measurable outcome;
- combine profitability with risk-adjusted and sustainability indicators;
- use scenario analysis for climate, cyber, liquidity and platform disruption;
- govern partners as extensions of the bank’s service chain;
- design inclusive channels for low-connectivity and low-literacy users;
- validate AI and alternative-data models for bias, drift and explainability;
- distinguish green finance from credible transition finance;
- protect privacy and provide effective grievance redress;
- maintain human judgement for consequential decisions; and
- review strategy as evidence and conditions change.
Chapter SummaryStrategy in retail and rural banking is the disciplined selection of customers, propositions, capabilities, channels and risk boundaries. Competitive advantage may arise from trust, local knowledge, digital efficiency, specialist rural capability or ecosystem coordination. A balanced scorecard converts strategy into measurable financial, customer, process, risk, learning and sustainability outcomes. Partnerships extend reach and capability but require due diligence, contractual controls and active oversight. Scenario analysis improves resilience by testing strategies under plausible combinations of economic, climate, technology and regulatory conditions. Climate risk affects credit, market, operational and reputational outcomes; green and transition finance require credible definitions, monitoring and protection against greenwashing. Platform banking, AI and CBDCs may reduce costs and expand access, but they introduce privacy, cyber, concentration, exclusion and accountability risks. The future of inclusion will depend on interoperable infrastructure, responsible data, assisted service, community institutions and outcome-based measurement. Sustainable banking therefore integrates commercial performance with resilience, ethics, customer welfare and environmental responsibility. Key TermsBalanced scorecard: A framework translating strategy into financial and non-financial objectives and measures. CBDC: Digital central-bank money designed for public or institutional use. Climate risk: Financial risk arising from physical climate effects and transition to a lower-carbon economy. Cost-to-income ratio: Operating expenses divided by operating income, expressed as a percentage. Economic capital: Capital allocated to absorb unexpected loss at a specified confidence level. Expected credit loss: An estimate of credit loss incorporating default likelihood, exposure and recovery assumptions. Financed emissions: Emissions associated with activities funded through a financial institution. Green finance: Finance supporting activities with credible environmental benefits. Greenwashing: Misleading presentation of a product or activity as environmentally beneficial. Inclusion: Effective, affordable and suitable access to useful financial services. Platform banking: Delivery of banking services through connected digital platforms and partners. RAROC: Risk-adjusted return on capital. Scenario analysis: Examination of strategy or risk outcomes under alternative plausible futures. Transition finance: Finance supporting credible movement toward lower-impact operations. Value proposition: The benefits and experience promised to a defined customer segment. Vulnerability: Increased exposure to harm because of economic, social, environmental or digital conditions. Climate physical risk: Loss arising directly from acute or chronic climate effects. Climate transition risk: Loss arising from policy, technology, market or preference changes during decarbonisation. Review QuestionsShort Answer Questions- What is meant by strategic coherence in retail banking?
- Identify the major perspectives of a modern banking scorecard.
- Distinguish physical climate risk from transition risk.
- State two governance requirements for fintech partnerships.
- Why should financial inclusion be measured by outcomes rather than accounts opened?
Long Answer Questions- Explain how a retail or rural bank can develop a competitive position using customer, capability and ecosystem analysis.
- Design a balanced scorecard for a bank seeking simultaneous digital growth and rural inclusion.
- Discuss the benefits and risks of platform banking and artificial intelligence.
- Explain how climate risk can affect credit risk and how banks can respond without abandoning vulnerable borrowers.
- Evaluate the potential benefits, risks and design choices associated with CBDCs.
Analytical / Application Questions- A rural bank’s digital-loan portfolio is growing rapidly, but early arrears and customer complaints are increasing. Use scorecard logic and partnership governance to recommend a management response.
- Construct three plausible scenarios for a bank financing agriculture in a drought-prone region. Identify signposts, no-regret actions and contingent actions.
- A bank is considering a guaranteed portfolio of solar irrigation loans. Analyse the proposal using expected credit loss, climate resilience, customer suitability, green-finance credibility and operational capability.
Multiple Choice Questions with AnswersQuestion 1Which measure most directly combines risk-adjusted income with capital consumed? A. Cost-to-income ratio B. RAROC C. Customer retention rate D. Net promoter score Correct Answer: B. RAROC Question 2In the simplified expected-loss relationship, which three components are multiplied? A. Interest rate, inflation and liquidity B. Probability of default, loss given default and exposure at default C. Revenue, expenses and equity D. Capital, deposits and branches Correct Answer: B. Probability of default, loss given default and exposure at default Question 3Which is an example of physical climate risk for an agricultural borrower? A. A new carbon tax B. A change in disclosure rules C. A prolonged drought reducing crop yield D. A competitor launching a mobile app Correct Answer: C. A prolonged drought reducing crop yield Question 4What is a principal reason for using scenario analysis? A. To guarantee a single accurate forecast B. To explore performance under plausible alternative futures C. To eliminate the need for risk governance D. To replace all financial statements Correct Answer: B. To explore performance under plausible alternative futures Question 5Which partnership control is most appropriate when a fintech handles customer data? A. No audit rights are required B. Unlimited secondary use of data by the fintech C. Defined consent, permitted use, security and incident-reporting requirements D. Transfer of all regulatory accountability to the fintech Correct Answer: C. Defined consent, permitted use, security and incident-reporting requirements Question 6A cost-to-income ratio is calculated as: A. Operating income ÷ operating expenses × 100 B. Operating expenses ÷ operating income × 100 C. Profit ÷ deposits × 100 D. Loans ÷ equity × 100 Correct Answer: B. Operating expenses ÷ operating income × 100 Question 7Which feature most supports inclusive digital banking in low-connectivity regions? A. Smartphone-only access B. High minimum balances C. Assisted channels and low-bandwidth functionality D. Exclusion of human service Correct Answer: C. Assisted channels and low-bandwidth functionality Question 8What distinguishes CBDC from a commercial-bank deposit? A. CBDC is a liability of the central bank B. CBDC is always privately issued C. CBDC cannot be used for payments D. CBDC has no regulatory implications Correct Answer: A. CBDC is a liability of the central bank Question 9Which practice helps prevent greenwashing? A. Using environmental labels without evidence B. Avoiding all monitoring after disbursement C. Applying clear eligibility criteria and reporting use or outcomes D. Treating every transition loan as automatically green Correct Answer: C. Applying clear eligibility criteria and reporting use or outcomes Question 10Why should bank staff incentives combine loan growth with repayment and customer-outcome measures? A. To encourage volume without controls B. To reduce the relevance of risk management C. To limit incentives for unsuitable or poor-quality lending D. To eliminate the need for customer service Correct Answer: C. To limit incentives for unsuitable or poor-quality lending
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