Vietnam sets 8% capital floor and daily liquidity tests for people's credit funds

Implications for lenders

For a cooperative lender, collateral type now changes capital use directly: a loan fully secured by housing or land carries 50% risk weight against 100% for most other loans, under a 8% capital floor. Lending to non-members is limited to their deposits with the fund, so growth may depend on recruiting members and savers. Daily liquidity checks at 100% may make long-tenor lending funded by short-term deposits harder to expand.

Implications

Facts

The rule: the State Bank of Vietnam (SBV) issued Circular 40/2026/TT-NHNN on 10 August 2026. It took effect on 1 November 2026 and replaces Circular 32/2015/TT-NHNN and Circular 13/2024/TT-NHNN as the set of prudential limits for people's credit funds, the member-owned cooperative lenders that operate at commune level.

Capital: funds must keep a capital adequacy ratio of at least 8% ¹. Loans fully secured by housing, land-use rights or both carry a risk weight of 50% ². Cash, deposits at the SBV and loans fully secured by the fund's own deposits carry zero weight, while fixed assets and all assets outside the lower-weight groups carry 100% ³.

Liquidity and funding: at the end of each working day, a fund must hold a payment-ability ratio of at least 100% ⁴ for both the next working day and the next seven working days. No more than 30% ⁵ of short-term funds may be used for medium- and long-term lending, and total deposits may not exceed 20 times ⁶ owners' equity. A fund is treated as at risk of insolvency after a liquid-asset shortfall of 20% or more for 30 consecutive days ⁷.

Lending limits: loans to a customer who is not a member are capped at that customer's deposit or savings balance with the fund, and loans to a legal-entity member are capped at its capital contributions plus deposits. SBV regional branches may impose stricter limits based on supervision results.

Sector size: SBV statistics cited by Thoi bao Tai chinh Viet Nam put the network at 1,177 ⁸ funds with about 1.95 million ⁹ members at end-2024, and outstanding credit of about VND 138.7trn ¹⁰, or about VND 117.9bn ¹¹ per fund on average.

Analysis

Cross-country comparison: Vietnam's community lending runs through many small cooperatives, while Cambodia's runs through fewer, larger institutions. Vietnam had 1,177 people's credit funds with about 1.95 million members at end-2024. Cambodia had 89 ¹² microfinance institutions at end-2025, and members of the Cambodia Microfinance Association served 1.53 million ¹³ borrowers with a portfolio of USD 5.99bn ¹⁴. The two client counts are not strictly comparable, since Vietnamese members include savers as well as borrowers.

What the rules reward: the design ties lending to the fund's own membership and deposits. Non-members can borrow only against what they hold with the fund, and housing or land-backed loans need half the capital of most other loans. A daily liquidity test covering the next seven working days, together with the deposit-to-equity cap, limits how fast a fund can grow its book on deposit funding alone. Small funds with an average book of about VND 117.9bn may find daily ratio reporting a heavier operational task than larger lenders do.

Counterpoints and uncertainties

The sector figures date from end-2024 and the network may have changed since; the source gives no exact non-performing loan ratio for the funds. Specially controlled funds are exempt from several of the limits, and SBV regional branches can set stricter ones, so the binding constraint can differ by fund. How much the new circular tightens each ratio relative to the replaced rules will determine the adjustment burden for each fund.