Micro Finance South Africa v Minister of Trade and Industry and Another q (16746/2016) [2016] ZAGPPHC 1153 (22 November 2016)

52 Reportability
Administrative Law

Brief Summary

Administrative Law — Review of Regulations — Applicant, representing micro lenders, challenged the legality of new regulations promulgated by the Minister of Trade and Industry under the National Credit Act, claiming the Minister failed to consider relevant factors and consult stakeholders adequately — Court held that the Minister's decision to publish the new regulations was reviewable due to the failure to take into account essential considerations affecting the micro lending industry, thereby rendering the regulations invalid.

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[2016] ZAGPPHC 1153
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Micro Finance South Africa v Minister of Trade and Industry and Another q (16746/2016) [2016] ZAGPPHC 1153 (22 November 2016)

IN
THE HIGH COURT OF SOUTH AFRICA
GAUTENG
DIVISION,   PRETORIA
Reportable:
NO
Of
interest to other judges: No
Case
No: 16746/2016
Date:
21/11/16
In the
matter between:
MICRO
FINANCE
SOUTH
AFRICA
Applicant
and
THE
MINISTER  OF  TRADE
AND
INDUSTRY
First Respondent
THE
NATIONAL
CREDIT
REGULATOR
Second  Respondent
JUDGMENT
J
W LOUW,
J
[1]
The applicant is a
registered non-profit company which represents approximately 500
individuals or corporate entities who are
providers  of
short term credit and who are colloquially referred  to  as
'micro  lenders'. They operate approximately
1190 branches
throughout the country. The applicant alleges that it represents
about 30% of  the  micro  lending
industry in
the country. In terms of regulation 39(2)(a) of the regulations
published in terms of the National Credit Act 34 of
2005 (the NCA)
on  31  May 2006 (the previous regulations), a short term
credit transaction is a transaction in respect
of a loan  not
exceeding  RS 000.00  which  is repayable  within
a period not  exceeding
six months.
[2]
Section 171(1) of the NCA
empowers the  Minister  of  Trade  and Industry
(the  first  respondent)
to  make
regulations  expressly  authorised or contemplated
elsewhere in the Act in accordance with
ss  (2).
Sub­ section (2) provides that before  making  such
regulations,  the  Minister
must publish the
regulations for public comment and may  consult  the
second respondent,  the National
Credit  Regulator
(the  regulator).
[3]
Section 101 of Part C of
Chapter 5 of the NCA permits, subject to limitations, the charging of
interest, an initiation fee and a
service fee in a credit
agreement.   In  terms  of s 105(1),  the
Minister-
after consulting  the  regulator,
may prescribe  a method  for calculating-
(a)
a maximum
rate of interest;
and
(b)
the maximum fees
contemplated in Part C applicable to each subsector
of the  consumer
credit  market, as determined  by the Minister.
Short
term credit  is one such  subsector.
[4]
Regulation 42 of Part C of Chapter 5 of the previous regulations
prescribed the maximum interest rate, maximum  initiation

fee  and  maximum service fee for short term credit
transactions. In terms  of  regulation 45(1), the
regulator
must  perform  a  review  of
interest  rates  and cost factors at intervals of no more
than
3 years  and  advise  the  Minister of any
changes  that  may  be required.
It
is common  cause  that this was not done. The
regulator's failure to comply  with regulation  45(1)
led
to litigation in terms whereof the regulator and  the
Minister  were  ordered to comply with their obligations

within a stipulated period of time. They  failed to comply
with that court order  and a further  court order,
both
of which  led to  contempt applications.
[5]
The Minister thereafter,
on 26 June 2015, published new  draft regulations for public
comment. On  6  November
2015,  the
regulations were promulgated by the Minister to take effect  on
6 May  2016.  On
1 March  2016, the applicant
launched  the present application  against
the
Minister and
the regulator.
It
was
contended by Mr Carstensen  who appeared on behalf of the
regulator that the  applicant  should  be
non­
suited because it unreasonably delayed the bringing of the
application. I disagree. The draft regulations were published
on 25
June 2015, but the  final regulations were only published on
6  November  2015.  The application,
which is
substantial, was brought within less than 120 days thereafter. Part A
of the notice of motion  was  an
urgent
application  in which the applicant sought to stay the
implementation of the regulations pending the review of
the
regulations which was sought in part B of the  notice of motion.
The urgent application was heard by Meyer J on 3 May
2016 and was
dismissed. In part B of the notice of motion, which is the
application now before court, the applicant originally
sought an
order reviewing and setting aside all of the regulations. It
has since decided  to  limit the relief
sought to an order
reviewing  and  setting  aside  the regulations
insofar as they relate to  short term
credit.  The
review  record was only filed by the respondents on  8
June  2016,  whereafter
the applicant filed a
supplementary founding affidavit. The respondents filed
supplementary  answering  affidavits to
which the
applicant filed a   reply.
[6]
Section 105(2)  of
the NCA provides as  follows:
(2) When
prescribing a matter contemplated in subsection (1), the Minister
must consider, among  other things-
(a)
the  need to
make credit available to persons contemplated  in section
13
(a)
[1]
;
(b)
conditions
prevailing in the credit market, including the cost of credit and the
optimal functioning of the consumer credit market;
and
(c)
the
social impact on low income
consumers.
[7]
Regulation
45(2)    of   the   previous
regulations
provided    that
the regulator must, when making a recommendation to the Minister,
consider
(a)
ruling interest rates
and fees;
(b)
cost of providing
such
credit;
(c)
the choice available
to consumers in the particular category of credit agreements,
between different  products
and different  credit
providers;
and
(d)
the impact upon
access to finance for persons referred to in section
13(a)
of
the Act.
[8]
The applicant contends
that the above mandatory requirements were not complied with by the
Minister and the regulator, and that
the  Minister's
decision to publish the new regulations is  accordingly
reviewable in terms of sections 6(2)(e)(iii)
and/or
6(2)(e)(vi)  and/or  6(2)(h) of PAJA. In terms of s
6(2)(e)(iii), an administrative decision is reviewable
if irrelevant
considerations were taken into account or relevant considerations
were not taken into account.  In  terms
of s 6(2)(e)(vi),
it
is
reviewable if  it  was  taken
arbitrarily  or  capriciously.  In  terms
of
s 6(2)(h), it is reviewable if the exercise of the
power or the performance  of  the function authorised by
the
empowering provision  is  so unreasonable  that no
reasonable person could have  so  exercised  the

power  or performed  the function.
[9]
The  maximum
interest  rate  prescribed  in  terms  of
regulation  42  was 5%
per  month  for
short  term  credit  transactions,  the
maximum  initiation
fee was R150 per credit agreement
plus  10%  of  the  amount  of  the
agreement in excess of
R1 000, but never  to  exceed
R1  000,  and  the  maximum monthly service
fee  was
R50.  In  terms  of  the
new  regulations, the maximum prescribed interest rate  is
5%
per  month  on  the  first  loan
and 3% per month on subsequent loans  within  a  calendar

year.  The  maximum initiation fee is  R165  per
credit  agreement  plus  10%  of
the amount
in excess of R1 000, but never to  exceed  R1  050.
The  maximum monthly  service
fee  is
R60.
[10]
In the founding affidavit
in the urgent application it  is stated that  prior to the
promulgation of the new regulations,
a period of no less than nine
years had passed without them being renewed. This, the applicant
states, gave rise to an untenable
situation. As a result of inflation
and certain other additional expenses (such as payment streams), the
members   of
the  applicant   found
it   increasingly   difficult   to
conduct
business. When the new regulations were finally
promulgated the entire industry was of the hope that the new
regulations would remedy
the  situation and provide a new
lease of life in the micro finance industry. However, upon closer
scrutiny it became apparent
that in issuing the new regulations the
respondents had failed to take into account  the effect that the
new fees and interest
rates would have on  the  providers
of  micro loans; failed to conduct proper market  research
in order  to  determine  if the new fees and interest
rates would be beneficial to the market  as a  whole;
and
failed to consider the views of the members of the applicant or any
of the micro financiers in the industry. The net effect
of the new
regulations, the applicant states, is effectively to  bring
the  entire  micro  loan industry
to its knees and
make it impossible to conduct business, let alone a profitable
business.
[11]
The applicant further
states that the new regulations  do  not  only
affect its members personally,  but
that  there
will be an enormous  knock on effect on the South African public
as a whole. Some  5  to
6 million  people make
use of micro financiers for  funding.
It
is  a  niche
market which is not served by the traditional banks.  By
taking  a  substantial
portion of the members of the
applicant  out  of  the  market,  those
members of the public that
require credit will not be able to
obtain  credit from legitimate sources and an enormous increase
of unregistered credit
providers  is a real
possibility.
[12]
Having regard to the
above and to the opinions  of  three  experts
which the applicant has presented, the applicant
contends that the
respondents have failed to promote equity  in  the
credit  market  as  required
by s 3(d) of the NCA by
balancing the respective rights and responsibilities of credit
providers and  consumers.  The
applicant  states
that no account has been taken of the rights,  interests
and  obligations  of
its members and that, ironically, the
individuals who  will  be most affected are the members of
the general public who
will be forced to obtain finance from
unregulated and unregistered sources, thereby increasing  the
prospects of them
being
exploited.
[13]
The applicant points out
in its supplementary founding affidavit that there is nothing
contained in the record which  was
furnished  by
the Minister which indicates that any member of the applicant or any
of their customers was approached
in the assessment which was done
and that it was obvious that the entire short term credit
industry  was,  to
all intents and purposes, ignored.
More particularly, the applicant states, the respondents did not take
into account  the
typical  short  term
credit provider  or the individuals  which  they
serve.
[14]
Although these
allegations are denied by the Minister in his supplementary
answering  affidavit,  he  has
not
provided  any  evidence to
the contrary. The
regulator states in his supplementary answering affidavit that in
making the recommendation to the Minister, the
balance between the
rights of the consumer and the credit providers was considered. He
does, however, not give any information
of how this was done.
[15]
The regulator denies that
the interests  of  the  short  term  credit
industry were ignored, and relies
in this regard on a report by
PricewaterhouseCoopers (PWC) who the regulator commissioned in
February 2015 to carry out an assessment
of the impact of changing
the current maximum interest rates,  initiation  fees
and  service  fees.
There are, however, a number of
difficulties  arising  from  the  PWC report.
The first is that
the report itself states that the results for short
term credit transactions are based on insufficient responses and can
therefore
not be relied  upon.  The applicant  further
points  out that  PWC  was not instructed to do an
analysis
of the  interest  rate  as recommended
by  the  regulator and ultimately promulgated.  It

was  only  instructed  to  assess
scenarios  for interest rates of 5%, 7%
and
10%.  The regulator  admits this,  but says that the
impact of the proposed interest  rate changes
had
already  been researched prior to the appointment of PWC. In
support of this statement, the regulator attaches a
letter which was
addressed to Capitec Bank on 14 August 2014 which it says is an
example of numerous letters which  were
dispatched
inter  alia
to  Bayport
Financial  Services  (which
it
says is a
significant player in the short term credit industry) and  other
banking institutions such as ABSA.
It
is further  stated that engagements  with
approximately 19 credit  providers  were  undertaken.
The
regulator goes on to say that the applicant and its members
are a small part of the credit industry as a whole, and is not a key

player in the short term credit industry.   The letter to
Capitec  Bank  states the  following:
"1.
In terms of
Regulation 45 of the National Credit Regulations,
2006,
the National Credit
Regulator (NCR) must perform a review of interest rates and cost
factors at intervals of not more than three
(3) years and advise the
Minister of Trade and Industry of any changes that may be required.
When making the recommendation to
the Minister, the NCR must consider
the ruling interest rates and fees, the cost of providing credit, the
choice available to consumers
in the particular category of credit
agreements between different products and different credit providers
and the impact upon access
to finance for persons referred to in
section 13(a)
of the
National Credit
Act.
2.
The
NCR has
commenced with work for this review
with
conceptual scenarios which will ultimately  inform  the
rationale  for  the  regulations
to be issued by
the dti. The NCR envisages that these regulations will be implemented
after extensive consultations with industry
stakeholders and testing
by selected credit providers to determine their impact on the credit
market.
3.
The NCR
hereby invites Capitec Bank to participate in the testing of the
different scenarios in relation  to  this work.
Further
details  will be provided to Capitec Bank once the response to
the invitation has been    received."
[16]
The regulator does not
say whether Capitec or any of the  other  banking
institutions responded to the invitation.
It
does  not
give  any  further information about the research which it
says it conducted. The deponent to the
applicant's supplementary
founding  affidavit  states  that only one short term
credit provider provided PWC with
any  evidence,  namely
First Rand Bank.   This is not denied by the
regulator.
[17]
In regard to the
PWC report,  the  regulator  states  that
the  report  must be seen as an impact
assessment report
and not as an original piece   of research to enable it to
discharge its  statutory  duties.
The  regulator
states that the report was considered by it  and  that
its  contents  were
found to be at odds with the
envisaged course of action  to  be  recommended
to  the  Minister,
a  significant  portion
of  which  was,
inter
alia,
based  on  consumer
interests.  As  is  pointed  out  by
the    applicant,
there is, however, no evidence or
documentation which could justify why the regulator departed from the
PWC recommendations. PWC
observed in their report that actual costs
over a period have increased on an annual basis and that these
increases had not been
met by corresponding raises in the maximum
fees chargeable. The direct result of this was a gradually widening
gap between actual
costs on loans disbursed and maximum fees
chargeable. In view of the fact that the fees  had not
been reviewed
for  such a long period of time, PWC
recommended a two-fold solution for the situation. First, that there
should be a rebase
of the maximum fees  chargeable and, second,
to prevent the rebased fees from falling behind actual cost
increases, that an
annual  CPI adjustment  be  applied.
[18] Mr
Michau, who appeared for the applicant,
inter
alia
referred to the
following passages in  the  judgment  of the
Constitutional Court in
Minister
of Health and Another  v New Clicks South Africa (Pty) Ltd and
Others :
[2]
[391]
The Pricing Committee
seems
to have  calculated
the
dispensing
fee  without any
evidence of the breakdown of the income and expenditure of the
dispensaries, information they considered to
be important for the
proper determination of the dispensing fee.  They  assumed
that  dispensing  subsidises
the operations of the front
shops of community pharmacies. They have not, however, provided any
evidence to support this assertion,
which is denied by the
Pharmacies. As Dr Stillman points out, it is unlikely that front
shops would be operated if they were indeed
loss-making ventures.
The Pricing Committee  does not say what weight was attached to
this assumption in the calculation
of the dispensing
fee.
………………………
..
[393]
The Minister and the Pricing Committee do not deal with the impact of
the dispensing fee on rural pharmacies. Professor McIntyre
says that
the Pricing Committee considered the predicament of rural pharmacies
which are 'economically disadvantaged, primarily
because of a
comparatively  low  turnover and also unfavourable payment
conditions from wholesalers'. They concluded,
however, that
this  is  the result  of  'distortions  in
the  health  sector'
and  that 'an appropriate
dispensing fee should be as neutral as possible in respect of such
distortions'. No mention is made
of what  those
distortions  (if  any)  are,  other  than
low turnover and adverse payment conditions.
Moreover,  they
do  not  suggest how these distortions could be overcome,
what the impact of the  dispensing
fee will be on the
economically disadvantaged rural pharmacies, and how that will affect
access to  medicines in rural  areas.
………………………
..
[403]
The Pricing Committee has
provided no models or other evidence to demonstrate how the
dispensing fee was calculated or how the members
of the Pricing
Committee satisfied themselves that it was appropriate. It has not
told us what assumptions  it  made
about the probable SEPs
in calculating  the  dispensing
fee, or how it
assessed the dispensing fee when it seems to have had no data dealing
with dispensary revenue and expenses which
it considered to be
essential for that purpose.
It has not addressed in any meaningful
way
the
contention
that
the  dispensing
fee
will  lead
to
pharmacy
closures
that
will
impair accessibility   to
health  care,  particularly   in  rural
areas.
The
assertions
made by
Professor McIntyre and Dr Zokufa about additional revenue sources and
the subsidisation of the front shop by the back shop
are,  at
best,  flimsy.  The failure to make provision for
compounding in the dispensing fee is a material
misdirection.
………………………
..
[510]
What lies at the heart of
the challenge
to
the
dispensing
fees  is
the
contention that  the  dispensing
fees  as  determined
in  the
regulations
are
not
viable
for pharmacies and will drive them out of  business.
In
effect
the pharmacies contend that, in
determining the dispensing fees,
the
Pricing
Committee did not have due regard to the viability of the dispensing
fees for pharmacies, as they were bound to do. This
contention was
upheld by the SCA, which in effect concluded  that  the
fees  were not  viable for  pharmacies.
Failure
by a decision-maker to take into account a relevant
consideration  in  the  making  of
an
administrative decision is an instance of an abuse of discretion. As
pointed
out earlier, this is a ground of review
which is expressed  ins  6(2)(e)(iii)    of
PAJA.
[511]
There is obviously an overlap between the ground of  review
based  on  failure to take into consideration
a relevant
factor and one based on the unreasonableness of the decision. A
consideration of the factors that a decision­ maker
is bound to
take into account is essential to a reasonable decision. If a
decisionmaker fails to take into account a factor that
he or
she is bound  to take  into consideration, the resulting
decision can hardly be said to be that of a reasonable
decisionmaker.
It seems to me to follow that if, in determining the dispensing
fees,  the  Pricing Committee
was bound  to take
into consideration the
viability
of the fees for pharmacies, but  failed  to  do
so
properly,
the  resulting fees can hardly be said to  be one that a
reasonable Pricing Committee could
fix.
[512]
As I  see it,  therefore,
the
central  question  in  this  case  reduces
to
whether
the Pricing
Committee gave proper consideration to the viability of pharmacies
in
fixing the
dispensing fees. This question raises two
separate,
but
related,
questions. The first is whether the Pricing Committee was bound, in
fixing an appropriate dispensing fee pursuant to
s
22G(2)(b)
,
to
have
regard
to
the viability of
pharmacies,
so
that failure to do
so
amounted
to failure to take into account a consideration relevant to the
determination of an appropriate fee. The second question,
which only
arises if the first question is answered in
the affirmative,
is whether the Pricing Committee gave due regard to the viability of
pharmacies.
………………………
..
[518]
As the  SCA held,  an appropriate  dispensing
fee must  be fair and   just. Indeed
it can hardly be
argued that a dispensing fee that is unjust or unfair is appropriate.
The dispensing fee must be fair not only to the public, but also
to
pharmacies
. The fee must  not be
such that  it  will render  medicines
inaccessible  to the general public.
Nor must it be such that it
pharmacies out of business. Its determination requires a
consideration of conflicting interests of
the public, who are
entitled to access to affordable medicines, on the  one hand,
and the interests  of dispensers
who,  in terms of
the Act, are essential  to  the  public for the supply
of medicines and whose economic viability
is implicitly
recognised  by the  Act and is of  'national
importance', on the other   hand.
………………………
..
[526]
Once it is accepted, as it must be, that pharmacists are crucial to
the objectives of the Medicines Act, it must also be accepted
that
there is a need for them to survive. But those who are
involved  in  the  pharmaceutical  industry

do
so
for
profit.
An appropriate
dispensing fee must be rationally related to the
cost
of doing business. It must be such that it makes it worthwhile for
pharmacies  to remain in business
.
And the economic viability of pharmacies
is
implicitly recognised by
the Medicines Act. As the Australian Federal Court observed in the
context  of price fixing
for  pharmaceuticals
in  that country.
………………………
..
[531]
The Pricing Committee  and the  Minister  must
therefore  do more  than pay lip service to
the viability
of pharmacies. They must address the need for pharmacies to exist in
a meaningful way when fixing the appropriate
fee, and be able to
demonstrate that they  have done
so.
This could  be done
by  explaining
the
manner in which the viability of pharmacies  was given effect.
They  must
give an explanation of how the appropriate fee was calculated. This
explanation
is
crucial to the
process of determining an appropriate  fee. It  explains
to  the
public
and the pharmaceutical industry the manner in which the  fee
was  arrived  at.  It discloses  the

reasoning  process  of  the  Pricing
Committee.  And  it  enables those who have
an
interest  in  the  fee  to  assess
whether  the  Pricing Committee
has
properly discharged its statutory duty. This explanation
should generally be contained in the report  of  the
Pricing
Committee  making  a  recommendation
to the Minister.
………………………
..
[535]
What is singularly lacking
in
the
record
is  an  explanation  of
how
the
dispensing fees were
arrived at. There is no explanation  as  to  why
the
Pricing
Committee chose the
figures  that  it  chose.
While the Pricing
Committee indicated    that the fee covers both the
professional  remuneration  and
operating
costs,  it does not explain what was allocated to  each
of  these component  parts
of  the fee. As the
SCA observed, 'except for a general  statement  that all
factors  were  taken  into
account,  there is no
evidence or document that shows what those  factors  were,
what  weight they bore,
whether any calculations were made and,
more particularly,  whether  any  regard  was
given to  the viability
of the dispensing profession'.
It
was
this lack  of  explanation  for  quantum
of  the  dispensing  fees  that
led
the
SCA
to  conclude  that  there  was  no
rational
explanation
for  the  quantum  of
fees
and
that  therefore  the  fees were not appropriate.
[3]
[19]
The requirements  which  the  decision  maker
in
New  Clicks
was found  to have to comply
with, apply
mutatis mutandis
to  the  regulator
and  the  Minister in the present matter. Had the
recommendations of  PWC
been followed,   the
maximum   service   fee   would
have
been   R80.54.    Without
any explanation, the regulator simply  suggested  an
amount
of R65.00  to the Minister. The Minister, also
without any explanation,  reduced  the  amount to
R60.00. Furthermore,
the Minister of  his  own
accord  and  without being advised by the regulator to do
so  and
without  any explanation,  added  a
rider  that the  fee should  be calculated
pro
rata
the number of days if  a credit agreement
was concluded  during the course  of  a calendar
month. No reason
or explanation  is given for the
reduction  of  the interest rate from
5%
to
3%
per
month for further loans after the first during a calendar. All that
is referred to is a policy to reduce the over­ indebtedness
of
consumers. There is, however, no evidence  that  the
existing initiation fee, service fee and interest rate were the
cause
of such over-indebtedness.
[20]
I have referred above to
the requirements of s 105(2) and regulation 45(2) with which the
Minister and the regulator have to comply.
These include the
need to make credit available to historically disadvantaged persons
and low income  persons  and communities,
the impact
of access  to finance for such persons, and the conditions
prevailing in the credit market, including the cost
of providing
credit. Apart  from  the  regulator stating in general
terms that research was done, no evidence has
been provided of how
these matters were investigated or considered.  The
Minister and the regulator have not addressed
in any meaningful way
the applicant's contention  that  the amended  fees
and interest  rates  will lead
to  closures of
the businesses  of many  of the applicant's members and
will
impair access to credit by those members of the population who
require  short term credit provided  by the applicant's

members.
[21]
In view of the
aforegoing, I agree with  Mr  Michau's  submission
that the Minister's decision to promulgate
the regulations
insofar as they relate  to short term credit is reviewable in
terms of  either  s  6(2)(e)(iii),
s
6(2)(e)(vi)  or s  6(2)(h)  of
PAJA.
[22]
I therefore make the
following
order:
[a]
The first respondent's
decision to promulgate the  regulations  published in
Government Gazette 39379, Vol. 605 of 6 November
2015, is reviewed
and set aside insofar as it relates to short term credit.
[b]
The first and second
respondents are ordered to pay the applicant's costs jointly and
severally, such costs to include the costs
of senior counsel.
Counsel
for applicant: Adv. R Michau SC
Instructed
by:  Lewies Attorneys, Pretoria
Counsel
for first respondent: Adv. TV Norman SC; Adv. P Jara
Instructed
by: State Attorney, Pretoria
Counsel
for second respondent: P L Carstensen SC
Instructed
by  Edward  Nathan  Sonnenbergs,  Sandton
[1]
In
terms  of  s  13(a)  the  National
Credit  Regulator  is  responsible
to-
(a)
promote and support the development, where
the need exists, of a fair, transparent, competitive, sustainable,
responsible, efficient,
effective and accessible credit market and
industry to serve  the needs
of-
(i)
historically  disadvantaged
persons;
(ii)
low income persons and communities;   and
(iii)
remote, isolated or low density
populations and communities, in a manner consistent with the
purposes of the
NCA.
(iv)
[2]
2006
(2)  SA  311  (CC).  Footnotes  have
been omitted.
[3]
My
emphasis  in  all  of  the  quoted
passages.