Country Comparison — Corporate
Modify selection| Questions |
Japan
Japan Housing Finance Agency |
Tanzania
Tanzania Mortgage Refinance Company Ltd. |
Armenia
National Mortgage Company |
Jordan
Jordan Mortgage Refinance Company |
Pakistan
Pakistan Mortgage Refinance Company (PMRC) |
Indonesia
PT Sarana Multigriya Finansial (Persero) |
Korea
Korea Housing Finance Corporation |
Malaysia
Cagamas Berhad (“Cagamas”) |
Kenya
Kenya Mortgage Refinance Plc (KMRC). |
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| Founding Instrument(s) (with links if possible) | Act on the Japan Housing Finance Agency, Independent Administrative Agency https://laws.e-gov.go.jp/law/417AC0000000082 Act on General Rules for Incorporated Administrative Agencies https://www.japaneselawtranslation.go.jp/ja/laws/view/2754 | TMRC is a private company incorporated under the Companies Act, 2002. It is a financial institution licensed by Bank of Tanzania. TMRC’s operations are guided by the Banking and Financial Institutions (Mortgage Refinance Companies) Regulations, 2022 and amendments of 2023. | NMC is a private company established, registered and licensed by the Central Bank of Armenia in accordance with the laws of the Republic of Armenia "On Credit Organizations" and "On Joint Stock Companies." https://nmc.am/rules-regulations/2024/NMC_charter_ENG_29.05_2024.pdf | JMRC is a public shareholding limited company established under the provisions of the Temporary Companies Law No. (1) of 1989 and registered in the register of public shareholding companies under number (314) on 5/6/1996, and obtained the right to commence operations on 22/7/1996, with its subscribed and paid-up capital amounting to (22.5) million Jordanian dinars. | PMRC is an unlisted public limited company incorporated under the Companies Act, 2017, and designated as a Development Financial Institution (DFI) by the Government of Pakistan. It operates under directives issued by the State Bank of Pakistan (SBP) and the Securities and Exchange Commission of Pakistan (SECP) | PT Sarana Multigriya Finansial (Persero) was established pursuant to Government Regulation of the Republic of Indonesia No. 5 of 2005 on the State Capital Injection of the Republic of Indonesia for the Establishment of a Limited Liability Company (Persero) in the Secondary Housing Finance Sector, as amended by Government Regulation No. 57 of 2020 on the Second Amendment to Government Regulation No. 5 of 2005 on the State Capital Injection of the Republic of Indonesia for the Establishment of a Limited Liability Company (Persero) in the Secondary Housing Finance Sector | Korea Housing Finance Corporation Act(Enacted in 2003) | Cagamas is a public company incorporated under the Companies Act . It was established in 1986 to promote home ownership and contribute towards national development. https://www.cagamas.com.my https://financialmarkets.bnm.gov.my/cagamas | KMRC is a financial institution registered as a public liability company (PLC) in 2019 under the Companies Act 2015. The company is licensed and regulated by the Central Bank of Kenya (CBK) as a non-deposit taking financial institution under the Central Bank of Kenya (Mortgage Refinance Companies) Regulations, 2019, and the Capital Markets Authority (CMA) as an issuer of securities to the public. Link: https://www.centralbank.go.ke/wp-content/uploads/2019/08/Central-Bank-of-Kenya-Mortgage-Refinance-Companies-Regulations-2019.pdf |
| Any additional or subsequent mandate or governance statements (not included in the above). | Not limited to these laws, amended laws and other related laws also applies. Penal Code Civil Code Financial Instruments and Exchange Act Companies Act Act on Building Unit Ownership, etc. Housing Loan Insurance Act Act on Securitization of Assets Act on Securement of Stable Housing for the Elderly Act on Promotion of Entry of Japanese Businesses into Overseas Social Infrastructure Projects Special Measures Act on Promotion of Countermeasures for Vacant Houses, etc. Act on Special Financial Assistance and Aid for Coping with the Great Hanshin-Awaji Earthquake Act on Special Financial Assistance and Aid for Coping with the Great East Japan Earthquake Act on Promotion of Supply of Rental Housing for Persons Requiring Special Assistance in Securing Housing Act on Promotion of Workers’ Asset Formation Small and Medium-Sized Enterprise Retirement Allowance Mutual Aid Act Act on the Improvement of Energy Consumption Performance of Buildings, etc. Trust Act Act on Concurrent Operation of Trust Business by Financial Institutions, etc. Okinawa Development Finance Corporation Act Special Measures Act on Acceptance of Foreign Capital from the International Bank for Reconstruction and Development, etc. Special Measures Act on Credit Management and Collection Business | None | Company mission is to provide liquidity, stability and affordability to the mortgage market in Armenia. | None | Mentioned in Point 1 | The conduct of PT Sarana Multigriya Finansial (Persero)’s business activities is governed by: 1. Presidential Regulation No. 19 of 2005 on Secondary Housing Finance, as last amended by Presidential Regulation No. 100 of 2020 on the Third Amendment to Presidential Regulation No. 19 of 2005 on Secondary Housing Finance. 2. Financial Services Authority Regulation (POJK) No. 4/POJK.05/2018 on Secondary Housing Finance Companies, as last amended by Financial Services Authority Regulation (POJK) No. 12/POJK.05/2022 on the Amendment to Financial Services Authority Regulation (POJK) No. 4/POJK.05/2018 on Secondary Housing Finance Companies | The mandate of KHFC has been expanded through subsequent amendments to the Korea Housing Finance Act, including the introduction of the reverse mortgage program(2007) | Cagamas provides liquidity to the financial sector as a secondary mortgage corporation. It contributes towards the growth of the capital markets, Islamic finance and other priority sectors through the issuance of innovative instruments | None |
| Ownership | 100% Government of Japan | Member banks, IFC, Shelter Afrique and National Housing Corporation. | Central Bank of Armenia (100%) | Banks, Central Bank, Public Sector Institutions | Refer “Annexure A – Shareholding Structure” | PT Sarana Multigriya Finansial (Persero) is 100% owned by the Government of the Republic of Indonesia, represented by the Ministry of Finance of the Republic of Indonesia. | Government 59.8%, Bank of Korea 36.3%, Fund: 3.9%. Reason for divided ownership (Government, Bank of Korea, and Fund): The shareholding structure reflects KHFC’s dual role in both housing policy and financial markets. Government (MOEF): As a public entity established by law, the Ministry of Economy and Finance (the primary ministry managing state-owned enterprises) holds ownership through capital contribution. Bank of Korea (BOK): Since KHFC's securitization business significantly impacts monetary liquidity, the BOK—as the central bank responsible for monetary policy—contributes a portion of the capital. Fund (MOLIT): To facilitate the practical execution of housing policies, specialized housing-related funds under the Ministry of Land, Infrastructure and Transport also provide capital. | 20% owned by Bank Negara Malaysia (Central Bank of Malaysia), the rest by commercial and investment banks. https://www.cagamas.com.my/about/shareholders | Government of Kenya (GoK) through National Treasury (25%); Commercial banks (44%); Savings and Credit Cooperative Organizations (SACCOs) (8%); Development Finance Institutions (23%). |
| Legal status | Incorporated Administrative Agencies | TMRC is a non-bank financial institution. | Refinancing Credit Organization Closed Joint Stock Company | Non-banking financial institution (public shareholding company) | Refer point 1 | PT Sarana Multigriya Finansial (Persero) is a State Owned Enterprise as a Non-Bank Financial Institution. | A government owned public corporate. KHFC is primarily supervised by the Financial Services Commission (FSC), as we perform housing-related financial services. While we maintain close policy coordination with MOLIT due to the nature of housing policy, the official regulatory and supervisory oversight rests with the FSC. | A public company incorporated in Malaysia under the Companies Act. | Non-Deposit Taking Financial Institution |
| Government accounting for stake | Pursuant to the Article 37 of Act on General Rules for Incorporated Administrative Agencies, Generally Accepted Accounting Principle (GAAP) applies. | N/A | NMC remains a 100% subsidiary of the Central Bank of Armenia, fully controlled by the CBA (all NMC Board members are simultaneously members of the CBA Board). Indeed, the IFRS accounts are fully consolidated with CBA. We are currently investigating options of alternative shareholding and capital structure, in particular, based on the research of similar structures’ best practice. | Investments held by public-sector entities (Central Bank, Social Security Investment Fund, Housing & Urban Development Corporation) are recorded as financial assets measured at fair value. Changes in fair value are recognized in Other Comprehensive Income (OCI) and reflected in equity. | Information not available | The Government of Indonesia records its equity as a permanent investment using the equity method, in accordance with Law No. 17 of 2003 on State Finance and the Government Accounting Standards (Standar Akuntansi Pemerintahan – SAP) as applied in the Central Government Financial Statements (Laporan Keuangan Pemerintah Pusat – LKPP) | Government 59.8%, Bank of Korea 36.3%, Fund: 3.9%. Bank of Korea generally accounts for its investment in KHFC at historic cost in its financial statements. | Bank Negara Malaysia’s 20% equity interest in Cagamas is recorded as a financial investment carried at cost in its accounts. The shareholding does not confer control, joint control, or significant influence over Cagamas and, accordingly, is neither consolidated nor equity‑accounted. | N/A |
| Member bank accounting for stake | N/A | Equity investments into TMRC are accounted for in accordance with guidance from IFRSs. | N/A | The company's financial statements are prepared in accordance with the standards issued by the International Accounting Standards Board and the interpretations issued by the International Financial Reporting Interpretations Committee emanating from the International Accounting Standards Board. Accounting treatment is the same as in the public sector (fair value through OCI). For regulatory capital purposes, these investments are assigned a 100% risk weight, not deducted from CET1. This is because the banks ownership stakes in JMRC are below 10% of their capital, so they are not considered significant. | International Financial Reporting Standards (IFRS) more specifically IFRS 9. | N/A | N/A | Private sector shareholders account for their investments in Cagamas as equity instruments under IFRS 9, measured in line with their respective accounting policies, either at fair value through profit or loss or, where designated, through other comprehensive income. From a prudential perspective, the regulatory treatment is applied at the shareholder bank level in accordance with the prevailing capital adequacy framework: For banks holding more than 10% of Cagamas’ equity, the investment is treated as a significant investment in the capital of a financial institution, with the relevant CET1 deduction or threshold treatment applied. For banks with smaller shareholdings, the investment is subject to the applicable risk weighting for equity exposures under the regulatory rules. | Equity investments into KMRC are accounted for in accordance with guidance from IFRSs. |
| Government guarantee | Explicit government guarantee is provided on JHF Green Bond, a corporate bond issued by JHF to purchase green housing loans. There is no explicit support of the obligations of JHFA as such but, according to S&P the probability of support if needed is descrbed as "a;most certain". JHFA and the government have the same credit ratings. | N/A | No implicit guarantee. Moody’s statement: NMC's ratings incorporate our assumption of a "very high" probability of support from the Government of Armenia, although the latter does not lead to any rating uplift as NMC's standalone assessment is already positioned on par with the government rating. Moody's "very high" government support assumption is based on the current full ownership of NMC by CBA, its public policy role supporting the development of Armenia's housing finance market, and track record of government support in terms of capital increases and the extension of funding lines. | N/A | Government guarantee is available for Credit Guarantee Trust (CGT) managed by PMRC as a Trustee | N/A | Government backing | N/A | N/A |
| Other Comments | None | On the shareholding, first few years was mostly banks, then National Housing Corporation (Developer) joined, then First Housing Finance (mortgage finance company) joined, more banks joined, then Shelter Afrique joined in 2015, IFC joined in 2019, more banks joined and then the government just joined in November 2025 with 27% direct shareholding. National Housing Corporation and TIB Development Bank are state owned enterprises (SOEs) but they have TMRC shareholding separately. | / | N/A | PMRC acts as a trustee of | None | / | Cagamas’ corporate bonds and sukuk are assigned the ratings of AAA/Stable/P1 by RAM Rating Services Berhad and AAA/MARC-1, AAAIS/MARC-1IS by Malaysian Rating Corporation Berhad, and A3 by Moody’s Investors Service. Capital Management Solutions (CMS): Cagamas provides Tier-2 capital support to FIs and development FIs by providing long-term unsecured funding through the purchase of subordinated debt issuances by FIs. Cagamas’ sister company, Cagamas SRP Berhad (CSRP) provides guarantees under the MGT programme. | None |