By Theon Alleyne, CRCP, CCEP | Georgetown, Guyana | 31 July 2026
OPINION
The Guyana Development Bank is promised as being for every Guyanese. Section 25 compels written lending criteria and no provision requires publishing them. A promise about who gets served needs a way to check.
The President assented to the Guyana Development Bank Act on Thursday. The bank is not open. Section 1 leaves commencement to a date the Minister appoints by Order, no board has been appointed under section 7(2), and no chief executive has been named under section 17.
Nothing has gone wrong. Nobody has been refused anything. That is the only reason this is worth writing, because everything I am about to ask for can still be built rather than retrofitted.
Begin with the promise the bank has made about itself. Zulfikar Ally, Minister of Public Service, Government Efficiency and Implementation, has said the Development Bank is for every Guyanese, not just Georgetown. The scheme has separately named women, youth and differently abled entrepreneurs as priority groups. Those are commitments about who ends up served, and they are the right ones.
A promise about outcomes needs a way to check outcomes. Otherwise it is a hope with a press release attached, and the institution making it has no way of knowing whether it kept its word.
Start with what the Act gets right, because the commentary has understated it. Section 25 does not leave lending criteria to anyone’s discretion. It compels the bank to maintain written credit policies and specifies what they must cover: eligibility, risk assessment, approval thresholds, monitoring and recovery. Parliament was careful here. La Caribeña News has set out what the Act requires in full.
Now the part that has been missed. Nothing in the Act requires those policies to be published. The rules governing who receives credit are required by law to exist and permitted by law to stay private.
Consider what that means at the counter. A woman applies for the G$3 million facility. She is assessed against a written standard she has no entitlement to read. If she is approved, she never thinks about it again. If she is declined, she cannot establish whether the standard was applied to her, and she cannot argue that it was not, because she does not know what it says. She leaves with an impression and no way to test it.
This is where I want to be careful, because the point is easy to state badly.
A new institution does not get new people. It gets the people this country already has, drawn from the same pool of lending officers, carrying the same training, the same instincts and the same habits, some of which were never written down anywhere. The Development Bank will open with a development mandate and a state shareholder, and neither of those things changes who sits at the desk.
And discretion is never neutral. It falls somewhere. In a country with our history, where the question of who gets access to what has never been an abstract one, unpublished criteria are not a technical gap. They are the exact condition under which racism operates without ever needing to announce itself, because nobody can point to a rule that was broken when no rule was ever published. A bank can be for every Guyanese in its mandate, its funding and the sincerity of its Minister, and still not be for every Guyanese at the desk.
An institution that publishes nothing cannot prove it was fair. It also cannot find out that it was not.
I am not making an allegation. There is nobody to allege anything against. What I am saying is that a bank promising to serve every Guyanese has, as the Act now stands, no mechanism by which it could ever discover that it had not. It will be judged on outcomes it cannot currently see.
That is a problem for the bank before it is a problem for anyone else. A commitment that cannot be measured cannot be defended, and it cannot be managed. If a branch is approving at half the rate of another, nobody inside the institution will know until somebody outside it notices.
The Act states the difficulty against itself. Section 9(c) obliges the board to safeguard the independence of credit decisions, while supplying no record, no report and no consequence by which anyone could tell whether it had. Section 33(1)(c) makes destroying a decision record an offence. Nothing requires one to be created.
The exposure widens at the second counter. Seventy per cent of the headline G$10 million package sits with commercial banks the Act reaches through a bare power to co-finance at section 5(2)(b), carrying no amount, no rate and no obligation. I have examined that separately. The tier with a statutory credit policy holds thirty per cent of the money.
The fix requires no amendment. Section 34(1)(b) empowers the Minister to make regulations on the terms and conditions applicable to loans provided by the bank. A credit policy can be revised by a board on a Tuesday, without notice, and nobody outside would know. A regulation cannot. Six provisions would close the gap.
Publish the credit policies section 25 already requires. A refusal can only be tested against a standard the applicant can read.
Give reasons in writing for every decline, citing the criterion that failed. This is the control that turns an impression into a record.
Provide an appeals route outside the deciding branch. Review by the office that issued the decline is not review.
Write equivalent terms into the co-financing agreements. Otherwise the scheme protects thirty per cent of the money.
Publish outcome data annually by branch, region, sector, loan size and reason for decline. Not by ethnicity, which would require collecting it. Branch-level divergence is visible without asking any applicant to declare anything.
Train officers against the published criteria, with documented completion. Training that leaves no record cannot be evidenced to a regulator, a court, or a complainant.
There is a seventh, and it is about people rather than paper.
Every officer who meets an applicant will have been trained somewhere else. Most will arrive carrying rules nobody wrote down: what a serious borrower looks like, whose file is worth the extra hour, which application moves and which one waits. Some of that is experience. Some of it is not, and the person carrying it is often the last to know which is which.
Published criteria settle the question. Once the rules are on paper, an officer who applies a different set is not exercising judgement. That officer is writing policy, at a desk that was never given the power to write policy, and doing it to one applicant at a time.
Anyone who would substitute their own rules for the published ones has no place at the counter. Not at the Development Bank, and not at the bank that receives its referrals.
And that standard has to travel. An applicant arriving at the second counter referred by the Development Bank, by a chamber of commerce, or by the private sector help desk carries an institutional endorsement with her. If the terms of participation do not bind the officer who receives her to the same published criteria, the scheme has not removed the discretion. It has moved it one desk along, to the counter holding the larger share of the money and the fewer written rules.
This is a personnel control, not a moral judgement, and it belongs in the operating manual and in the co-financing agreements alongside everything else. It costs nothing to write and it is unenforceable if the criteria stay unpublished, because there is nothing to depart from.
None of this is hostile to the bank. It is the opposite. These are not controls to police an institution suspected of something. They are the instruments by which an institution keeps a promise it has already made in public, and proves it kept it.
A bank that publishes its criteria and records its reasons can answer an accusation the day it is made. A bank that does neither will spend years unable to prove a negative, and the accusation will attach to it whether or not it is deserved. For every Guyanese is a standard. Standards require measurement.
The Government has already accepted the principle. Conflict-of-interest guardrails were attached to public servant eligibility before opening, because a risk was identified and written safeguards followed. This is the same argument applied to a larger exposure.
So let this be on the record, with a date on it. The credit policies are being drafted now. The commencement Order has not been signed. The Minister holds a regulation-making power he has not yet used. Every provision above costs less to build this month than to retrofit after the first disputed decline, and far less than defending a decision the bank kept no record of making.
The bank has told the country it is for every Guyanese. I believe that is meant. Build the means to prove it while there is still time, and if it goes wrong later, nobody will be able to say it could not have been seen coming.
Disclosure
The author is founder and Managing Director of La Caribeña News, which publishes this opinion piece. He is Vice President and Public Relations Officer of the Essequibo Islands-West Demerara Chamber of Commerce and Industry, and a Director and Chair of the Services Sub-Sector at the Guyana Manufacturing and Services Association, whose membership includes commercial banks that may participate in the co-financing tier referred to above. The views are his alone. Neither organisation has considered or endorsed these recommendations, and this is opinion rather than the reporting position of the La Caribeña News newsroom. Statutory references are taken from Bill No. 5 of 2026 as gazetted on 4 June 2026.