M2i pioneered Code of Conduct Assessments of MFIs in 2010. M2i developed a framework of Code of Conduct Assessments and performed first set of assessments in India. Subsequently, five other agencies developed their tools for COCA and were empaneled by SIDBI to perform Code of Conduct Assessment of MFIs in India. By March 2016, COCA had become essential requirement for bank lending to the MFIs and was part of the lending covenants of many Banks and NBFCs. At the same time, it was being realized that since different agencies were using different methodologies, it was being difficult to compare rating grades/scores assigned by the different agencies. In July 2006, SIDBI organized a workshop to harmonized Code of Conduct Assessments which was attended to by the important lenders to the MFIs, MFI Self Regulatory Organizations (SROs), agencies performing Code of Conduct Assessments and SMART Campaign. It was agreed in the workshop that all agencies should use a common COCA methodology and reporting format for better comparison of COCA scores/grades performed by different agencies. It was also agreed that since some of the assessment parameters for Capacity Assessment Gradings and COCAs were overlapping (eg compliance with regulatory directions), COCA and Capacity Assessment Gradings could be integrated in a single comprehensive assessment. M2i was assigned to harmonized the Code of Conduct Assessment tools and integrate COCA and Capacity Assessment Gradings. The assignment involved the following • Review of methodologies of COCA and Capacity Assessment Gradings of different rating/assessment agencies • Detailed review of 84 COCAs performed by different agencies, including assessment of normality in COCA grades • Development of COCA dimensions considering Industry Codes of Conduct, RBI's directions and Smart Campaigns Client Protection Principles • Identification of objective indicators to measure performance on these dimensions • Development of sampling guidelines, report format and guidelines for scoring • Design of framework of integration of COCA and Capacity Assessment Gradings • Training of staff of rating/assessment agencies M2i has finalized the COCA tool based on the feedback from stakeholders. We have also trained the staff of the rating agencies on Code of Conduct Assessment Tool. .