Page 15 - ITU-T Focus Group Digital Financial Services – Consumer Experience and Protection

ITU-T Focus Group Digital Financial Services
Consumer Experience and Protection

Table 2: Dispute resolution

Key issues Examples

1. COMPLAINTS POLICY AND PROCE- DFS providers have a complaints policy and procedure in place
DURES IN PLACE

2. COMPLAINTS POLICY IS TRANS- Policy is effectively communicated using multiple channels (such as in branch,
PARENT AND COMMUNICATED TO online, leaflets, verbally by agents etc.), and the policy is made available in
CONSUMERS common local languages.

3. MULTIPLE RECOURSE CHANNELS Access to a variety of channels to make complaints such as toll free numbers,
AVAILABLE TO THE CONSUMER local agents, social media, and branches etc.
4. ALTERNATIVE DISPUTE RESOLU- Consumers who are not satisfied with how their complaint was handled by
TIONS OR EXTERNAL RECOURSE their provider are able to access alternative or external channels to seek
redress. Information on how to use alternative methods is readily available.

5. TIME FRAME PROVIDED FOR DIS- Time frames of how long consumers should expect to wait for a response are
PUTE RESOLUTION reasonable and clearly communicated to consumers.

6. DEDICATED, TOLLFREE RECOURSE Consumers have access to a designated phone line for dispute resolution and
HELPLINE AVAILABLE it is toll free.

7. COORDINATION BETWEEN THE Close coordination and collaboration between the financial and telecom
FINANCIAL AND TELECOM REGULA- regulators (including sharing data and analysis on DFS complaints) ensures
TORS IN DISPUTE RESOLUTION effective resolution. This information can also inform their DFS-related licens-
ing, supervision/oversight, and enforcement roles.

8. OVERSIGHT OF THE RECOURSE Financial regulator or supervisor has the remit to monitor complaints and
SYSTEM BY THE FINANCIAL REGULA- listen to and resolve disputes. This can include providers sharing complaints
TOR OR SUPERVISOR data with the regulator and/or onsite checks for compliance.
9. EMPLOYEES AND AGENTS ARE Employees are trained and provided with scripts/procedures for the most
TRAINED IN HANDLING DISPUTES common complaints received. Moreover the categorisation of complaints
makes handling disputes more efficient.

3.3 Fraud Prevention

Fraud is a key issue for consumer protection as not only can it result in loss of funds or the misuse of personal
data but the fear of fraud can prevent users from adopting DFS in the first place or prevent OTC users from
adopting wallets and more advanced services. There are a number of ways that fraud can be categorised. GSM
Association has identified three common types of fraud by the perpetrator :
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1 Transactional – fraud which may be committed by a user posing as a genuine consumer

a) vishing/smishing – use of phone calls or SMS to gather personal information such as account details,
PINs or passwords or other identification details
b) advance fee scams where customers are tricked into sending funds under fake circumstances or
promises (i.e. lottery scams)
c) reversal requests – where a person may ask a user to refund them an incorrect transaction which
was deposited in their account
2 Channel – fraud which may be carried out by the agent

a) split transaction – agents split transaction to earn more commission

1 Source: Managing the Risk of Fraud in Mobile Money, GSMA

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