Page 59 - ITU-T Focus Group Digital Financial Services – Consumer Experience and Protection

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

Box 2: Fees and charges

Uganda: The Mobile Money Regulations 12 (b) – At mobile money account opening, the consumer
shall obtain a copy of the agreement with the service provider. The agreement shall be explained
by the agent clearly and in plain language. The terms and conditions provided by the mobile money
service provider shall highlight to the consumer the relevant fees, charges, penalties and any other
consumer liabilities or obligations in the use of mobile money services. The mobile money customers
should be able to access the service fees chargeable from their phones.
Comment:

The agreements reviewed (Utl M-sente and MTN Uganda) did not highlight to the consumer the
fees, charges, and penalties.

2.2 Provider obligations

Some contracts state obligations that providers owe to consumers including: Fraud and funds protection;
data protection and privacy, including when customer information is shared with third parties; procedures for
reversal of erroneous transactions; and whether consumers are given advance notice of changes to contract
terms. The following is a discussion of how often such obligations are stated and, when they are, what is
provided.

2.2.1 Fraud and funds protection

Consumers often lose money through fraudulent activity perpetrated by third parties or even by provider
employees or agents. The contracts were examined to establish whether they incorporated provider obligations
with regard to fraud and funds protection.

Figure 1: Fraud & funds protection

As demonstrated in the chart, only half of the agreements stipulated specific obligations relating to fraud and
funds protection. Examples of such provisions include providers suspending services or closing accounts where
they suspect or become aware of fraudulent activity in relation to a customer’s account.

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