Page 63 - ITU-T Focus Group Digital Financial Services – Consumer Experience and Protection

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

2.3 Consumer obligations

2.3.1 PIN security

A majority of the provider contracts (61 per cent) stipulate that customers should keep their PIN securely.
Further, provider contracts state that all transactions are presumed to have been generated by the consumer
if instructions come from their phone number and the correct PIN is entered. Some contracts even caution
customers not to disclose their PIN to provider employees at customer care centres or to provider agents at
outlets.

Figure 5: PIN safety

2.3.2 Dormant accounts
In some jurisdictions, such as Kenya and Tanzania, the law requires that funds be paid to the government if an
account has been dormant for a specified period of time, in some cases five years. Yet, provisions relating to
management of dormant accounts were only present in 28 per cent of the contracts reviewed, with providers
employing varying definitions of dormancy. In the event of inactivity in such accounts, funds may be transferred
into a trust or holding account and customers have a right to claim their balances. In fact, in Kenya, Nigeria,
Tanzania, Uganda, and Zambia, regardless of whether the account is active or considered dormant, the mobile
money funds must be held in a trust or escrow type account by law. However, if the customer requests the
funds prior to the law requiring that the funds escheat to the state, then the credit balances should be paid
to the customer upon presentation of proper identification. Otherwise, those funds may be lost or subject to
a government claims process.

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