Page 219 - The Digital Financial Services (DFS) Ecosystem

ITU-T Focus Group Digital Financial Services
Ecosystem

systems led to the program’s demise. Without technical and economic alignment, these new programs
will also fail. 22

6 Considerations for policy makers

We believe policy makers can play a guiding role in helping to ensure the potential benefits of ACD, including
the use of e-money, in helping to incent BoP sellers to accept electronic payments, are realized. This, in turn,
could serve as a strong factor in effecting digital liquidity. This guidance can come in several forms:

• Encourage the development of ACD in a system open to a wide range of participants – banks, MNOs,
alternative lenders, etc. and explicitly address the use of e-money payment data as a meaningful data
point in bringing credit to BoP merchants.
• In order to support these ACD systems, policy makers need to get out in front of a range of issues
surrounding collection, usage, securing, and sharing of ACD data.
• To the extent policy makers can influence telecom and payment platforms, encourage open and easy
to integrate APIs to access data while complying with applicable regulatory policies. The notion of
“interoperability” should also address access to data.
• The notion of credit bureaus should be addressed in terms of their potential benefits to BoP populations,
particularly the unbanked.
• Develop policies/guidance as to how firms share scores and/or raw data, loan decisions, and repayment
and loss histories with other ACD users and/or traditional credit bureaus (it is possible that different data
and scoring methodologies could be complementary).
• As further research is conducted and/or as market-specific programs are developed, consider including
additional “deep dive” analyses, including:
– How can ACD be used to enable trade credit between BoP businesses?
– Merchant rights to review, dispute, opt out, or seek redress regarding data, decisions, etc.
– How often and from what sources are data updated?

– Who should be liable for loss or misuse of data?
– Permissible use of data and what should these entities be allowed to do with the data?

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stalls- over- hitch- on- profit- sharing--/-/ 539552/ 1373474/-/ 8e1xlj/-/ index. html

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