Page 29 - ITU-T Focus Group Digital Financial Services – Interoperability
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ITU-T Focus Group Digital Financial Services
                                                       Interoperability



               6.3    Consumer and business associations

               Business and consumer associations exist in most country environments and can play an important role in
               representing the interests of businesses, merchants and consumers vis-à-vis other stakeholders like regulators,
               PSPs and PSOs.

               Business associations – including chambers of commerce and trade associations – can play a key role in building
               inclusive DFS ecosystems by providing useful feedback on DFS products and services to PSPs and PIPs, as well
               as to regulators. They can also provide feedback to policymakers if the enabling environment is not entirely
               conducive to the growth of commerce.
               Consumer associations are typically advocacy groups that seek to protect members or in general citizens from
               various abuses. Common examples include predatory lending or high transaction fees, among many others.
               They can also play a strong role in advocacy for adoption of products and services through educational efforts
               and outreach.

               In a NPS-like structure, both types of associations can play a strong role in promoting the use of DFS among
               stakeholders. Areas of coverage can include:
               •    Promote best practices through technical assistance, case studies, and toolkits.

               •    Facilitate public-private dialogue by uniting the stakeholders around common issues and policy proposals.
               •    Provide program models such as the National Business Agenda to assist business/consumer associations
                    in creating grassroots-driven campaigns that promote adoption of DFS.
               •    Educate businesses and policymakers on the importance of participatory policymaking.





               7      Conclusions

               Central banks are a key driving force in any NPS reform effort as they perform multiple functions in the
               payments arena: from operator, to catalyst, to regulator and overseer.

               However, central banks cannot (and should not) act alone in this space. Involvement of other regulators and a
               broad range of private sector stakeholders is not only highly desirable but of paramount importance, especially
               in the case of retail payments reforms as these touch the lives of vast sectors of the population, as well as all
               types of businesses.
               Recent reforms to retail payments in many countries have been focusing on advancing financial inclusion
               objectives and increasing the overall efficiency of payments. In this regard, some of the key intermediate
               objectives have included the development of DFS, the expansion of the networks of service delivery/customer
               access points and achieving greater levels of interoperability for the various payment products and services.
               These intermediate objectives would generally imply major reforms to the NPS, and any such reforms will
               most likely affect the interests, business and operations of multiple stakeholders. Hence, it is imperative that
               mechanisms to exert leadership, to conciliate interests and establish a reasonable level of consensus, and to
               coordinate actions be developed and that they function in an effective manner.
               A National Payments Council (NPC) has been one of the traditional mechanisms to promote and enhance
               cooperation and collaboration across payment system stakeholders. There are many good examples in which
               NPCs have been particularly useful to facilitate consensus. To this end, it is crucial to ensure that all interests
               involved in payments activities are fairly represented, both across different categories of stakeholders (e.g.
               banks and non-bank PSPs) and within each category (e.g. large and/or traditional players vs. small and/or new
               players).

               In some countries, consultation and coordination on payments topics and reforms are also carried out through
               mechanisms other than a central bank-led NPC. These mechanisms typically do not substitute a NPC, but are




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