Page 82 - ITU-T Focus Group Digital Financial Services – Recommendations

ITU-T Focus Group Digital Financial Services
Recommendations

Title of recommendation Require adequate internal complaints handling units
Working Group Consumer Experience and Protection

Theme Recourse
Audience for recommendation DFS providers

DFS providers should establish an adequately staffed internal DFS complaints handling function which is account-
able to the corporate governance. Regulators should require that DFS providers’ complaints handling units or
functions: Provide services in all languages commonly spoken in the jurisdiction, are free of charge, and allow
customers to file with or without supporting documentation. Regulators should also set minimum standards for
the efficiency and efficacy of the complaint resolution process (e.g., procedures and time parameters for receiv-
ing, tracking, and resolving complaints, communicating decisions, and escalating complaints).

The ability to ask questions and resolve issues is necessary for consumer acceptance and use of DFS. Reaching
out to customer care is common among DFS customers; research commissioned by the ITU showed that 62 per
cent of Tanzanian, 39 per cent of Ghanaian, and 29 per cent of Filipino DFS users have called a DFS customer
care line. Research by CGAP has found that customers are less willing to trust DFS when there are negative
14
perceptions of available recourse if something goes wrong. Therefore, regulators should establish a robust
recourse framework with well-defined rules and responsibilities for all participants, including: consumers;
DFS providers; consumer and industry associations; and alternative dispute resolution bodies, if they exist in
the market.
The first and most critical step in the dispute resolution process is the customer contacting the DFS provider.
The correct provider to contact should be made clear to the customer, especially in situations where multiple
providers, such as an MNO and bank, have partnered to offer a product. Each provider’s governance must
ensure that there are soundly written procedures, clear reporting lines, and adequately trained staff assigned
to handle complaints. Because DFS and telecommunications are uniquely different services, staff assigned to
deal with DFS concerns should have specialized training on issues related to the mobile phone service itself.

In line with the World Bank’s Good Practices for Financial Consumer Protection , G20 High-Level Principles
13
39
on Financial Consumer Protection , and CGAP research , complaints handling and redress should not impose
40
unreasonable cost, delay, or burden on consumers. The DFS complaints handling function should be offered
using easy-to-understand terminology in a language appropriate to the customer, including local dialects and
speaking or hearing impaired persons. Access to complaints handling should be free and easily accessible.
Customers should be permitted to provide supporting documentation of their complaint, but not required to
do so, as a requirement for documentation is a barrier to many customers, especially low-income, from having
complaints resolved. Additional good practices include providing a dedicated hotline for agents, training
39
agents to deal with common and/or basic problems, and providing digital mechanisms to file a complaint,
such as via SMS or social media.

As described in the World Bank Good Practices for Financial Consumer Protection , providers should log and
39
acknowledge receipt of all complaints. For example, the Central Bank of Nigeria requires DFS providers to
41
maintain a dispute and complaints resolution desk to receive and acknowledge complaints with a case identifier

39 World Bank, Good Practices for Financial Consumer Protection, (2016) http:// documents. worldbank. org/ curated/ en/
583191468246041829/ Good- practices- for- financial- consumer- protection
40 CGAP, Recourse in Digital Financial Services: Opportunities for Innovation (2015) http:// www. cgap. org/ sites/ default/ files/ Brief-
Recourse- in- Digital- Financial- Services- Dec- 2015. pdf
41 Regulatory Framework for Mobile Payments Services in Nigeria (2009) https:// www. cbn. gov. ng/ OUT/ CIRCULARS/ BOD/ 2009/
REGULATORY%20 FRAMEWORK%20 %20FOR%20 MOBILE%20 PAYMENTS%20 SERVICES%20 IN%20 NIGERIA. PDF

76