Page 86 - ITU-T Focus Group Digital Financial Services – Recommendations

ITU-T Focus Group Digital Financial Services
Recommendations

Title of recommendation Multiple channels to complain
Working Group Consumer Experience and Protection

Theme Recourse
Audience for recommendation Regulators

Regulators should require DFS providers to allow customers to submit complaints through a minimum of two
channels (e.g., via agents, in branches, call center hotlines, SMS).

To promote ease of access, DFS providers should provide multiple means through which customers can
submit complaints. There should be options to submit complaints through a channel similar to the delivery
channel ; for example, a mobile phone-based service should have the means of lodging a complaint or
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inquiry via mobile phone. Providers that offer other services in addition to DFS, such as telecommunications,
should ideally provide a dedicated team to deal with DFS complaints, as well as a dedicated hotline for DFS
customers. Because technologies and product offerings mature and evolve, regulators should require that
recourse channels evolve with them.

DFS providers should consider the unique needs of their customers when selecting the appropriate channels
to offer. For example, walk-in complaints might be feasible for customers living and working in an urban area,
but this would be less accessible for those in rural areas where the costs of travel and time away from work
could be prohibitive. In markets where toll-free phone numbers are not available, recourse should be adapted
so the cost is borne by the provider. For example, a customer could initiate a call, and then the provider could
call back, thus incurring the cost.

Issues of trust may determine which channel a customer is most comfortable using, such as a local agent
instead of the main office of the provider. While a minimum of two channels is recommended, DFS providers
should also consider additional channels to facilitate different customer preferences, without creating so many
levels or touchpoints that there is a risk that complaints will get lost.

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Current rules on the number and types of required channels vary by country. Bangladesh Bank requires
providers to have a call center to receive and process disputes by telephone, SMS, IVR, and mail. Central Bank
of Nigeria requires providers to maintain a functional dispute and complaint resolution desk that is equipped
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to receive complaints through phone calls, e-mails, and personal visits or contact from the user.

Regulators should ensure that customers who are illiterate are not effectively barred from accessing recourse
systems because DFS providers require the complaints to be filed in writing, consistent with the World Bank’s
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Good Practices for Financial Consumer Protection . The DFS provider’s frontline staff or agents should be
available to assist these customers in formulating and processing their complaints while ensuring that a written
record is maintained.

The AFI recommends that providers have a clearly defined process for escalating unresolved complaints. Good
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practice also suggests that the complaints function includes a method to escalate more serious or complicated
issues. For example, CGAP reports that some providers have specialized teams to address issues such as lost
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SIMs and forgotten personal identification numbers (PINs). Dedicated or specially-trained teams can also be
used to address fraud and erroneous transactions, as resolution of both is particularly time-sensitive.

44 Mazer, R., Garg, N., CGAP, Recourse in Digital Financial Services (2016) http:// www. cgap. org/ publications/ recourse- digital-
financial- services

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