Page 87 - ITU-T Focus Group Digital Financial Services – Recommendations

ITU-T Focus Group Digital Financial Services
Recommendations

Title of recommendation Standardized & regular complaints reporting by DFS providers
Working Group Consumer Experience and Protection

Theme Recourse
Audience for recommendation Regulators

Regulators should require standardized, electronic, and regular reports such as quarterly complaints reporting
from DFS providers.

Regulatory review of complaints data can provide a check on the quantity and type of complaints providers
receive, and on providers’ compliance with the required response times and other standards. Through
independent analysis, regulators may be able to spot issues and trends earlier. DFS providers should also make
complaint data and supporting documentation available to regulators for review during onsite inspections.
Analysis of complaints data gives regulators a wealth of information on individual providers, new products, and
the overall health of the industry. It can be used for market-monitoring, risk-based supervision, and identifying
emerging risks and gaps requiring regulatory or other attention. The AFI notes that as quantitative and
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qualitative data is collected and analyzed over time, regulators may be able to use this information to make
necessary adjustments to consumer protection and market conduct regulations and guidelines.
General reporting requirements should include the type of complaint, segmented into category, such as
product and delivery channel, to aid in analyzing: trends and problem areas; response times; final resolution
(e.g.; in favor of customer or provider, sent to ADR or other third party); unresolved complaints; and the reason
for delay. Regulators should require DFS providers to provide this information using a standard template to
facilitate offsite review, statistical analysis, and comparison across providers and products. Where practicable,
providers should upload this report electronically.

Complaint reporting should be done on a regular basis, both to the DFS providers’ governance and to the
regulator. Depending on the volume and trends, regulators may want to require complaint information every
three or six months. The supervisor should have the authority to require providers to provide more frequent
updates when circumstances necessitate. G20 High-Level Principles on Financial Consumer Protection
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also recommend that aggregated complaints data and their resolution be made public, which would further
enhance accountability and transparency. The Central Bank of Brazil, for example, publishes complaint statistics.

DFS providers should also be expected to assess their complaint data to identify and correct systemic issues.
The Bank of Uganda requires that a financial services provider have in place arrangements to ensure that,
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when handling complaints, it identifies and remedies any recurring or systemic problems by: (a) analyzing the
causes of individual complaints in order to identify any failings in processes, products, or services; and (b)
correcting any such failings.

45 Bank of Uganda Financial Consumer Protection Guidelines (2011) https:// www. bou. or. ug/ bou/ bou- downloads/ Financial_
Literacy/ Guidelines/ 2011/ Jun/ Consumer_ Protection_ Guidelines_ June_ 2011. pdf

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