Page 199 - ITU-T Focus Group Digital Financial Services – Technology, innovation and competition
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ITU-T Focus Group Digital Financial Services
                                              Technology, Innovation and Competition



               In January 2017, the Zimbabwe Telecommunications regulator, POTRAZ set floor prices on access to MNO
               services. It had used a study of a bottom-up costing model  to determine pricing. Implementation of the new
                                                               129
               pricing, however, led to market confusion and massive retail price increases in mobile data, USSD, SMS, and
               voice call costs. This led to recriminations between POTARZ, the MNOs and consumers. Ultimately the retail
               price increases were suspended by the MNOs a few days after initial implementation. 130

               5.2.7   Quality of service in USSD sessions


               5.2.7.1  Overview

               Often USSD sessions drop, leading to a poor customer experience and maybe even loss of funds. This may
               dissuade customers from using the DFS service again, instead opting to use an over the counter (OTC) provider
               to do a transaction for them. The reasons for the dropped USSD session may be poor GSM signal,  network
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               congestion, or – as some TSPs and PSPs have alleged – deliberate throttling of their customer’s USSD sessions.
               Such drops may reflect poorly on the TSPs and PSP’s service offering.


               5.2.7.2  Competition aspects

               Complaints from SPs allege that while MNOs may provide access, the QOS is poor, characterized by a high
               proportion of dropped USSD sessions that abruptly end before the customer session is completed. As noted
               above, technical issues relating to GSM networks and coverage may be the issue, although some SPs have
               alleged that they are being handicapped through implementation of random throttling or prioritizing of
               access.  As a recent CGAP report noted, whether quality can be selectively degraded by the MNOs, and
                     132
               if they are doing so, is a factual issue that can be further explored by a regulator in markets where these
               allegations arise. 133


               5.2.7.3  Country examples

               Uganda
               Some TSPs and PSPs say that their customers experience QOS issues with USSD sessions, but the TSP/PSP
               is unable to ‘fix’ the issue because some MNOs refuse to provide a QOS guarantee to them in their service
               contracts.  SPs have also alleged to the UCC that they may not have visibility of some failed USSD transactions.
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               The length, duration, quality and wholesale charges of USSD sessions used in DFS are the subject of an ongoing
               exploratory investigation by the UCC. 136






               129   There are two approaches to estimating unit costs: top-down, bottom-up. These can be combined to form a ‘mixed approach’.
                  A bottom-up approach is used to estimate the costs of service usage and involves identifying all resources used to provide a
                  service, and then assigning a value to each of those resources. These values are summed and linked to a unit of activity to derive
                  a total unit cost. Top-down costing is more amenable to estimating the society level costs which are often intangible and where
                  data is scarce. See UK Cabinet Office (2017) Top Down And Bottom-Up Unit Cost Estimation, available at https:// goo. gl/ nZWX3M
               130   Techzim (2017) New Tariffs - POTRAZ Says It Consulted The Mobile Operators, They Actually Wanted Even Higher Prices, available
                  at http:// bit. ly/ 2isSXNz
               131   Mobile handsets & base stations must transmit enough power to maintain a call of acceptable quality or USSD session to com-
                  pletion without transmitting excessive power into the frequency channels & timeslots allocated to others. See Keysite (2014)
                  Understanding GSM/EDGE Transmitter and Receiver Measurements for Base Transceiver Stations and their Components, available
                  at https:// goo. gl/ n6kqnF
               132   See Further Chen (2015) ibid); and CGAP (2014) ibid. The BB and the BTRC are planning to investigate QOS issues, part of a larger
                  study on USSD pricing. See also on USSD reporting for the BB, Business News (2015) ibid
               133   CGAP (2014) ibid
               134   In Uganda, service providers reported limited scope for negotiation of service level agreements with MNOs, that it was not possi-
                  ble to negotiate the level of service availability. Cartesian (2015) ibid
               135   UCC (2016) ibid
               136   ibid.



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