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With insights from CFI Fellow John Owens’ report, the Smart Campaign is charting a way forward on responsible digital credit, including considering a new Client Protection Principle and debuting a certification program for mobile credit providers.


By Alex Rizzi, Senior Director, Smart Campaign

The Smart Campaign recently released a paper by digital financial inclusion expert and CFI Fellow John Owens: Responsible Digital Credit: What does it look like? The paper lays out the variety of digital credit models and, using the Client Protection Principles (CPPs) as a framework, enumerates emerging risks and suggests good practices and mitigating steps that providers, regulators and even clients can take.

The paper is a helpful addition to the Smart Campaign’s work on a number of fronts. Read the rest of this entry »

In the era of digital credit, we need not just new laws, but also new mental models for responsible digital credit provision.

> By John Owens, CFI Fellow

Responsible Digital_Credit Report CoverAs digital credit providers have grown exponentially over the past few years, and as digital products and models have proliferated, so too have concerns around consumer protection. In the recently published report, Responsible Digital Credit, I argue that ensuring that digital credit customers receive responsible treatment requires more than enhanced consumer protection laws and regulations. It also requires strong commitment from the digital credit industry. Finally, it needs consumers who are empowered to play a more proactive role in managing their digital credit responsibly.  Read the rest of this entry »

With the weakening of institutional watchdogs and regulations for mortgage lending in the U.S., the future of consumer protection in financial services is jeopardized.

Free standing house with driveway

> Posted by Carmen Paraison, Senior Program Associate, The Smart Campaign

Can your skin color help predict whether you may be financially exploited in the United States? Unfortunately, even in 2018, the answer is still yes.

In February of this year, Wells Fargo was sued by the city of Sacramento, California for allegedly discriminating against black and Latino mortgage borrowers since 2004. The specific charge, raised against the country’s third-largest bank in terms of assets, was providing these clients with more expensive loans compared to those offered to white borrowers.

Across the country, in Baltimore, Maryland, a study that found that black homeowners were charged higher interest rates and disadvantaged at every stage in the borrowing process compared to similarly qualified white borrowers – even taking into account factors such as credit scores, income and down payments. Over the span of a 30-year loan, the researchers say, discrimination against black borrowers cost them an extra $14,904 each, compared with white borrowers.

Homeownership is one of the most important ways for working and middle class families to build generational wealth. According to the U.S. Census Bureau, 69 percent of a household’s net worth in America lies in the net equity in their home. And investigations have repeatedly shown that people of color pay a heftier price to achieve wealth than their white counterparts.

What are the economic implications of financially exploiting people of color in home ownership? More expensive mortgage loans translate into higher monthly payments, lower savings, and a higher risk of default and foreclosure. On a macro-level, consequences include a stagnant homeownership rate among people of color, a yawning (and growing) racial wealth gap, and continued institutional discrimination against people of color in the United States.

As a national consumer advocacy entity, the Consumer Financial Protection Bureau (CFBP) is designed to investigate claims of nefarious behavior among financial service providers and ensure that providers treat consumers fairly. However, its Office of Fair Lending and Equal Opportunity was stripped of its power earlier this year, with the removal from its mandate of oversight and enforcement. Commenting on the move, Lisa Donner, executive director of Americans for Financial Reform remarked, ‘‘These changes . . . threaten effective enforcement of civil rights laws, and increase the likelihood that people will continue to face discriminatory access and pricing as they navigate their economic lives.”

The burst of the U.S. housing bubble yielded the Great Recession, which spread throughout world. Its origins in reckless lending in the subprime market convinced many people involved in the financial sector that consumer protection was urgently needed. In response to this gap, the 2010 Dodd-Frank financial reform law was passed. However, the current administration has since rolled back banking regulations, making it harder to detect discriminatory mortgage lending practices. Signed in May 2018, the new Economic Growth, Regulatory Relief and Consumer Protection Act would exempt 85 percent of banks from reporting detailed information about mortgage loan applicants. This means it will be more difficult to identify systemic issues, conduct research about them, and respond with corrective action.

As borrowers of color in the U.S. continue to access credit with the goal of owning a home, and the steady deliberate weakening of institutional watchdogs and regulations continues, the future of consumer protection in financial services for all remains in jeopardy. As banks continue to backslide into more discriminatory and predatory practices towards people of color, we as consumers and advocates should continue to be aware of and vigilant about them.

Image credit: David Sawyer via Flickr. (CC BY-SA 2.0)

Former CFPB staffer endorses consumer protection and we couldn’t agree more.

> Posted by Beth Rhyne, Managing Director, Center for Financial Inclusion at Accion

Arjan Schutte, a venture capitalist and head of Core Innovation Capital, was recently asked to resign from his advisory role with the U.S. Consumer Financial Protection Bureau – as were all the other members. This prompted Schutte to make the following statement about his belief in the importance of consumer protection regulation:
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100 Certified Seal Final - IBarres 4-24-2018Adapting Smart Certification for Digital Financial Services

>Posted by Alex Taylor, Marketing and Community Outreach Manager, Smart Campaign

This is the fourth in a series of blog posts exploring the impact of Smart Certification on the financial inclusion industry.

Since launching Smart Certification in 2013, we’ve witnessed rapid changes in the financial inclusion space driven by digitization of financial services and fragmentation of traditional business models. Nearly $100 billion in investment has flown into the global fintech market since 2010, creating an explosion of digital innovations and provider models. Our analysis of the Global Findex data shows that recent gains in inclusion have been largely driven by the rise of mobile money and digital payments.

Digital financial technology is central to making financial products more accessible to underserved people around the world. This is an exciting moment for digital finance, and an equally important for time for client protection. The industry has the opportunity to marry the client-centric approach embraced by so many fintechs and the industry-accepted consumer protection standards to develop quality products, build trust, and encourage usage. The Smart Campaign will leverage its experience to help lead the charge on this.

As we celebrate 100 Smart Certifications, we look forward to the next 100. Looking to the future requires defining responsible practices and standards given the technological advances that allow nearly instant access to credit, payments, savings, and insurance. The standards and the certification program must become more agile, mirroring the fast pace of change. We envision an adaptable approach that takes into consideration the product and client delivery mechanism, as well as the provider’s function in the value chain. The flexibility of this framework could eventually allow any type of provider to seek certification, but the process will begin with a focus on digital lenders and expand to encompass additional business models on a demand-driven basis.
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Woman holds POS device

Demand for credit in Africa exceeds supply, despite the rise in mobile money. Yet start-ups, growing daily in number, are at risk of accelerating over-indebtedness, by supplying credit to clients without conducting appropriate repayment capacity analysis. Digital lenders need to understand the risks of over-indebtedness from a client perspective, and algorithms need to evolve to take this into account. Regulation also must guide good practice for fintech digital lenders.
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> Posted by Sarah Samuels, Global Operations Manager, the Smart Campaign

This is the third in a series of blog posts exploring the impact of Smart Certification on the financial inclusion industry

When financial service providers approach Smart Certification, they often have a number of questions. Many want to know if certification is worth the investment in terms of their financial bottom line. The answer we’ve heard from Smart Certified institutions is an unequivocal “yes.” As the Smart Campaign celebrates the recent milestone of 100 Smart Certifications, we’d like to explore the value of certification as Smart Certified financial service providers see it.

In partnership with Deutsche Bank, the Smart Campaign recently conducted a survey of certified institutions to understand how they view their experience with Smart Certification. (You can find the full survey findings in the Consumer Protection Resources Kit.) In an affirmation of Smart Certification’s value, 82 percent of institutions surveyed believe the cost of certification (in terms of both the servicing fee and internal staff time) was compensated by the value the institution received in return. This finding aligns with research from the European Microfinance Platform, which determined that consumer protection practices, such as price transparency, respectful collection practices and effective complaint resolution, are linked to higher financial returns and have a positive impact on the provider’s bottom line.

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> Posted by Jeffrey Riecke, Senior Specialist, CFI

Never before have issues of data privacy and security been more top of mind. In the United States this attention was on full display a few weeks ago when every media outlet was glued to Facebook’s CEO Mark Zuckerberg as he fielded questions from Congress on how his company handles, and has mishandled, user data.

Europe begins a new era for data protection today as the General Data Protection Regulation (GDPR) goes into effect, following its passage roughly two years ago. The law is being celebrated widely for its robust customer-centricity. The degree to which it succeeds, in Europe and globally, in enforcing a business environment that provides adequate safeguards for consumer data management remains to be seen. One thing is certain, however: it has the potential to change the way we all interact with businesses, from internet platforms to banks.

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> Posted by Isabelle Barrès, Global Director, the Smart Campaign

This is the first in a series of blog posts exploring the impact of Smart Certification on the financial inclusion industry.

The Smart Campaign is thrilled to announce that 100 financial service providers have been Smart Certified, extending fair treatment and respect to more than 42 million low-income financial clients around the world. One hundred Smart Certifications marks a major milestone for the advancement of pro-client practices in the financial inclusion industry. These 100 financial service providers have worked to achieve and demonstrate their commitment to protecting clients from harm and delivering responsible financial services.

The journey to 100 certifications began with the launch of the Smart Campaign in 2008, at a time when microfinance sector leaders recognized the need to ensure that consumers remained front and center to their operations as the sector underwent a period of rapid growth. The Smart Campaign went on to become an umbrella for financial inclusion sector cooperation, through the endorsement of thousands of stakeholders of the Client Protection Principles (CPPs) and accompanying standards. The CPPs offer a common framework for understanding client risks and improving practices, and form the bedrock of the Campaign’s Smart Certification program. The certification program was launched in 2013 as a tool to support and reward financial service providers that offer appropriate products and services and deliver them in a fair and respectful way.

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> Posted by Jeffrey Riecke, Senior Specialist, CFI

Last week, Mick Mulvaney, interim director of the U.S. Consumer Financial Protection Bureau (CFPB) said in reference to the CFPB’s consumer complaints database, “I don’t see anything in [the Dodd-Frank Act] that says I have to run a Yelp for financial services sponsored by the federal government. I don’t see anything in here that says that I have to make all of those [complaints] public.”

Mulvaney’s comments refer to the complaints database CFPB has been running for several years, which allows anyone to view, sort, and filter complaints submitted by customers regarding their treatment by their financial service provider. Since the database was created, roughly 1.5 million complaints have been logged. This database has functioned as a tremendous resource for prospective customers who want to check out financial institutions, for analysts of consumer risks in the U.S. financial system, and for financial institutions who want to see how they stack up against others. Its publication may also induce financial service providers to be more vigilant in avoiding bad practices and handling customer complaints well.

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Credit Suisse is a founding sponsor of the Center for Financial Inclusion. The Credit Suisse Group Foundation looks to its philanthropic partners to foster research, innovation and constructive dialogue in order to spread best practices and develop new solutions for financial inclusion.

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The views and opinions expressed on this blog, except where otherwise noted, are those of the authors and guest bloggers and do not necessarily reflect the views of the Center for Financial Inclusion or its affiliates.