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CFI Fellow Patrick Traynor, Associate Professor in the Department of Computer and Information Science and Engineering at the University of Florida, explains his research on the privacy and security of data in mobile lending applications.

We have all seen privacy policies before: sign up for a credit card and you receive a pamphlet with tiny print detailing your bank’s particular policy. Create an account at an online service and you will get a link to something similar from it, too.  These policies are supposed to provide consumers with detailed information about which pieces of their data will be stored, how they might be used, with whom they can be shared, and how they will be protected. Privacy policies are now mandatory for financial institutions in developed nations, and here in the United States we are provided protection by laws such as the “Gramm-Leach-Bliley Act” (also known as the Financial Services Modernization Act of 1999).

Unfortunately, the reality of such policies is often not so clear. Many of these policies are written by attorneys with the sole intention of being consumed later on by other attorneys. That means that, in some cases, even highly educated individuals without a degree in law may not be able to fully understand what they are reading. What chance does the common consumer have to understand such policies?

You would think that consumers would be up in arms. But, let’s be honest – most people have never actually read these privacy policies, yet alone tried to understand them. Have you?

So then why is it important to examine the state of privacy policies?

Let me offer first an insight into the role of studies like ours and then some comments on why privacy policies for digital credit matter.

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> Posted by Jeffrey Riecke, Senior Communications Specialist, CFI

Phones are making everything more convenient, but are they also reducing costs? That depends on which service and whose wallet you’re talking about. If it’s the consumer’s mobile money wallet, well, the verdict is still out. In a CGAP paper published last year, Rafe Mazer and Philip Rowen lamented that pricing transparency practices in mobile money services are wholly inadequate across payments, credit, and other product lines. They assert an urgent need for standards and policy to impose better practices on mobile money providers. It’s critical to know how prices are tabulated and what fees are incurred – for the betterment of customers and the industry.

In Kenya, arguably the world’s most robust and dynamic mobile money market, we’ve seen a few recent steps in the right direction.

As of May 2017, per a directive issued by the Competition Authority of Kenya (CAK), telcos and financial institutions providing mobile money services were required to ensure that their users are informed via real-time notifications of the price of their transactions – after they are initiated by the user, but before the transactions are completed and money is transferred. This order by the CAK was permitted to be carried out in stages: first, mobile money providers were asked to let users know the price of their money transfers and bill payments after their transactions occurred; then, providers were required to provide pre-transaction pricing for these two services; and finally, this pre-transaction price disclosure was extended to “value-added” mobile money services like micro-loans and micro-insurance. The new rule applies to mobile money services offered through apps, USSD codes, and SIM toolkits.

You might not think that getting notified about relatively small fees is a big deal. After all, mobile money services in Kenya like M-Pesa are used so often that users probably have a strong grasp on pricing. But this is unclear. When CGAP queried mobile money users in Kenya on M-Pesa pricing changes in 2014, despite claiming to be aware of current pricing figures, many respondents in fact were not.

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> Posted by Carmen Paraison, Senior Program Associate, Africa, the Smart Campaign

Smart Campaign Uganda convening participants

Smart Campaign Uganda convening participants

Earlier this year, the Smart Campaign co-hosted a financial inclusion and consumer protection event in collaboration with the Microfinance CEO Working Group and the Association of Microfinance Institutions of Uganda in Kampala, Uganda. With more than 100 people in attendance representing diverse stakeholder groups, the event served as a platform to exchange ideas and commit to greater partnership to progress financial inclusion policies and practices, and consumer protection in Uganda.

The goal of the event was to provide an opportunity to obtain clear commitments in support of the key themes and objectives of Uganda’s developing national financial inclusion strategy, and to place consumer protection at the heart of its roll out. The convening brought a variety of stakeholders together, including financial service providers, donors, researchers, government ministries, and the Bank of Uganda, to support the country’s consumer protection goals and facilitate better collaboration.

After hearing the perspectives and inputs of the key sector stakeholders in attendance, we took stock of our three-year strategy for the country. Going forward, the Campaign’s approach will focus on the following:
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> Posted by Kyle Burgess, Executive Director and Editor in Chief, Consumers Research

From cash to digital currency

Image Credit: FamZoo Staff. No alterations made. CC BY-SA 2.0

Digital currencies, such as Bitcoin and its underlying blockchain protocol, introduce a technical platform for a new global payment infrastructure that has the potential to level the playing field for the 2.5 billion people across the globe who are unbanked or underbanked. The immutable and distributed nature of digital currencies and a number of the platforms built on top of blockchain protocols can provide improved security, efficiency, affordability, privacy, and transparency in financial transactions, as well as a whole host of other transfers of value or information. Furthermore, thanks to the proliferation of mobile devices, blockchain-based digital currencies can even remove the middleman, and serve as a bank in your pocket. However, fully removing a third party intermediary comes with significant risks, as there’s no one to call if you lose your private key (which functions as your password), break your hardware wallet (which acts as your digital vault), or want to dispute a payment because the goods you purchased are damaged (because digital currency transactions are irreversible). Like any other product, consumer protection must be at the forefront of the development and implementation of digital currency and blockchain-based financial services.

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> Posted by Sonja Kelly, Director of Research, CFI

The role of data is increasingly crucial as the financial services industry shifts to digital delivery, alternative analytics, targeted marketing, and data-driven customer segmentation. As outlined in the recent Accion report, Unlocking the Promise of Big Data to Promote Financial Inclusion, the future of financial inclusion will include higher volumes of better quality and more wide-ranging data to expand access, lower prices, reduce bias, and drive innovation. However, the use of big and alternative data in financial inclusion is not a value-neutral trend—nor should it be.

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> Posted by Danielle Piskadlo, Manager, Investing in Inclusive Finance, CFI

Data privacy is officially dead. The U.S. House of Representatives’ vote to overturn the Federal Communications Commission’s (FCC) internet privacy rules was yet another nail in the coffin, making data privacy a thing of the past.

In previous generations, banking may have been based on personal relationships and a handshake. More recently, it was based on your banking history and financial flows. But for future generations, access to financial products and services will almost undoubtedly be decided by big data algorithms, gobbling-up whatever digitized information, financial or otherwise, the corporate tentacles can seize.

We know what you’re thinking. Won’t this help underwrite previously-underbanked individuals? Of course. And what does data-sharing matter so long as you don’t have anything to hide? Won’t ultra-targeted ads make the consumer experience better? All definitely true. Well, actually there are inherent problems with these lines of thinking, but honestly what’s the point of resisting? The notion of being “data rich” has never been more powerful. And what are negative social externalities in 2017? After all, the U.S. political system breathed new life into the fallacy of “clean coal” earlier this week in the name of making a few bucks.

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> Posted by Carmen Paraison, Project Associate, the Smart Campaign

On January 18th, 2017, the Consumer Financial Protection Bureau (CFPB) filed suit against Navient, the largest federal and private student loans servicer in the U.S., for “systemically and illegally failing borrowers at every stage of repayment.” Allegations include:

  • Misallocating student loan payments by failing to follow instructions from borrowers about how to apply their payments across their multiple loans.
  • Steering struggling borrowers toward multiple forbearances instead of lower payments via income-driven repayment plans. (Forbearance is an option that lets borrowers take a short break from making payments, but that still accrues interest.)
  • Providing unclear information about how to re-enroll in income-driven repayment plans.
  • Deceiving private student loan borrowers about requirements to release their co-signer (e.g. a parent or grandparent) from their loans, which can be advantageous given some lenders’ practices surrounding the death of a co-signer.
  • And failing to act when borrowers complained.

Navient currently services more than $300 billion in loans for more than 12 million borrowers.

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> Posted by Ros Grady

The following post was originally published on Ros’ website.

27204912422_277033d622_b2016 has seen a sharp-eyed global focus on clarifying what responsible digital financial inclusion means in practice. This is connected to the increasing recognition that digital financial inclusion brings new and significant risks for consumers, as well as considerable benefits.

The September 2016 McKinsey Global Institute Report – How Digital Finance Could Boost Growth in Emerging Economies – suggests that widespread use of digital finance (payments and digital services delivered via mobile phones and the Internet) could add $3.7 trillion to the GDP of emerging economies – or six percent – by 2025. Which in turn could create around 95 million jobs.

So responsible digital financial inclusion is important.

But what was new in 2016? Consider these important developments:

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In the following post, John Owens offers an overview of his research project with the CFI Fellows Program.

Background & Research Questions

More and more online credit providers have started to offer loans to not only consumers but also to SMEs around the world.

Outside of digital banking platforms, new alternative online and digital platforms that target consumers and small SMEs include:

  • Peer-to-peer (P2P) SME lenders
  • Online balance sheet lenders
  • Loan aggregator portals
  • Tech and e-commerce giants
  • Mobile data-based lending models

While the rise of alternative data-based lending has opened new and innovative credit opportunities for individuals and SMEs, these new technologies and providers also come with several consumer protection challenges. These can be categorized into seven main areas:
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> Posted by Nadia van de Walle, Lead, Africa Partnerships and Programs, the Smart Campaign

A keynote speaker at a recent conference I attended described consumer protection as “incredibly important,” before adding that it was also “boring.”  Palpable excitement buzzes around new products or technologies, but consumer protection can be a real buzzkill. After all, it is often viewed as a dry, bureaucratic subject, costly for providers, and entailing barriers to pace of change and convenience.

As the Smart Campaign’s Africa team lead, I’m excited about client protection! And that’s not because it’s my purview. First, I think that client protection should not be seen as pumping the breaks on financial inclusion’s momentum. Rather, it guarantees a longer, more enjoyable ride. Secondly, client protection need not be a dull compliance exercise. It too can crowdsource, beta-test, gamify, and so forth to hack innovative, agile, disruptive approaches. But seriously, as an industry we can consider and engage in client protection practices that are data-driven, and that use behavioral economics, human-centered design, fintech, and other disciplines to not only ensure fair consumer treatment but strengthen financial bottom lines.

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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.