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> Posted by Elisabeth Rhyne, Managing Director, CFI
Internet privacy rules have just been overturned in the U.S. by Congress and the Administration, and at the same time, struggles over banking privacy are taking place. There are striking similarities as well as crucial differences. As a consumer protection advocate, I am struck by how the narrative about these kinds of conflicts primarily centers on where competitive advantage lies, and which company or industry is made the winner or loser, rather than about the rights of consumers.
The internet case pits telecoms and cable companies, like AT&T, Verizon and Comcast, against internet companies, like Google and Facebook. The Obama-era rules that were just overturned required broadband providers to ask customer permission before tracking, sharing and/or selling their data. These companies complain that the rules disadvantage them relative to internet-based companies, which can collect data without such rules.
The banking case, as reported in The New York Times, pits major banks against fintechs and data aggregators. The question is whether banks will transfer consumer data – at the consumer’s request – to companies that provide personal financial management tools, like Mint, Betterment, and Digit (or to data aggregators that facilitate the transfer – like Plaid and Yodlee). Without this data the financial management apps cannot build the complete portrait of a person’s financial life they need to provide analysis and advice. But banks are reluctant, even after specific consumer requests. You might think this reluctance is to protect their customers or because of data privacy rules for banking, but actually, according to The Times, it’s because the customer data reveals details about banks’ own business models – like pricing and products. The banks fear, probably correctly, that the personal financial management companies will use the information to undercut bank products with their own offerings.
> Posted by Sarah Rotman Parker, Director, the Center for Financial Services Innovation, and Sonja Kelly, Director, the Center for Financial Inclusion
The following post was originally published on the CGAP blog.
Over the past year, the Center for Financial Services Innovation (CFSI) and the Center for Financial Inclusion (CFI) have explored financial health in emerging markets. We wanted to understand whether the concept of financial health, promoted widely in the United States by CFSI, could be used as a relevant framework to understand consumers. Financial health is defined as coming about when your daily systems help you build resilience and pursue opportunities. Our working hypothesis was that financial health could serve as a method of tracking progress in emerging markets since it is what people strive to attain, and therefore is one of the core aims of financial inclusion.
Our work took us to rural and urban areas in Kenya and India. With the help of the Dalberg Design Impact Group and funding from the Bill & Melinda Gates Foundation, we asked consumers in these markets questions about their financial lives. These questions ranged from how much money they could come up with if they liquidated all of their assets to whether their friends would help them financially in the case of an emergency (and about a hundred other questions in between these two ends of the spectrum).
The aim of the research was to identify the key indicators of financial health in a developing world context, similar to the eight key indicators that CFSI had identified for the U.S. market. We found that while financial health as a concept holds in countries like India and Kenya, the indicators to define and measure financial health look somewhat different from those in the United States. The resulting framework can be summed up as follows (and the full report is here).
> 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.
> Posted by Elisabeth Rhyne, Managing Director, CFI
The following post was originally published on Devex.
In his proposed budget, U.S. President Donald Trump is calling for cuts to foreign assistance. In this message I would like to suggest that even with a smaller foreign aid budget, an excellent opportunity exists to work toward financial inclusion as a development goal. Financial inclusion provides wins all around: for business, for national security and for individuals — and it would not be expensive for the administration to pursue it.
Financial inclusion means ensuring that everyone — farmers, shopkeepers, teachers, students, etc. — has quality financial services to manage their lives and become economically productive. Over 2 billion adults worldwide lack a bank account. Financial services, including accounts, savings and credit, have become a gateway for social and economical inclusion, which in turn contributes to prosperity and peace. For the first time in history, financial inclusion is actually feasible: mobile money, e-commerce and digital financial services make it possible for providers to serve enormous new segments of the population.
> 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.
> Posted by Center Staff
This post is part of a series examining the global phenomenon of de-risking and its impact on financial inclusion. To investigate this issue, CFI staff partnered with Credit Suisse Global Citizen Rissa Ofilada, a compliance lawyer based in the Philippines, to undertake a literature review and conduct interviews with key players in the conversation on de-risking.
The root causes of de-risking have been surprisingly hard to pin down. In our previous post in this series, we looked at the role that the Financial Action Task Force (FATF) and global standards have played. Today we’ll examine the role of the U.S. government.
It is no wonder that decisions by the U.S. government—at both federal and state-levels—have a significant ripple effect. Most international settlement systems—the way that banks move money across borders—are pegged to the U.S. dollar. Furthermore, the U.S. plays a strong role in setting international global norms. Added to this is the massive size of the U.S. financial system and the power that the U.S. government has to govern the system. Finally, banks located in emerging markets, even if they are largely domestically oriented, need to be able to do business with U.S. businesses and banks, and therefore must remain in good standing with American authorities.
> Posted by Center Staff
Customers wait to collect money at the Juba Express money transfer company in Mogadishu, Somalia.
This post is part of a series examining the global phenomenon of de-risking and its impact on financial inclusion. To investigate this issue, CFI staff partnered with Credit Suisse Global Citizen Rissa Ofilada, a compliance lawyer based in the Philippines, to undertake a comprehensive literature review and conduct interviews with key players in the conversation on de-risking.
Are anti-money laundering and counter-terrorism financing (AML/CTF) rules to blame for de-risking and the resulting financial exclusion? A World Bank survey of financial institutions says, “probably.” The survey respondents listed concerns about money laundering and terrorism financing risks, including the imposition of international sanctions pertaining to AML/CTF. To say the least, the de-risking phenomenon has huge implications for the advancement of financial inclusion in our current geopolitical climate.
De-risking has been defined as the trend of financial institutions terminating or restricting business relationships with clients or categories of clients to avoid, rather than manage, risk. This can take the form of: restricting or terminating correspondent banking relationships (CBRs) where one bank provides services to another; restricting or terminating money transfer operators (MTOs); and restricting or terminating the accounts of individual clients deemed to be risky. It’s important to note that recently “de-risking” as a term has been called inappropriate by some as there may be other reasons why, to give one example, CBRs are terminated. Nevertheless, we use it here as it is the most commonly used phrase to describe this phenomenon.
> Posted by Sonja Kelly, Director, CFI
This post is the first in a series examining the global phenomenon of de-risking and its impact on financial inclusion. Through the Credit Suisse Global Citizens Program, CFI partnered with Rissa Ofilada, who works as a lawyer in compliance in the Philippines, to undertake a study on de-risking. In the series, we’ll discuss the causes of the phenomenon, what it means for customers at the base of the pyramid, how it affects global momentum toward financial inclusion, and what solutions are on the horizon.
The term de-risking may sound arcane and technical, but in fact some observers believe that de-risking is the biggest threat to the progress that has already been made on financial inclusion. We at CFI are worried about it—and you should be too.
De-risking refers to the trend of commercial banks, payments companies, and regulators closing down “suspicious” accounts. These accounts could be suspicious for any number of reasons. The owner may not have had adequate proof of identity—a common problem for lower-income people in countries without well-developed identification systems. Or the owners may not be able to precisely trace the source of the funds they deposit—a frequent issue for those operating in the informal sector. Or the provider had a problem with another lower-income customer who was flagged as suspicious, and as a result decided to close all accounts owned by people with similar patterns or profiles.
> Posted by Nadia van de Walle, Lead, Africa Partnerships and Programs, the Smart Campaign
The following is part of the Smart Campaign’s #FintechProtects mini campaign. We’re raising awareness about responsible digital financial services, spotlighting work from the Smart Campaign and others, and engaging with industry actors on how fintech can move forward in a way that’s best for clients. For more information on #FintechProtects, and to get involved, click here.
Do you have a credit card you don’t know about? Last week, we learned that over 5,000 employees across Wells Fargo, the United States’ biggest home lender and one of the nation’s largest banks, had opened at least two million unauthorized deposit and credit card accounts in clients’ names. In an effort to meet high sales targets and earn bonuses, bank employees transferred funds from customers’ existing authorized accounts to unapproved accounts in customers’ names. Clients had not consented and were mostly unaware of this, despite incurring late fees and other charges on these new unapproved accounts. The widespread practice had somehow gone undetected for 5 years.