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Overview
1. Defining DFS
2. Purpose of RDT
3. What RDT is Designed to Do & Its Goals
4. What We Do & How We Do It
5. Content of RDT
6. Complementary Resources
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Purpose of RDT
• Assist regulators to identify remove barriers to the
adoption of, or gaps in regulation of, DFS.
• Determine appropriate regulatory response based on
market assessment.
• Support regulators to navigate towards compliance
with SSBs while seizing opportunities DFS present for
financial inclusion and economic growth.
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What RDT Is / Is Not Designed to Do
• IS – designed to guide us in asking the regulator the
right questions
• IS – designed to list the issues that should be thought
about (but many will be raised to be dismissed)
• IS NOT – designed to lead to regulation in any
specific area
• IS NOT – designed to burden the regulator but to
assist in refining their focus.
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Goals of RDT
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What We Do
• Identify regulatory barriers and gaps by:
– Understanding the regulatory approach and local context;
– Reviewing all relevant legislation and regulation pertaining to DFS; and
– Interviewing stakeholders to understand implications of existing and proposed legislation and regulation (or lack thereof).
• Analyse relevant legislation and regulations including:
– banking and payments laws and regs, and all policy and legislation that directly impacts the uptake of DFS, including anti-money laundering, competition, data protection, data privacy and consumer protection .
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How We Do It
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Applicability and Use of the RDT
• Applicability: for regulators implementing financial inclusion strategies who want a conducive regulatory framework.
• Align with the local definition of success: requires regulators to first clearly state the current market situation and the regulator’s goals for DFS. The RDT then identifies the issues that need to be addressed for the regulator to achieve those goals.
• A tool to enhance regulatory capacity: designed as an objective means of assessing, reviewing and refining regulatory frameworks to support DFS.
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Content of the RDT
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Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
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Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
12
Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
13
Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
14
Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
15
Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
16
Overall
Regulatory
Architecture
AML/CFT
Data Privacy
Protection of Funds Consumer
Protection
Content of the RDT (cont’d)
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1. Regulator Responsibilities
2. Regulatory Mandate
3. Regulatory Capacity
4. Regulatory Coordination
5. Payments versus
Prudential Supervision
1. Regulatory Intention
2. Competition & Innovation
3. Consumer Demand
4. Financial Literacy
5. Interoperability
6. Partnerships
7. Access to Market Data
1. Deposits
2. E-Money
1. Use of Agents
2. Agent Services
3. Agent Compensation
4. Consumer Protection
1. Risk-Based Approach
2. Remote Account Opening
3. Simplified versus
Enhanced CDD
4. Transaction Monitoring
and Reporting
5. New Approaches to
AML/CFT
1. Mandate
2. Industry Codes
3. Disclosure
4. Recourse
5. Digital Delivery
1. Individuals’ Rights
2. Information Sharing
3. Credit Information
4. Dispute Resolution and
Recovery
Overall RegulatoryArchitecture
Building theEcosystem
Protection ofFunds
The Use of Agents
ConsumerProtection
AML/CFT
Data Privacy
Complementary Resources• UNSW Regulatory Handbook
• CGAP Branchless Banking Diagnostic Template
• Template questionnaires developed for UNSW Australia’s Regulation of Mobile Money Project (2013 – 2015)
• G20 Principles for Innovative Financial Inclusion
• Brookings Institute ‘2015 Brooking Financial and Digital Inclusion Project Report’
• BIS documents:– Measures of Financial Inclusion – A Central Bank Perspective (IFC, 2016)
– Payment Aspects of Financial Inclusion (CPMI & World Bank Group, 2016)
– Guidance on the Application of the Core Principles for Effective Banking Supervision to the Regulation and Supervision of Institutions relevant to Financial Inclusion (BCBS, 2015) (‘BIS Financial Inclusion Guidance’)
– Range of Practice in the Regulation and Supervision of Institutions relevant to Financial Inclusion (BCBS, 2015)
– Non-Banks in Retail Payments (CPMI, 2014)
– Innovations in Retail Payments (CPSS, 2012)
• GSMA Mobile Money Policy and Regulation Resources
• BTCA, ‘Ecosystem Diagnostic Toolkit’ and relevant Country Diagnostics BTCA Ecosystem Diagnostic Toolkit and relevant Country Diagnostics
• USAID Mobile Financial Services Risk Matrix
• Guidelines on data protection in EU financial services regulation
• Innovative Digital Payment Mechanisms Supporting Financial Inclusion - Stocktaking Report (A report by the World Bank Group’s Payment System Development Group, the Better Than Cash Alliance, and the Alliance for Financial Inclusion for the G20 Global Partnership for Financial Inclusion)
• OCC white paper: Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective
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