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Today, inclusive financial products are fueled by ever-growing volumes of digital consumer data, primarily collected by mobile phones. Coupled with advances in analytics and innovations in data sharing, the face of privacy has changed radically. Despite the growing interest in Privacy by Design (PbD), a systems-engineering approach that calls for companies to consider privacy throughout the engineering process, current approaches overlook the growing importance of product managers in digital and software product development. This playbook, a first-of-its-kind knowledge product for the inclusive finance sector, aims to fill that gap and demonstrate a comprehensive way to integrate responsible data practices into the design process.

The Privacy as Product Playbook is based on the central tenets and emerging practices in Privacy by Design and is animated by unique considerations for inclusive finance product teams. The accompanying brief is intended for all practitioners in the inclusive finance space, sharing the rationale and approach for the playbook and discussing three key challenges for implementation that were uncovered when designing the playbook, how the playbook attempts to address them, and what learning questions remain.

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This playbook and brief are a result of CFI’s partnership with PayPal’s Global Privacy Team.

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Privacy as Product: Privacy by Design for Inclusive Finance

This is part of a <a class="fui-Link ___10kug0w f3rmtva f1ewtqcl fyind8e f1k6fduh f1w7gpdv fk6fouc fjoy568 figsok6 f1hu3pq6 f11qmguv f19f4twv f1tyq0we f1g0x7ka fhxju0i f1qch9an f1cnd47f fqv5qza f1vmzxwi f1o700av f13mvf36 f1cmlufx f9n3di6 f1ids18y f1tx3yz7 f1deo86v f1eh06m1 f1iescvh fhgqx19 f1olyrje f1p93eir f1nev41a f1h8hb77 f1lqvz6u f10aw75t fsle3fq f17ae5zn" title="https://www.centerforfinancialinclusion.org/series/digital-cash-transfers-for-women" href="https://www.centerforfinancialinclusion.org/series/digital-cash-transfers-for-women" rel="noreferrer noopener" aria-label="Link series">series</a> of work done in partnership with CFI and WFP, with funding from the Bill &amp; Melinda Gates Foundation, that explores how we can improve the design and delivery of digital cash transfers for low-income women.

Cash transfer programs have emerged as a crucial tool in the global effort to combat poverty, overcome shocks and other adversities, and achieve the Sustainable Development Goals (SDGs). Cash transfers provide financial support to vulnerable households, enabling them to meet their basic needs, access essential services, and invest in income-generating activities. However, beyond the immediate economic relief they offer, cash transfer programs also have the potential to <a href="https://cdn.odi.org/media/documents/11316.pdf" target="_blank" rel="noopener noreferrer">address deeper societal issues, including gender inequality</a>. 
<blockquote class="pullquote--right">By putting money directly into the hands of women within households, these programs challenge traditional gender norms and empower women to make decisions about finances, thereby enhancing their control over economic resources.</blockquote>
<a href="https://blogs.worldbank.org/voices/building-back-better-means-designing-cash-transfers-womens-empowerment" target="_blank" rel="noopener noreferrer">Women's economic empowerment</a> is increasingly recognized as a central objective of cash transfer programs. By <a href="https://docs.wfp.org/api/documents/WFP-0000141256/download/" target="_blank" rel="noopener noreferrer">putting money directly into the hands of women within households</a>, these programs challenge traditional gender norms and empower women to make decisions about finances, thereby enhancing their control over economic resources. This not only contributes to reducing gender inequalities but also enhances women's access to formal digital financial services and potentially brings additional benefits such as <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2022/12/Bridging-the-gap-1.pdf">increasing access to identification documents</a>. 

As we explore the potential benefits of directing funds to women, a critical question arises: could this approach exacerbate the risk of intimate partner violence (IPV)? This question probes the potential shifts in power dynamics within households and the increased vulnerability women might face as they gain control over financial matters. 

Is this concern rooted in perception, or does substantial evidence support these claims? To dig into this question, a <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/09/Sending-Cash-Transfers-to-Women-Report.pdf">comprehensive study</a> conducted by CFI, in partnership with the World Food Programme (WFP) and funded by the Bill &amp; Melinda Gates Foundation, examined existing evidence and sought insights from experts in the field. The study's findings suggest that directing funds into the hands of women on behalf of their households can in fact reduce the risk factors associated with IPV. This positive outcome is primarily attributed to the alleviation of financial stress within households and improvements in emotional well-being. However, it is essential to acknowledge that despite the potential benefits, cash transfers to women may still trigger instances of IPV, especially in contexts where harmful gender norms are deeply ingrained.
<blockquote>Despite the potential benefits, cash transfers to women may still trigger instances of IPV, especially in contexts where harmful gender norms are deeply ingrained.  </blockquote>
Globally, <a href="https://www.who.int/publications/i/item/9789240026681" target="_blank" rel="noopener noreferrer">27 percent</a> of ever-married/partnered women, ages 15 – 49 years, have experienced physical or sexual violence by an intimate partner in their lifetime. Women living in the least developed countries and in countries facing conflicts are disproportionately affected with an even higher prevalence of IPV. Gender inequalities that restrict women’s access to basic services and rigid social norms that support masculinities based on power and control are <a href="https://www.who.int/news/item/09-03-2021-devastatingly-pervasive-1-in-3-women-globally-experience-violence" target="_blank" rel="noopener noreferrer">major risk factors leading to IPV</a>. Cash transfers directed to women on behalf of the household can challenge these norms by putting money in the hands of women. However, simply transferring cash is not enough and must be accompanied by <a href="https://apps.who.int/iris/bitstream/handle/10665/312261/WHO-RHR-18.19-eng.pdf?ua=1" target="_blank" rel="noopener noreferrer">programming to gradually transform gender norms</a>. 

In line with the "do no harm" principle, designing cash transfer programs that effectively minimize the risks of IPV is paramount, particularly in settings where such violence is prevalent. At the same time, it is crucial to consider the impact on IPV beyond the program’s duration and explore how the reduction in IPV can be sustained in the longer term.  
<h1>How to Design Cash Transfer Programs and Send Money to Women While Reducing Risk of Intimate Partner Violence  </h1>
From this research, CFI and WFP developed a <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/09/Sending-Cash-Transfers-to-Women-infographic.pdf">guide</a> that details how to design cash transfer programs that enhance household well-being, increase women’s empowerment, and reduce the risks of IPV. It is important to note that effective design and implementation of cash transfer programs directed to women’s accounts should follow a comprehensive assessment of IPV risks, carefully considering contextual factors including prevailing gender norms, socioeconomic dynamics, and political conditions. 

Several key recommendations emerge from our analysis: 

<img class="wp-image-46448 size-full alignnone" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/09/Screenshot-2023-09-27-at-2.49.17-PM-e1695913799888.png" alt="" width="791" height="607" /> <img class="size-full wp-image-46449 alignnone" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/09/Screenshot-2023-09-27-at-2.49.32-PM.png" alt="" width="791" height="779" />

&nbsp;

The <a href="https://www.centerforfinancialinclusion.org/sending-cash-transfers-to-women-how-to-design-programs-that-enhance-well-being-while-safeguarding-against-intimate-partner-violence">full report</a> from the study details actionable insights backed by lessons and examples from diverse cash transfer programs.

Cash Transfers Directed to Women and the Implications for Intimate Partner Violence: Lessons for Program Design

When cash transfers are safely sent directly to women, they have the potential to address gender inequities by helping women meet basic needs, access essential services, and invest in income-generating activities. But prioritizing women as the primary recipients of cash transfer programs, and thus diverging from traditional practices where men are the heads of households, raises concerns about intimate partner violence (IPV).<span class="EOP SCXW226271306 BCX0" data-ccp-props="{&quot;134233117&quot;:false,&quot;134233118&quot;:false,&quot;201341983&quot;:0,&quot;335559738&quot;:0,&quot;335559739&quot;:160,&quot;335559740&quot;:240}"> This report examines existing evidence on the impact of cash transfers on IPV against women and proposes design approaches to mitigate and minimize those risks. While the report primarily focuses on evidence related to reducing the risk of IPV following cash transfers to women on behalf of households, it also underscores the potential that sending cash to women has for reducing existing IPV. The objective is to foster a constructive dialogue and encourage governments and humanitarian organizations implementing cash transfer programs to prioritize women as the recipients of cash on behalf of their households whenever feasible, while ensuring their safety and adequate support.  

This series, created in partnership with World Food Programme (WFP), the Center for Financial Inclusion (CFI), and the Bill &amp; Melinda Gates Foundation, shares how we can improve the design and delivery of digital cash transfers for low-income women.

Sending Cash Transfers to Women: How to Design Programs that Enhance Well- Being While Safeguarding Against Intimate Partner Violence

‘Responsible Finance’ is Not Responsible if it’s Not Gender-Intentional

Why is meal planning a recommended financial strategy for women but not for men with children, according to ChatGPT? And why is this important for financial services?

Natural language processing (NLP) tools can create human-like conversations. Perhaps the most well-known application of an NLP tool is ChatGPT, which <a href="https://www.theguardian.com/technology/2023/feb/02/chatgpt-100-million-users-open-ai-fastest-growing-app" target="_blank" rel="noopener noreferrer">reached over 100 million users two months after its launch</a> in November 2022. Many people have increasingly used ChatGPT as a tool for work or personal use. I wanted to test if ChatGPT showed gender bias when looking at finance-related applications, so I inputted a few prompts about financial services. The results are a reminder that while AI is a powerful tool, it is not free from problematic social norms and potential bias against women. This week CFI <a href="https://www.centerforfinancialinclusion.org/equitable-ai-for-inclusive-finance">released two new publications</a> to help strengthen industry conversations to mitigate against, monitor for, and correct harmful gender bias in inclusive finance. These publications are the result of CFI’s winning proposal to USAID’s <a href="https://www.usaid.gov/innovation/competitions/equitable-ai-challenge" target="_blank" rel="noopener noreferrer">Equitable AI Challenge</a>, implemented by DAI’s Digital Frontiers.
<blockquote class="pullquote--right">One simple prompt revealed three problematic differences. However, they reflect a complex problem requiring an urgent response.</blockquote>
When I asked ChatGPT, or GPT-3.5, to write financial advice to help men and women with children, the answers showed important differences by gender, as seen in the following screenshots. For instance, the tool recommended that men, not women, create or update their wills and designate beneficiaries for their assets. This result demonstrates an existing assumption that men with children are more likely to have assets or income than women with children. Moreover, GPT-3.5 advised only men, not women, to have a work-life balance and spend quality time with their families. Again, this shows a bias about gender roles in work and within families. Another blatant example was the recommendation GPT-3.5 gave to women, but not to men, about planning meals. The tool advised women to cook larger meals at home and plan their grocery shopping to save money.

One simple prompt revealed these three problematic differences. However, they reflect a complex problem requiring an urgent response — especially as many companies, including fintechs, incorporate AI tools, such as NLP, into their business models.

<img class="aligncenter size-full wp-image-46358" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/EqAI-ChatGPT-01.png" alt="" width="4038" height="3555" />
<h2>Growing Use Cases of AI in Inclusive Finance</h2>
AI has <a href="https://www3.weforum.org/docs/WEF_AI_in_Financial_Services_Survey.pdf" target="_blank" rel="noopener noreferrer">numerous applications in the financial sector</a>, such as revenue generation, process automation, risk management, client acquisition, and customer service. Companies are increasingly using AI to accelerate lending decisions and use alternative data — including social media, mobile phone activity, and satellite data — to measure creditworthiness. AI presents an opportunity to quickly expand access to financial services for populations without long credit histories, including women. Companies use facial patterns, voice recognition, and biometric data for know-your-customer (KYC) requirements and to verify customers’ identities. Insurance companies use AI algorithms to speed up claims processing. Companies are also using AI tools for client acquisition and customer service. Chatbots and virtual assistants help prospective and existing customers find information about financial products that meet their needs.
<blockquote>Instead of offering helpful customization, the financial advice given perpetuates outdated and unhelpful stereotypes. The resulting harm from biased AI systems used in financial services contradicts the goals of financial inclusion and has potential business and regulatory costs for fintechs and their investors.</blockquote>
However, while AI tools are making high-stakes decisions for the economic prospects and future of individuals, their businesses, and their communities, these systems are also introducing new risks, including data privacy vulnerabilities and unfair outcomes for certain consumers. Women have experienced negative effects, such as being unfairly rejected as “false negative” in credit decisions, or receiving higher pricing, lower credit limits, and more limited choices.  As the above experiment with GPT-3.5 showed, algorithms can provide different financial advice depending on a customer’s gender. When designed well, tailored solutions for different customer segments can increase usage by satisfying the specific needs of the group. However, in this case, instead of offering helpful customization, the financial advice given perpetuates outdated and unhelpful stereotypes. The resulting harm from these issues contradicts the goals of financial inclusion and has potential business and regulatory costs for fintechs and their investors.
<h2>Sources of Harmful Gender Bias</h2>
<img class="wp-image-46360 alignright" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/Screenshot-2023-08-25-at-7.40.18-AM.png" alt="" width="405" height="408" />

CFI has written extensively on the opportunities and risks of AI for inclusive finance, and in 2021, we released a <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2021/03/The-Stories-Algorithms-Tell-CFI-publication-MAR21.pdf">framework to help understand algorithmic bias</a>. The framework included three buckets to categorize sources of harmful AI bias: 1) inputs (such as datasets and AI teams), 2) code, and 3) context.

Applying this framework to my experiment with ChatGPT illustrates a few examples of where differences in financial advice by gender may originate. However, it’s important to highlight that these possible explanations are purely theoretical, as we have not tested them empirically.

Inputs: NLP and AI algorithms are trained on data to make predictions and inform decisions. In this case, <a href="https://medium.com/@dlaytonj2/chatgpt-show-me-the-data-sources-11e9433d57e8" target="_blank" rel="noopener noreferrer">GTP-3.5 processed input data from the web, books, and WebText2</a>, which is culled from Reddit submissions. As you may imagine, in aggregate these input datasets compile a series of beliefs and social norms, such as the one that suggested that women save money through meal prepping.

Code and Context: As a model is being built, developers can use techniques to reduce biased responses by, for instance, penalizing the model for generating harmful or stereotypical content. AI developers, or other actors, can periodically review model outputs after launch and provide feedback and adjustments over time. However, if the teams testing the system are primarily men, problematic outputs — like from my experiment — may be less likely to be flagged.
<h2>A Path Forward </h2>
As with any technology that experiences exponential growth, stakeholders — like investors, donors, and regulators — must play catch-up, and many questions remain. How, amid all these changes, can concerned stakeholders understand, let alone contribute to, shaping the future of AI in a way that is responsible and equitable, particularly for achieving our target financial inclusion outcomes?

In the inclusive finance sector, many actors are increasingly interested in incorporating principles and tools that guide the responsible and equitable deployment of AI. However, although there is a proliferation of techniques and academic resources to identify, mitigate, and correct bias, our extensive review of over 120 guides and checklists showed a lack of tools appropriately designed for the financial sector.

Recognizing this gap, CFI developed and this week released a <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/Equitable-AI-Guide.pdf">practical guide</a> to help impact investors identify harmful AI gender bias among their investee companies, and an <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/Equitable-AI-Brief.pdf">accompanying brief</a> that presents some of the key challenges with building accountability and transparency for AI in inclusive finance and offers opportunities to strengthen the industry conversation. Recommended practices in the guide touch on data, inputs, and model building as well as crucial business practices including governance. For instance, in the case of OpenAI, the creator of GPT-3.5, the company publicly committed that AI should benefit all of humanity and wrote <a href="https://openai.com/safety" target="_blank" rel="noopener noreferrer">principles to guide their mission</a>. This stance may explain OpenAI’s six-month effort to make the new version of ChatGPT, GPT-4, safer and with hopefully fewer problematic outputs. I’ll be sure to check back with some prompts for GPT-4!

Read more about our work around equitable AI <a href="https://www.centerforfinancialinclusion.org/equitable-ai-for-inclusive-finance">here</a>.

<img class="aligncenter size-full wp-image-46361" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/Screenshot-2023-08-25-at-7.42.00-AM.png" alt="" width="2054" height="1034" />

*Note: In this blog, gender gaps refer to the gap between women and men. However, CFI acknowledges that gender includes non-binary populations such as LGTBQ communities. It is essential to highlight that this blog does not intend to dismiss the existence of non-binary people.

Gender Bias in AI: An Experiment with ChatGPT in Financial Inclusion

On the outskirts of sprawling Delhi, 34-year-old Maya opens her kirana, a small grocery store, for the day. Sleeves of shampoo packets and dry snacks line the walls around the counter where Maya serves up to 80 customers on a good day. She accepts payments in cash as well as digital payments on her smartphone, thanks to India’s successful <a href="https://www.forbes.com/sites/zennonkapron/2023/04/10/is-indias-upi-real-time-payments-system-ready-to-go-global/?sh=298e95e94d14" target="_blank" rel="noopener noreferrer">Unified Payments Interface (UPI) system</a>. However, while Maya’s name is registered as the business and bank account owner, she does not know much about the bank account or the business finances beyond her handwritten ledger book. Instead, her husband manages the banking relationship, and she must ask him for more cash or information about the account balance.
<blockquote>Many registered businesses are owned and managed by women only on paper; their lived realities are much different.</blockquote>
According to the Indian Ministry of Micro, Small &amp; Medium Enterprises (MSMEs), <a href="https://msme.gov.in/msme-annual-report-2022-23" target="_blank" rel="noopener noreferrer">women only own 20 percent of Indian MSMEs</a>. While this is already a small figure, ​​​​<a href="https://www.centerforfinancialinclusion.org/fight-gender-inequality-prioritizing-womens-customer-experience-in-product-design-and-complaint-resolution-processes">interviews conducted in March 2023</a> with 38 women business owners in India suggest that this number may be even lower. Many registered businesses are owned and managed by women only on paper; their lived realities are much different.

<img class="aligncenter wp-image-46289" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/Nina-Liew-blog-graphic.png" alt="" width="1009" height="235" />
<h1>Challenging Existing Norms</h1>
Providing financial services to women in low- and middle-income countries <a href="https://www.povertyactionlab.org/policy-insight/designing-financial-services-and-social-protection-programs-enhance-womens-economic" target="_blank" rel="noopener noreferrer">does not necessarily result in economic empowerment</a> if women do not or cannot make the decisions about their finances. Of the Indian women micro- and small-business (MSE) owners interviewed, over one-third relied on a man — typically a husband or brother — to manage or assist in their use of financial services, even if the woman was the registered owner of the business and bank account. When asked why, women said it was because of personal preference, a lack of confidence in operating the account, or that it was the man’s choice. This was true of interviewees with a master’s degree as well as those with lower levels of formal education, illustrating the pervasiveness of gender norms across education levels.

Managing the business’ day-to-day finances extends to resolving issues with a bank or fintech. Women who rely on their husbands or brothers to operate their bank accounts will often wait for them to contact the agent -- who is usually a man -- to resolve any complaints. This process is time-consuming and causes friction in women’s daily business activities. Consequently, these women may turn away customers if they do not have enough cash or lack information on accessing financial services for business improvement or growth.

For women in India to fully realize their economic contribution to the Indian economy, we must challenge and change existing norms. The current lack of equality represents a missed opportunity as bona fide access to formal financial services enables women to build their assets and wealth, improving their wellbeing and the wellbeing of their families.
<h1>Benefits for Women and Businesses</h1>
The burgeoning fintech sector has the pivotal opportunity to create better outcomes for women. India’s fintech sector is one of the fastest growing in the world, with approximately <a href="https://www.bain.com/insights/india-fintech-report-2022-sailing-through-turbulent-tides/" target="_blank" rel="noopener noreferrer">USD $35 billion invested</a>, more than doubling India’s share of global fintech funding since 2016. However, many fintechs are “gender-neutral” and do not design intentionally for diverse genders, reinforcing discriminatory gender norms. For example, because women tend to have <a href="https://www.centerforfinancialinclusion.org/an-equitable-rebuilding-learnings-from-women-owned-msmes">lower rates of digital transactions or formal financial assets</a>, it can be more challenging for them to meet loan eligibility requirements. When fintechs have a gender-neutral approach, the <a href="https://www.inclusivefintech50.com/2022-insights" target="_blank" rel="noopener noreferrer">gender gap is 28 percent higher</a> than the gap for bank accounts or smartphone ownership.
<blockquote class="pullquote--left">Many fintechs are “gender-neutral” and do not design intentionally for diverse genders, reinforcing discriminatory gender norms.</blockquote>
Advancing gender-intelligent changes and developing strategies to overcome women’s specific constraints can help fintechs tap into the <a href="https://financialallianceforwomen.org/download/how-fintechs-can-profit-from-the-multi-trillion-dollar-female-economy/" target="_blank" rel="noopener noreferrer">$216 trillion global market</a> controlled by women. Research by the Financial Alliance for Women shows that fintechs could see a ​​​​<a href="https://financialallianceforwomen.org/download/how-fintechs-can-capture-the-female-economy/" target="_blank" rel="noopener noreferrer">70 percent increase in revenues</a> by converting new women customers at the same rate as men. While building economic power for women on its own is a compelling reason to inspire change, this financial incentive is an additional driving force for investor-backed and profit-driven fintechs to prioritize gender-inclusive design and compete in an increasingly crowded market.
<h1>Increasing Diversity Is a Crucial Driver of Change</h1>
One fundamental way that fintechs can adapt their strategies to benefit women is by increasing their organizational diversity. From its interviews with the <a href="https://www.inclusivefintech50.com/" target="_blank" rel="noopener noreferrer">Inclusive Finance 50</a> fintech winners, CFI found that women-led fintechs were <a href="https://www.inclusivefintech50.com/2021-insights" target="_blank" rel="noopener noreferrer">more likely</a> to explicitly target and serve more women customers and report gender segmentation data, which is necessary for gender-intelligent decision making. This staff diversity should extend to customer-facing roles, such as the agents and distributors interacting with women customers, and women business correspondents are critical in <a href="https://www.adb.org/publications/digital-doorstep-banking-female-banking-agents-lead-digital-financial-inclusion-through-the-pandemic-and-beyond" target="_blank" rel="noopener noreferrer">expanding financial inclusion</a>. Interfacing with women staff makes it easier for women business owners to manage financial matters as women place a higher value on building personal relationships with agents and building trust over time.
<blockquote class="pullquote--right">Women-led fintechs were more likely to explicitly target and serve more women customers and report gender segmentation data.</blockquote>
Investors and regulators can also incentivize and require fintechs to make these changes. For example, through <a href="https://www.womensworldbanking.org/what-we-do/gender-lens-investing/" target="_blank" rel="noopener noreferrer">gender lens investing</a>, Women’s World Banking works toward higher social and financial returns. Their in-depth approach uses fintech data to develop customized, strategic Gender Action Plans, and their first fund saw an <a href="https://www.womensworldbanking.org/what-we-do/gender-lens-investing/" target="_blank" rel="noopener noreferrer">83 percent increase in women reached</a> by portfolio companies. 

Although fintechs alone cannot bring about an overnight transformation in societal and gender norms, taking these steps represents a real and immediate opportunity to initiate change for the economic empowerment of women in India and beyond.



<a href="https://www.linkedin.com/in/camilla-nestor-640b70">Camilla Nestor</a>, Advisory Council Member of CFI and CEO of MCE Capital, teaches a financial inclusion course at Columbia’s <a href="https://www.sipa.columbia.edu/">School of International and Public Affairs</a> (SIPA). Each year, the course features a writing competition that gives students an opportunity to write a blog post on a topic of their choice related to inclusive finance. This piece was written by the winner of the 2023 writing competition, Nina Liew.

This work is inspired by a graduate research project conducted by students at Columbia University’s School of International and Public Affairs in consultation with CFI and with support from <a href="https://ifmrlead.org/">LEAD at Krea University</a>. Nina and the team of graduate students focused on digital financial inclusion and consumer protection for women MSE owners in India. They interviewed 38 women MSE owners, bank and fintech agents, and fintech executives in India in March 2023. 

Note: The story in this post was created as an amalgamation of interviewees.

Power in Practice – or Only on Paper? Addressing the Financial Gaps Affecting Women Business Owners in India

This blog post was generated from a research project conducted by a team of graduate students from Columbia University’s <a href="https://www.sipa.columbia.edu/" target="_blank" rel="noopener noreferrer">School of International and Public Affairs</a>, in consultation with CFI and with support from <a href="https://ifmrlead.org/" target="_blank" rel="noopener noreferrer">LEAD at Krea University</a>. The team focused on digital financial inclusion and consumer protection for women micro- and small-enterprise (MSE) owners in India and interviewed 38 women MSE owners, bank and fintech agents, and fintech executives in India in March 2023. Please note: Akanksha is a composite character based on interview anecdotes.  

It is the middle of the day in Noida in Uttar Pradesh, and an angry customer storms into Akanksha’s small mobile phone and banking agent shop. The customer demands to know why his parents have not yet received the money he transferred to them at Akanksha’s shop yesterday. To calm him down, Akanksha explains that the bank app’s server experienced an electrical outage in the morning that stalled all transactions. However, the customer continues to demand an immediate fix. 
<blockquote class="pullquote--left">As a woman, building trust with male customers has been particularly challenging, but she must do so since most customers are men. </blockquote>
In addition to running her shop, Akanksha is an agent for banks and fintechs, offering mobile money transfers and various utility services. In this scenario, she faces a tough decision. Akanksha must choose how to address the customer’s complaint – she can try to resolve the issue via the bank app, contact her area distributor — the middleman between banks or fintechs and the network of local agents serving customers, or close her shop and visit the bank. How she handles this complaint is critical, as she must maintain her customer base and the hard-earned trust of her customers. As a woman, building trust with male customers has been particularly challenging, but she must do so since most customers are men. 

Akanksha, a woman in her mid-thirties with a bachelor’s degree, is not confident in filing a formal complaint using the app, which only has instructions in English. She also does not want to file a formal complaint out of fear that staff may escalate her issue to upper management, damaging her relationship with bank staff or her distributor. She attempts to contact her distributor on WhatsApp, but he does not answer. Because her husband is busy at work, Akanksha has no choice but to close her shop early and walk to the bank to talk to a staff member in person.  
<h2 style="text-align: center;"><img class="aligncenter wp-image-46280" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/08/SIPA_quote1.png" alt="" width="1074" height="180" /></h2>
<h1>Minor Issues With Major Implications </h1>
While Akanksha’s story is fictional, it is not an uncommon situation for many women MSE owners in India. A team of graduate students from Columbia University interviewed 38 women in India who use digital financial services (DFS) to understand their user experiences with banking and fintech apps, especially concerning the complaints journey. The interviews revealed that a stalled transaction is just one of several common issues faced daily by women MSE owners and agents like Akanksha. Stalled transactions and outages are so common that one interviewee described this as “just a part of life.” Almost all interviewees (35 out of 38) experienced at least one minor issue like this when using banking or fintech apps. Because each instance takes valuable time to resolve and leads to lost revenue, the effects of “minor” issues can significantly impact MSE owners’ businesses. One interviewee reported closing her shop for 15-minute periods multiple times a day to walk to the bank and settle matters in person.  

Akanksha’s experience highlights some of the barriers to complaints resolution and consumer protection for women MSE owners in India, driven by low confidence in DFS and a reliance on personal relationships with distributors and staff. In an interview with one fintech CEO – whose company was also among the <a href="https://www.inclusivefintech50.com/" target="_blank" rel="noopener noreferrer">Inclusive Fintech 50</a> winners – she said, “Women do not come screaming and shouting; this never happens. Local partners are more approachable. It is a business relationship; if you go to that level, it is also a social relationship.” 

An example of this type of social relationship is how many women agents rely on and highly value their personal relationships with distributors who travel to different communities to collect and disburse cash to agents. One agent even described her distributor as her “mentor and guru.” However, this relationship can also be vulnerable; distributors can exploit agents who depend on them for operational needs and resolving issues. Furthermore, if complaints are made informally to the distributor, which is often true for women, distributors are not incentivized to formally record complaints. As a result, the absence of an official record limits management’s oversight of the challenges women agents face.  
<h1>Finding Solutions That Better Serve Women </h1>
<a href="https://www.microsave.net/2018/10/24/consumer-protection-in-the-digital-age/" target="_blank" rel="noopener noreferrer">Existing literature</a> points to factors such as literacy levels, a difficult interface, and a lack of trust that prevent the adoption and use of DFS. However, there remains a gap in understanding the challenges in post-adoption utilization of services, particularly in the face of weak consumer protection provisions by low-income women users. Therefore, in our study, we aimed to explore how consumer protection policies impacted the experiences of women MSEs in using DFS, particularly with complaint redressal.

We found that, generally, women were not comfortable with the process of submitting formal complaints. Despite fintechs and DFS providers having established complaints handling processes under their consumer protection policies, they are often inadequate in supporting their women users. This results in many women abandoning platforms altogether. 
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The interviews with women users in India showed that they highly value personal relationships and prefer in-person complaint resolution. However, women face higher challenges to complaint redressal because of their strong preference for resolving issues through social interactions and providers’ lack of gender-sensitive consumer protection policies. As such, to accommodate women’s user preferences, banks and fintechs need to adopt <a href="https://www.centerforfinancialinclusion.org/the-case-for-a-gender-intelligent-approach-an-opportunity-for-inclusive-fintechs">gender-intelligent</a> strategies.

Through a gender-intelligent approach, banks and fintechs can better understand how women use complaint resolution processes and ultimately design offerings that address their specific needs. This approach can help <a href="https://www.centerforfinancialinclusion.org/the-case-for-a-gender-intelligent-approach-an-opportunity-for-inclusive-fintechs">change entrenched gender inequalities</a> and <a href="https://financialallianceforwomen.org/download/how-fintechs-can-capture-the-female-economy/" target="_blank" rel="noopener noreferrer">benefit</a> companies’ bottom lines. Therefore, solutions should focus on directly addressing women’s specific needs while considering the ability to achieve scale.

Based on the research interviews, we recommend that banks and fintechs consider the following:
<h3>1. Banks and fintechs should develop support features that strengthen women agents’ ability to use their apps confidently.</h3>
This approach could include robust in-person onboarding, training, and support in learning to use the app’s features. While this element is considered “high-touch,” <a href="https://www.accion.org/the-path-forward-for-human-touch-in-a-high-tech-world" target="_blank" rel="noopener noreferrer">the tech-touch balance</a> is vital in providing inclusive financial services. Women users also reported that certain apps and resources were only available in English. Consequently, financial service products should be available in local languages and cater to varying literacy levels.
<h3>2. Banks and fintechs should formalize the full scope of the complaint process for their digital financial services.</h3>
Our research found that many women agents resolve complaints through informal mechanisms such as calling, texting (including WhatsApp), or meeting in person with distributors. Therefore, banks and fintechs should update processes and incentives to record distributor interactions and include them in formal complaint resolution processes and metrics.
<h3>3. Banks and fintechs should build user communities that enable high-touch and in-person support at scale.</h3>
Due to the travel-intensive and vulnerable cash collection nature of the role, most distributors are men. However, there is an opportunity to engage women as distributors to support women agents – one example is creating an “ambassador” program where established and high-performing women agents onboard and help new women agents. The incentive for becoming an ambassador is recognition as an expert and leader within the community. While many of our interviewees said they did not know other women agents, we saw that those who had learned from other women had higher competency levels in using the bank and fintech apps.   
<h3>4. There should be more physical meeting spaces or local offices for women customers to meet staff and raise complaints.</h3>
For example, one gender-intelligent fintech established local meeting hubs to support women using fintech services. By providing a secure environment and personalized assistance, the space motivated women customers to raise issues and embrace a broader range of digital financial services, ultimately improving customer loyalty and lifetime value to fintechs.

These recommendations are merely the beginning of the transformative potential of digital financial services in advancing financial inclusion and consumer protection for women. By taking experiences like Akanksha’s into account during the product design and complaint resolution processes, banks and fintechs can forge a more inclusive complaints-handling strategy. Such an approach would enable women MSE owners and agents to thrive, expand their businesses, and achieve greater economic prosperity. When more women feel they can use DFS and fintech successfully, financial service providers can expand their business reach, demonstrating that gender-intelligent design is a win for all.

Fight Gender Inequality: Prioritizing Women’s Customer Experience in Product Design and Complaint Resolution Processes

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The saying that is often attributed to Einstein is that insanity is defined as doing the same thing over and over again and expecting different results. While it’s been contested that Einstein said these words, it is nonetheless a saying that deserves reflection.

In responsible finance, we can feel stuck in this cycle of insanity. We continue to see the same old risks, and new risks are constantly emerging -- yet our toolbox is not keeping up. This cycle is most vivid when meeting with clients.

When visiting the northern wetlands in Colombia, I met a small business owner -- let’s call him Juan -- who recounted his experience with identity theft. A large financial institution approached Juan about taking out a loan for a pool table he planned to put in the beer hall that he owned in his village. After speaking with the bank agent and, presumably, applying for the loan, he never saw the agent again nor received the money. When visiting the branch to find out what had happened to his loan, he discovered that the bank records showed it already disbursed his loan, even though he had never received the funds. He tried to resolve the issue with the bank, but the cost of travel to the nearby town where the branch is located, the expense of taking time off work, and not understanding how to resolve this issue created massive hurdles for Juan. Similar challenges apply to millions of other low-income people around the world.
<blockquote>We continue to see the same old risks, and new risks are constantly emerging -- yet our toolbox is not keeping up.</blockquote>
During a recent trip to Kenya, I spoke to drivers of several ride-hailing apps who had borrowed funds to buy their vehicles. While the loans allowed them to become drivers, they struggled to meet their basic needs before platform companies demanded their earnings for loan repayment. A new tactic many drivers deployed was limiting the money they kept in their wallets and requesting that riders pay in cash. This approach helped them cover basic living costs and fuel expenses so they could work. Prioritizing loan repayment over basic earnings for living undermined the drivers’ trust in the platform companies where they worked. During the pandemic, researchers in Brazil found that scammers had deceived a highly vulnerable group of people — beneficiaries of government cash transfer programs — by creating fake apps mimicking the government’s government-to-person (G2P) program on the Play Store. By confusing recipients, scammers could gain access to people’s identity data because the individuals believed they were registering for the G2P program. Not only did beneficiaries lose access to their government transfers, but they also became vulnerable to abuse of their data, potentially harming their ability to benefit from other government initiatives in the future.
<h1>Growing Distrust in Financial Services Industry</h1>
Stories of fraud, a lack of recourse, and irresponsible practices abound. Therefore, it’s no surprise that there is growing distrust of financial institutions across developed and developing markets — a fact echoed in a global report by Edelman. For example, since 2019, Colombia experienced a 10 percent decline in trust in the financial services sector.

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While the digital economy increasingly allows more people to participate in the financial system, it’s also enabling fraudsters to find new and innovative ways to take advantage of people who cannot keep up with the fine print and loopholes typically found in product user agreements. These scammers are modern-day charlatans preying on people’s vulnerabilities. Regulators and supervisors, meanwhile, are struggling to keep up with the rapid changes and protect the financial system from scams and irresponsible practices. Which risks should regulators prioritize? How can they keep up with the harm that consumers experience daily?
<h1>Let’s Stop the Cycle of Insanity and Think Afresh</h1>
Breaking out of the cycle of insanity means that the inclusive finance sector must do things differently. Sessions at the upcoming <a href="https://globalrff.org/december-2022" target="_blank" rel="noopener noreferrer">Responsible Finance Forum (RFF</a>) will assess the sector’s achievements over the last decade and determine where to refocus our collective efforts. RFF has undergone a transformation process, broadening the stakeholders around the table and the scope of responsible finance to address all emerging risks that low-income people face. Partners have spent the past year identifying concrete solutions to old and new risks. <a href="https://www.betterthancash.org/" target="_blank" rel="noopener noreferrer">BTCA</a>, <a href="https://www.cgap.org/" target="_blank" rel="noopener noreferrer">CGAP,</a> and <a href="https://www.centerforfinancialinclusion.org/responsible-social-protection-lessons-from-covid-19-digital-cash-transfers">CFI</a> have been leading working groups on responsible recourse, responsible digital credit, and responsible AI, respectively. They will reveal their findings and discuss their insights at the RFF 2023 convening in July. The three-day event will also dedicate time to home in on two emerging risks that demand greater attention: cybercrimes and climate risks.

What more can we do to remove responsible finance from the cycle of insanity? We need to consider the incentives that guide provider behavior and our roles in unleashing harm or enabling responsible practices. Here are a few of my thoughts on how we can improve ecosystem incentives.
<h3>Donors who fund innovation must balance funding for risk monitoring and supervision.</h3>
For every dollar spent on innovative tech solutions, donors should put in equal funding to support regulatory and supervisory capacity, develop market conduct tools, and implement consumer research to better understand and help mitigate potential harms.
<h3>Consumer protection by design.</h3>
Ensuring companies use data responsibly, disclosures that customers can understand, and interfaces that help customers make informed decisions -- these are not afterthoughts. Organizations should not provide funding for innovation without attention to consumer protection and responsible data practices in the design process.
<h3>Scaling and strengthening consumer advocacy organizations.</h3>
Consumers have so little power and so little voice. Governments and donors must help rebalance the scale by empowering consumer advocacy organizations. While this is a long-term investment, it is nonetheless essential.

RFF convenes July 5-7, 2023 in Bengaluru, India, under the theme of Shaping a Responsible Digital Finance Ecosystem. Visit the <a href="https://globalrff.org/july-2023" target="_blank" rel="noopener noreferrer">RFF website</a> to view the full agenda.

Ending the Cycle of Insanity: Responsible Finance in the Digital Age

It was a scorching hot February afternoon in Sempegua village in Colombia’s Zapatosa Marsh. Merciless rays of sunshine beat down as temperatures soared to 100 degrees Fahrenheit (38 degrees Celsius). Tired, skinny cows with ribs and hipbones jutting out foraged the dry pastures in search of feed. A group of cattle ranchers took a respite from the sweltering heat and sipped juice made from uvita de playa, a local Caribbean fruit, under the shade of a tree while recounting the good times when there was plenty for everyone. “Things are much worse than what they were 30 years ago. The government does not care. We are barely surviving, and on some days, we have no hope. All we have is the community for support,” said a cattle rancher.
<blockquote class="pullquote--left">A group of cattle ranchers took a respite from the sweltering heat and sipped juice made from uvita de playa under the shade of a tree while recounting the good times when there was plenty for everyone.</blockquote>
The men and women from the villages of Sempegua and La Mata in the Magdalena floodplains of Colombia -- <a href="https://www.dw.com/en/in-colombia-locals-fight-to-save-a-unique-disappearing-habitat/a-47300190" target="_blank" rel="noopener noreferrer">home to 32.5 million people</a> -- shared their experiences with me during a visit earlier this year. The Center for Financial Inclusion (CFI), along with <a href="https://www.nature.org/en-us/" target="_blank" rel="noopener noreferrer">The Nature Conservancy</a> and Accion, visited the Magdalena floodplains to understand how financial services can help community members manage the impact of climate change. CFI’s Green Inclusive Finance research team is working with climate NGOs and financial service providers in Colombia to uncover evidence and test promising solutions that help communities in the Magdalena floodplains develop resilience and adapt to climate change.

Livelihoods in this region are precarious, and the villages are wracked by climate shocks all year round. Summers are dry with long heat spells. Water levels recede, and there are fewer fish, a primary source of food. Community members must rise earlier and venture deeper into the wetlands to fish. The pastures become dry, leaving very little for cattle to forage on, and many ranchers are forced to sell their animals to survive. And when it rains, the Magdalena River overflows and inundates the villages, causing enormous damage to life, livestock, and livelihoods. The devastating floods caused by <a href="https://www.nature.org/en-us/about-us/where-we-work/latin-america/colombia/stories-in-colombia/climate-change-adaptation-for-communities-in-the-wetlands-of-the/" target="_blank" rel="noopener noreferrer">La Niña</a> in 2010 and 2011, impacting over 2.2 million households, are a case in point. According to <a href="https://www.strausscenter.org/wp-content/uploads/Country-Brief-Fragility-and-Climate-Risks-in-Colombia-2019.pdf" target="_blank" rel="noopener noreferrer">USAID</a> estimates, in the years between 2000 and 2016, Colombia experienced at least 56 climate-related disasters, including devastating floods.
<h1>Diversifying Livelihoods</h1>
Given the fragility of the traditional occupations of fishing and cattle ranching, community members have had to diversify their livelihoods by collecting local fruits, managing nurseries and community gardens, and selling local snacks and alcohol. Nearly everyone we spoke to was engaged in fishing, but it was no longer the preferred livelihood choice, given the rising expenses and the risk of being attacked by stingrays or crocodiles. Cattle ranching, the other traditional occupation, was also becoming more unpredictable. Ranchers mentioned having to sell livestock, challenges finding fertile lands for grazing, and conflict with an industrial farming operation, which was increasingly encroaching on the grounds where the cattle grazed.

But these means of supplementing their livelihoods are proving equally precarious. The forest where the fruits grow is replete with venomous snakes. Furthermore, the industrial farming operation owns much of the land, and the women picking fruits have no choice but to trespass. Despite the hardships, community members said they prefer living in the village where they can lean on one another for support. “Finding a well-paying job in cities is hard,” explained a man who had recently moved back from the city of Barranquilla. “We need land to do some productive activity, earn money, and pay off our debts.”

Several people said they have access to bank accounts but rarely use them beyond accessing conditional cash transfers via the government-run <a href="https://prosperidadsocial.gov.co/sgpp/transferencias/familias-en-accion/" target="_blank" rel="noopener noreferrer">Familias en Accion</a> program. The few salaried people used their accounts to receive their pay. We probed deeper to understand why existing financial systems do not work for the vulnerable and what needs to be changed.

Our discussions revealed three key areas where appropriately designed financial services could help:
<h1>1. Financial Services Must be Tailored to Needs</h1>
Several people we spoke with had taken loans from banks and microfinance institutions. However, the experience was often stressful. The loans had high interest rates, and when crops failed because of climate change, banks rarely provided flexibility on the loan terms. This rigidity made it difficult for farmers to meet their loan obligations, and they reported needing to leave their children behind in the village to work in the cities so they could repay their debts. According to them, financial institutions did not understand their predicament or provide any support to reduce the pressure. Consequently, many preferred the convenience and flexibility local moneylenders (gota gotas) offered, even though they were more dangerous and expensive. The gota gotas visited the villages daily and were willing to adjust the repayment schedule when customers with good repayment records faced challenges.
<blockquote class="pullquote--right">While community members desperately need financial services that allow them to save safely, conduct transactions, and access credit for their livelihoods, existing offerings do not meet their specific needs.</blockquote>
Despite their small and unpredictable incomes, community members said they dream of rebuilding or renovating their houses or sending their children to college, and they try saving whenever possible. However, most people prefer storing their money at home, despite the risks of floods or termite infestations that have destroyed their savings. Some women expressed a desire to learn more about saving in a more disciplined manner, and a community-based organization and partner of TNC called <a href="https://www.fundacionalma.org/" target="_blank" rel="noopener noreferrer">Fundacion Alma</a> responded by helping these women form their own savings group.

While community members were familiar with mobile money, not everyone owned mobile phones, and household members often shared phones. Even when they had phones, remembering passwords was a challenge. Furthermore, they frequently changed SIM cards to take advantage of promotions and offers from mobile companies, which required them to open new mobile money accounts. When they needed to withdraw or send money, they would travel to the nearest town and rely on an agent – who required a fee -- to facilitate transactions.

These anecdotes illustrate that while community members desperately need financial services that allow them to save safely, conduct transactions, and access credit for their livelihoods, existing offerings do not meet their specific needs.

Financial services could help residents of the Zapatosa Marsh transition to more climate-resilient livelihoods if the financial service providers were to adapt their offerings to better meet the needs and vulnerabilities of the communities, as CFI has outlined in its <a href="https://www.centerforfinancialinclusion.org/research/financial-services-to-mitigate-and-adapt-to-climate-risks">Green Inclusive Finance taxonomy</a>. The taxonomy lays out the various impact pathways through which financial services can help: mitigation, resilience, adaptation, and transition.
<h1>2. Financial Services and Skills-Building Can Multiply Impact</h1>
Even when community members had access to financial services, they had a minimal understanding of the features and terms associated with a product. For example, one woman mistakenly assumed that the credit life insurance covering her loan in the event of death would also cover loan defaults. Consequently, she was very disappointed when it did not help cover late payments related to the credit she used to buy her boat.

Most community members were skeptical about the utility of financial capability-building programs and felt these initiatives would have limited relevance given their volatile incomes. One exception was a salaried teacher who mentioned attending a financial education program offered by a bank that helped him learn how to budget and save money. However, community members were eager to participate in training that would equip them with skills to provide value-added services, such as making fruit juice or wine and accessing new markets.

While most people were familiar with WhatsApp and Facebook, they remained cautious about digital apps and preferred in-person programs where they would have opportunities to ask questions. By offering digital and financial education and supporting community members to start small businesses and access markets, there is a more significant opportunity to strengthen resilience and improve livelihood outcomes.
<h1>3. Consumer Protection is a Priority</h1>
“My husband and I took a home improvement loan. Since our earnings from fishing and collecting uvita de playa were insufficient, I moved to Valledupar and worked as a maid for a year to pay off the loan. But even after all our efforts, the loan still appears as red [unpaid] on the [credit] bureau,” explained one woman. Another person reported having a credit bureau record for a loan he never applied for or received. Others reported instances where they had to pay additional installments or fees or were victims of identity theft.

When asked about available recourse channels, most community members said it cost them too much time and money to travel to the bank in the city to sort out these problems, so they left them unresolved. Instead, they relied on gota gotas when they needed credit.

As weather patterns change, consumers face risks from newer sources that impact their financial lives at any stage of their interaction with financial services. <a href="https://www.centerforfinancialinclusion.org/research/consumer-protection">Consumer protection</a> is integral to building customer trust and is a cornerstone of a stable financial system.
<blockquote>Systemic changes are needed for financial services to support low-income, vulnerable communities in preparing for, responding to, and recovering from climate shocks while protecting them from additional harm.</blockquote>
Our visit to the Zapatosa Marsh exemplifies the area’s high vulnerability to climate change, which is already forcing the community to seek new livelihoods. These changes will only become more acute. Droughts and extreme floods in the region are expected to <a href="https://www.climatechangenews.com/2021/12/30/colombian-fishers-fighting-rights-protection-vital-wetlands/" target="_blank" rel="noopener noreferrer">intensify</a>. Entire villages risk being eliminated should there be <a href="https://www.reuters.com/business/environment/us-forecaster-says-el-nino-could-arrive-by-summer-2023-2023-03-09/#:~:text=March%209%20(Reuters)%20%2D%20La,and%20persisting%20through%20the%20fall." target="_blank" rel="noopener noreferrer">another El Niño</a>, which weather forecasters predict this year. With annual temperatures projected to rise by 1-1.5 degrees and precipitation to increase by <a href="http://documentacion.ideam.gov.co/openbiblio/bvirtual/019711/preliminares.pdf" target="_blank" rel="noopener noreferrer">5-15% by 2040</a>, the climate crisis is becoming increasingly real and urgent. Systemic changes are needed to enable the financial services sector to support low-income, vulnerable communities in preparing for, responding to, and recovering from climate shocks while protecting them from additional harm.

Acknowledging the urgent requirement for contextually relevant and responsible financial services in communities like the Zapatosa Marsh is vital. This situation provides a significant opportunity for organizations specializing in climate and inclusive finance to collaborate, acquire evidence, and test solutions to safeguard vulnerable communities from unintended adverse effects.

Colombian Wetlands Hard Hit by Climate Shocks - What Role for Financial Services?

A decade ago, <a href="https://www.cgap.org/topics/collections/digital-credit" target="_blank" rel="noopener noreferrer">digital credit models</a> that catered to low-income consumers were relatively unknown and untested. A lot has changed since then. Data from the <a href="https://ccaf.io/" target="_blank" rel="noopener noreferrer">Cambridge Center for Alternative Finance</a> shows that between 2011 and 2021, the number of digital lenders -- including those catering to low-income consumers -- has grown nearly ten-fold globally. <a href="https://www.imf.org/en/Publications/WP/Issues/2021/03/19/Digital-Financial-Inclusion-in-Emerging-and-Developing-Economies-A-New-Index-50271" target="_blank" rel="noopener noreferrer">Economies in Africa and Asia</a> have significantly driven this growth within the emerging market context. This rapid growth has been accompanied by a rise in consumer protection challenges, which have been studied and <a href="https://www.cgap.org/topics/collections/digital-credit" target="_blank" rel="noopener noreferrer">reported extensively in the East African context</a>.  

Catalytic capital — debt, equity, guarantee, or other instruments that assume disproportionate risk to return — is often seen as an important signaling device to attract further, timely investment in the target. As such, it can facilitate innovation and help organizations and companies build a track record in underserved markets. 
<blockquote class="pullquote--right">Catalytic capital has spurred rapid growth in digital credit, but at the same time, digital credit has created significant concerns over consumer protection.</blockquote>
However, the role of catalytic capital in influencing market-level incentives for digital credit has been less studied. In multiple markets, catalytic capital has spurred rapid growth in digital credit, resulting in an influx of investment. At the same time, digital credit has created significant concerns over consumer protection, and the supervisory capacity of local regulators has failed to keep pace with the risks emerging from the rapid growth of digital credit.  

In our research, we focus on the role of catalytic capital in shaping market incentives as they attract capital to digital credit models. We conclude that the role played by catalytic capital differs depending on the stage of market development. At an early stage, catalytic capital investments can help prove business models, expand services to newer consumer segments, and/or attract capital to underserved geographies. As the supply of capital increases, markets shift to a growth stage. Catalytic capital investors, who are more impact-oriented, need to shift their roles as markets grow to one that addresses consumer risks that accompany an increased supply of capital.  
<h1>A helpful case study: Kenya -- the birthplace of digital credit  </h1>
Our research traces the role played by catalytic capital investments, mapping consumer risks that evolved to missed signals that catalytic capital investors could have used to build guardrails. We hope other markets on a similar growth path as Kenya can use this guidance. 

Consumer risks rising from digital credit can be influenced through investor incentives, and they fall into three broad categories: 
<h3>High interest rates, indebtedness, and default risks</h3>
Financial service providers often cite the high cost of funds in emerging markets as the underlying driver for high interest rates. Catalytic capital investors can play a crucial role in reducing the cost of funds by deepening domestic capital markets. As one positive example, Lendable and other funders, including FSD Africa, set up a fund offering a first-loss default guarantee. This structure mobilizes domestic debt investors, increases transparency, and reduces the cost of funds for end borrowers as the supply of on-lending funds in emerging markets becomes less constrained. 
<h3>Aggressive sales practices, exploitative terms and conditions, and deceptive fees</h3>
As investments in digital credit models rise, there is a need to establish responsible market practices. Catalytic capital providers can play a role in working with industry associations and regulators to establish responsible market practices, and advocacy is one of the most powerful tools they can use. For example, community Investment Management (CIM) is an institutional impact manager that began operations in mature markets and is now expanding to emerging markets. CIM co-founded <a href="http://www.borrowersbillofrights.org/bill-of-rights.html" target="_blank" rel="noopener noreferrer">the Small Business Borrowers’ Bill of Rights</a>, identifying six fundamental financing rights of all businesses. The Small Business Borrowers’ Bill of Rights has now been adopted by the <a href="https://www.aspeninstitute.org/programs/business-ownership-initiative/small-business-borrowers-bill-rights/#:~:text=The%20Small%20Business%20Borrowers%E2%80%99%20Bill%20of%20Rights%20identifies,in%20order%20to%20uphold%20and%20protect%20those%20rights." target="_blank" rel="noopener noreferrer">Responsible Business Lending Coalition,</a> a network of for-profit and non-profit lenders, brokers, and small business advocates. 
<h3>Data privacy issues</h3>
With the emergence of technology-driven business models, using data to innovate is a crucial part of the DNA of digital financial services. Catalytic capital providers have a role in ensuring that companies respect data privacy without constraining innovation. 
<h1>Complementing catalytic capital investments for responsible market development </h1>
While catalytic capital is crucial for innovations and expanding access, not everything is attributable to catalytic capital investors. While catalytic capital may enable market development, as the case of digital credit demonstrates, responsible market development does not automatically follow. Several other factors must be supported to complement investor incentives for responsible market development. Responsible market development needs investments beyond the firm level to enable market information, consumer awareness and capability, regulatory and supervisory capacity, and various other measures that can serve as checks and balances on firm behavior.  

While investors can conduct firm-level due diligence to ensure client protection principles are respected, two of the three legs of the consumer protection stool require grant funding: regulation/supervision and building consumer awareness. Market actors need access to timely information and market research that informs them about potential market risks and which consumer segments might be particularly vulnerable. In addition, market conduct supervision that facilitates consumer protection needs investment that allows actors to test and invest in new tools that can capture consumer risks as they evolve. Therefore, traditional grant funding is needed to support responsible market development along with catalytic capital investments. 

As a complement to catalytic capital investments, our research highlights six key lessons that can help support responsible market development: 
<h3>1. Recognize market growth indicators.</h3>
This requires infrastructure investments that can contribute to responsible market development. Catalytic capital investors face four strategic decisions that will shift their role as the market develops: when to exit an investment, who would replace them, how will the investee company continue responsible behavior post-exit, and how to balance financial and social returns at the time of exit. Answers to these questions require agreement on a common set of indicators for market growth. 
<h3>2. Support initiatives that can help source market-level data.</h3>
Surveys that provide information on trends in funding and areas of concentration are crucial to support funding decisions for underserved areas. We need investments in sector-level evidence gap maps and systematic data on the volume of investments made in digital credit by funders and instruments.  
<h3>3. Design Digital Public Infrastructure (DPI) that respects users’ privacy and security.</h3>
This will have a cascading effect on newer business models because those using digital rails tend to build on existing infrastructure. Responsible market development can result from investing in the inclusive design of public infrastructure, respecting users’ privacy and security, and supporting regulations that ensure accountability. 
<h3>4. Invest in industry associations and networks to complement regulatory capacity.</h3>
Industry associations and networks can play the role of effective shadow regulators, often with the ability to monitor and identify emerging risks with market development. However, building this ecosystem requires investments beyond catalytic capital. 
<h3>5. Build regulatory/supervisory capacity.</h3>
Expanding new models requires testing tools that can detect new risks and initiatives that can bring together regulators to learn from “sister” networks in other markets. These initiatives can help augment the capabilities of market conduct supervisors but require traditional grant funding.  
<h3>6. Invest in mechanisms enabling consumer awareness.</h3>
Consumer awareness is crucial to reinforce consumer protection, but extant investment instruments may lack the incentives to support such initiatives. 

The detailed report can be accessed <a href="https://www.centerforfinancialinclusion.org/the-role-of-catalytic-capital-in-digital-markets-successes-pitfalls-and-lessons-learned">here</a>, and a discussion on the role of catalytic capital in digital credit at Financial Inclusion Week can be <a href="https://www.youtube.com/watch?v=7y8x44tLk2I&amp;list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY&amp;index=5&amp;t=5s" target="_blank" rel="noopener noreferrer">accessed here.</a>

Catalytic Capital and Its Role in Digital Credit

Jayshree Venkatesan

Senior Research Director

Alexandra (Alex) Rizzi

Dr. Maritza Johnson

Swati Mehta

Mayada El-Zoghbi

Joanna Ledgerwood

Lucciana Alvarez Ruiz

Nina Liew

Nikita Chettri

Evelina Durlind

Leonie Rauls

Ulayya Gempur Tirani

Marina Santos Piacente

Anindita Chakraborty

Diana Boncheva-Gooley

Veronica Karpoich

Dunja Latinovic

India

South Asia

Colombia

Latin America and The Caribbean

Kenya

Sub-Saharan Africa

Guatemala

Data Privacy

Fintechs

Responsible Product Design and Delivery

Access Usage Gap

Digital Payments

Women

Consumer Protection

Responsible Digital Finance

Alternative Data

Enabling Environment

Small Business Owners

Underserved Groups

Digital Financial Services

Financial Capability

Financial Health

Resilience

Credit

Data Transparency

Impact Investing

Fintech

Fraud

Mobile Banking

Insurance

Risk Management

Blockchain

Challenges and Crises

Toolkits and Guides

Blog Post

Report

India is a global leader in financial inclusion. For over a decade, Accion has worked with and learned from India’s innovators, investors, and policymakers to expand economic opportunity for its people and businesses.

The majority of Kenyans have mobile money accounts; their activity demonstrates digital financial services’ potential. Accion helps Kenyan innovators harness emerging technologies to create new financial services.

<h3>“My husband wanted to start a small business but he could not get a big enough loan from the cooperative and did not qualify for a bank loan. The coyote, however, had no problem giving him a large loan to take him to America. My husband sends me money every month and I take the cash to the coyote to repay the loan.”</h3>
<h4 style="text-align: right;">– Anonymous woman from Santa Apolonia, Guatemala</h4>
Immigration to the United States from Guatemala is motivated by a myriad of factors, including rising rates of local violence and climate-change induced impacts on agriculture, but the main accelerant is extreme poverty without prospects for economic mobility. Guatemalans view the enormous potential for economic opportunity abroad as a pull factor, especially in contrast to the limited financial prospects that they face at home. This presents the financial sector in Guatemala with both the opportunity and imperative to support Guatemalans hoping to build and maintain wealth in their home country. This blog shares how the <a href="https://www.usaid.gov/" target="_blank" rel="noopener noreferrer">United States Agency for International Development (USAID)</a> is helping deepen financial access and usage among low-income and marginalized Guatemalans to create more economic opportunities within their communities.

Guatemala has the largest economy in Central America, an achievement fueled primarily by agricultural production, as the nation produces and exports some of the highest quality coffee and spices in the world. Guatemala also has rich cultural diversity, with a <a href="https://www.macrotrends.net/countries/GTM/guatemala/population" target="_blank" rel="noopener noreferrer">population of over 18 million</a>, over 40 percent of whom identify as one of the country’s more than 20 <a href="https://www.pionerophilanthropy.org/guatemalas-indigenous-community-a-struggle-against-poverty-racism-and-exclusion/" target="_blank" rel="noopener noreferrer">Indigenous communities</a>.
<blockquote class="pullquote--right">The financial sector in Guatemala has the opportunity and imperative to support Guatemalans hoping to build and maintain wealth in their home country.</blockquote>
Despite its rich culture and economic standing in the region, Guatemala has high social inequity, including a <a href="https://www.worldbank.org/en/country/guatemala/overview" target="_blank" rel="noopener noreferrer">poverty rate of 52.4 percent</a>, which has been further exacerbated by factors such as climate change and COVID-19-induced economic shocks. The country’s economy benefits from significant remittance inflows—which make up <a href="https://country.eiu.com/article.aspx?articleid=221764805&amp;Country=Guatemala&amp;topic=Economy&amp;subtopic=Forecast&amp;subsubtopic=Economic+growth" target="_blank" rel="noopener noreferrer">18 percent of the country’s GDP</a>—but this has yet to translate into significant reductions in poverty. In terms of financial access, according to the <a href="https://www.worldbank.org/en/publication/globalfindex" target="_blank" rel="noopener noreferrer">latest Findex Data from 2022</a>, only 35 percent of adults have access to formal bank accounts, down nine percent from 2017 when 44 percent of adults had an account. The gender gap is six percent: 34 percent of women had an account in 2022 versus 40 percent of men, a one percent increase in the gender gap from 2017 when it was five percent. Many do not rely on formal lending sources, with only 11 percent of adults borrowing from a financial institution last year. The Center for Financial Inclusion wrote about<a href="https://www.centerforfinancialinclusion.org/rural-poor-and-pressured-by-climate-change-migration-and-financial-inclusion-in-guatemalas-western-highlands"> the potential for financial services to support rural opportunities in Guatemala</a>.

To break the poverty cycle in Guatemala, low-income families need access to financial services that will build and protect their wealth, enabling them to be more resilient in the face of climate-induced economic shocks and other unanticipated crises. Presently, low-income earners primarily interact with formal financial service providers, including banks, in an over-the-counter (OTC) manner, to cash out remittances without accessing the full suite of benefits that digital financial services can offer such as lower costs, higher speed, and security, as well as building a credit history to access loans.

As smartphone ownership rises in countries around the world, digital financial services (DFS) are a more efficient way to support low-income earners in wealth creation and management by offering convenience, cost savings, economic security, and broad accessibility—and removing the need to go to a physical bank or financial institution. Unfortunately, these service offerings are nascent in Guatemala—and even more so in the country’s rural areas. For example, according to the latest Findex, just 26 percent of adults made or received a digital payment in the last year—a low rate even in comparison to neighboring countries such as El Salvador (28%) and Honduras (32%). While DFS are gaining traction in Guatemala, more work needs to be done to make them accessible, practical, and useful to a broader consumer group.
<blockquote>While DFS are gaining traction in Guatemala, more work needs to be done to make them accessible, practical, and useful to a broader consumer group.</blockquote>
In partnership with DAI’s Digital Frontiers and ConsumerCentrix, USAID recently conducted qualitative customer market research to offer the Guatemalan financial sector concrete recommendations on how it might leverage DFS to positively impact the financial security of low-income and marginalized populations in Guatemala. This research, conducted with 112 participants in Guatemala City, Quiché, and Chimaltenango, identified clear segments and sustainable commercial potential, debunking common misunderstandings about the needs and demands of financially underserved Guatemalans. 

Here are a few key findings: 
<h2>While low-income communities are among the clientele of established providers, banks tend not to treat these communities as strategically critical customer segments deserving of tailored services.</h2>
Most banks mainly offer OTC services to low-income populations, failing to transition these customers to full account holders. The few banks that dominate the financial sector provide bank accounts to only four million people out of the country’s over 18 million population. They offer banking OTC to about five million remittance receivers and one million government-to-person (G2P) and humanitarian aid recipients. Tigo Money, the mobile money provider, offers OTC services to about 700,000 people. The main financial account providers are rural cooperatives, which have about three million clients, and microfinance institutions, which serve about half a million primarily urban clients. 
<h2>A widely-held assumption among financial institutions—that low confidence and limited education are the main barriers to access and use among low-income individuals—is not backed by evidence.</h2>
Providers name literacy, confidence, and aversion to formal financial services as the primary reasons why low-income earners are not formally banked. Yet this study demonstrated that poor customer service, including non-transparent banking fees, which is closely related to low trust in the financial sector, is a major issue alongside stringent requirements for accessing credit—a need among those looking to build a better future for themselves. 
<h2>Latent demand for formal finance exists, and there is awareness of and openness to using digital channels for financial transactions.</h2>
Research participants across all age groups and localities have smartphones and sufficient network connectivity to access DFS. Research found that digital financial literacy is present, particularly among younger segments, and that these segments can and are willing to support their older relatives in using technology. While concerns exist around protecting their security and making mistakes online, there is a shared understanding among participants that DFS is the future, and they are open to using DFS where it can save time and money. Most existing users have prior experiences with bank and cooperative mobile banking applications, generally as complementary to an account. There is little to no awareness of other DFS solutions or even how mobile banking applications could be used more broadly—representing a real opportunity for the financial sector.
<blockquote class="pullquote--left">There is little to no awareness of other DFS solutions or even how mobile banking applications could be used more broadly—representing a real opportunity for the financial sector.</blockquote>
Considering the nascent status of digital finance in Guatemala, financial service providers can start by tailoring products to the most viable segments to first create a critical mass before reaching out to those most in need: the lowest income and most rural consumers. Using criteria around population size, aggregation potential, income regularity, and digital readiness, the research identified two consumer segments with the strongest opportunities for DFS with the most potential use cases, regular income flows, and capacity for aggregation: 1) domestic remittance senders (such as domestic workers) and their recipients, and 2) international remittance recipients. 

Research showed opportunities in digitizing domestic remittance transfers and receipt of international remittances to an account that can be used for a broader set of financial needs including utility payments, savings, and credit facilities based on remittance flows to be used for a microbusiness or household needs. 

Low-income and vulnerable Guatemalans need financial products that help them manage their variable cash flows and to manage risks, including those arising from climate change, and to help them access more economic opportunities. Prototype testing of a potential solution is underway, and the team will produce a full Digital Financial Services Market Assessment Report that outlines these DFS opportunities in greater detail. Stay tuned for the full report—expected in spring 2023.

Letting the Consumer Speak: The Reality of Access to Finance in Guatemala

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Over the last ten years, catalytic capital — investment capital that is patient, risk-tolerant, concessionary, and adaptable — has played an increasingly important role in filling the gaps left by the rapidly expanding and diversifying field of impact investing and serves to attract more conventional investors to sectors with high development potential. While we do not know the volume of catalytic capital investments in inclusive finance, we know that investments in inclusive finance continue to be a top category of growth.

</div>
This report focuses on the role of catalytic capital in the digital credit industry and highlights the limitations of a framework that does not consider broader market-level consequences of such investments. The rapid growth of digital credit has resulted in an influx of investment but also created significant concerns over consumer protection, and the supervisory capacity of local regulators has failed to keep pace with the risks. The report draws lessons from how digital credit markets have evolved and highlights guardrails needed at the market level to ensure that growth is responsible, impactful, and leads to inclusive market development.

</div>
</div>

The Role of Catalytic Capital in Digital Markets: Successes, Pitfalls, and Lessons Learned

In 2022, advances in artificial intelligence captured our collective imaginations in unprecedented ways. Whether it was the artistic text-to-image renderings of <a href="https://openai.com/dall-e-2/" target="_blank" rel="noopener noreferrer">Dall-E2</a> shown in this blog post or in-depth conversations with <a href="https://openai.com/blog/chatgpt/" target="_blank" rel="noopener noreferrer">ChatGPT</a>, the implications of data advances in analysis, prediction, and generation became clearer than ever to the “non-techy” public. Last year, governments around the world raced to stay on top of data advances through various data governance approaches, such as <a href="https://www.dlapiperdataprotection.com/" target="_blank" rel="noopener noreferrer">data protection legislation</a>, or draft approaches to regulating AI including the <a href="https://www.whitehouse.gov/ostp/ai-bill-of-rights/" target="_blank" rel="noopener noreferrer">White House’s AI Bill of Rights</a> and the <a href="https://artificialintelligenceact.eu/" target="_blank" rel="noopener noreferrer">EU’s AI Act</a>. What has become very clear is that there is both tremendous excitement at the promise of these advances, as well as significant concern.

Several sessions at <a href="https://financialinclusionweek.org/" target="_blank" rel="noopener noreferrer">Financial Inclusion Week</a> (FIW) 2022 focused on data-driven advances in inclusive finance that grappled with the duality of exciting opportunity and concerning risk – particularly with regards to low-income and vulnerable consumers, like female-owned MSEs and migrants.
<h1>Data Opportunities</h1>
A few sessions shared how customer data is helping to shape product design for traditionally underserved consumers. The UN Capital Development Fund hosted a session on <a href="https://www.youtube.com/watch?v=g15noAC2vWU&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=5" target="_blank" rel="noopener noreferrer">Driving Women’s Financial Inclusion and Resilience</a>, with a focus on how consumer data, whether administrative or survey based, can drive innovative financial products for women. In this session, a speaker from <a href="https://imeremit.com.np/" target="_blank" rel="noopener noreferrer">IME Nepal</a> talked about how the company is leveraging remittance transaction data during COVID to better understand consumers and expand its digital offerings, including a wallet. UNCDF highlighted demand-side research that showed the challenges women face in onboarding to digital remittance services. My colleague <a href="https://www.centerforfinancialinclusion.org/bio/anindita-chakraborty">Anindita Chakraborty</a> contributed to the discussion with insights from CFI’s research on the difficulties <a href="https://www.centerforfinancialinclusion.org/research/covid-19-and-msmes-data-and-analysis-to-understand-impact">female-led MSEs</a> faced during the pandemic, and how that data should inform products to help MSEs be more resilient in future shocks.
<blockquote>Customer data is helping to shape product design for traditionally underserved consumers.</blockquote>
In addition to leveraging consumer data, looking at data on a larger scale can have significant benefits. In a <a href="https://www.youtube.com/watch?v=F0aZV-Zfzd0&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=5" target="_blank" rel="noopener noreferrer">short session by Principal Financial Group</a>, the Principal team shared the launch of the Global Financial Inclusion Index, a ranking of 42 markets based on what governments, financial systems, and businesses are doing to advance financial inclusion for their populations. This index aims to give investors insights into the strength and resilience of these markets.

Several fintechs and providers shared insights on their data-driven business models. A <a href="https://www.youtube.com/watch?v=WwecOBYOyi4&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=6" target="_blank" rel="noopener noreferrer">session</a> hosted by Korean fintech giant <a href="https://www.sentbe.com/" target="_blank" rel="noopener noreferrer">SentBe</a> presented how its cross-border money transfer services leverage data on traditionally underserved consumers – including migrants from Bangladesh and Cambodia working in Korea – to provide customer-centric receipt options. Senegalese fintech <a href="https://www.lebfay.com/" target="_blank" rel="noopener noreferrer">LebFay</a> presented <a href="https://www.youtube.com/watch?v=DA8wqNKl2f4&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=7" target="_blank" rel="noopener noreferrer">its business model</a> that uses an app and artificial intelligence-driven scoring model to lend to traditionally underserved MSEs and tradesmen. And, <a href="http://imbita.org/" target="_blank" rel="noopener noreferrer">Imbita Swaziland Women’s Finance Trust</a> spoke about the digitalization journey in offering its savings and credit cooperative society (SACCO) members a USSD-based platform to save, borrow, and make mobile payments.
<h1>Data Risks</h1>
<blockquote class="pullquote--right">Challenges, including privacy, bias, and other human rights issues, can stem from the exponential growth of digital lending.</blockquote>
At the same time, several sessions highlighted the risks around data-driven innovation and what inclusive finance stakeholders need to do about it. <a href="https://aapti.in/" target="_blank" rel="noopener noreferrer">Aapti Institute</a>, an India-based think-tank that conducts research at the intersection of technology and digital rights, hosted a session <a href="https://www.youtube.com/watch?v=lXLY7BsG_fg&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=3" target="_blank" rel="noopener noreferrer">on AI and Financial Inclusion</a>, discussing risks and opportunities for risk mitigation with representatives from <a href="https://www.dvara.com/research/" target="_blank" rel="noopener noreferrer">Dvara</a>, <a href="https://rbihub.in/" target="_blank" rel="noopener noreferrer">RBI Innovation Hub</a>, and <a href="https://www.undp.org/india" target="_blank" rel="noopener noreferrer">UNDP</a>. This session raised challenges, including privacy, bias, and other human rights issues, that could stem from the exponential growth of <a href="https://www.centerforfinancialinclusion.org/digital-credit-algorithms-in-india-expanding-access-or-cementing-exclusion">digital lending in India</a>. I was honored to moderate a session on the <a href="https://www.youtube.com/watch?v=J0QaPM6sDDk&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=2" target="_blank" rel="noopener noreferrer">Potential of Privacy by Design for Inclusive Finance</a> with inputs from <a href="https://www.paypal.com/us/home" target="_blank" rel="noopener noreferrer">PayPal</a>, <a href="https://foundation.mozilla.org/en/" target="_blank" rel="noopener noreferrer">Mozilla Foundation</a>, and the <a href="https://www.dlak.co.ke/" target="_blank" rel="noopener noreferrer">Digital Financial Services Association of Kenya</a>. Representatives from PayPal and Mozilla discussed how Privacy by Design has been implemented in their business models, and Kevin Mutiso of DFSAK shared how startup fintechs can integrate and benefit from strong privacy practices.
<h1>Looking Ahead</h1>
As we look ahead to 2023, CFI will be monitoring how advances in AI are integrated into the inclusive finance space. Will there be chatbots or financial capability curricula that use ChatGPT? We’ll also be watching for countries to codify the use of AI and enforce data protection legislation. With so much happening in this space at the moment, there is a lot to pay attention to as we continue to grapple with the duality of data opportunities and risks.

View the full <a href="https://www.youtube.com/playlist?list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb" target="_blank" rel="noopener noreferrer">Data Risks &amp; Opportunities</a> Playlist from FIW 2022.

Financial Inclusion Week 2022 had over 3,300 registered participants from 2,000 organizations across 148 countries. With almost 400 speakers and 125 sessions, FIW 2022 was the largest event to date. All sessions from FIW 2022 can be viewed here.

And be sure to save the date for FIW 2023 which will take place October 16-19, 2023.

FIW Recap: Grappling with Data Opportunities and Risks in Inclusive Finance

Each year, World Consumer Rights Day is celebrated on March 15 as a means of raising global awareness about consumer rights and needs. To join in spreading the awareness, this post outlines current risks and opportunities emerging in the field of consumer protection.

By October 2022, when <a href="https://financialinclusionweek.org/" target="_blank" rel="noopener noreferrer">Financial Inclusion Week</a> (FIW) was held, the world was beginning to emerge from more than two years of pandemic lockdowns and accelerated digitalization. The Global Findex 2021 showed that the share of adults in developing economies making or receiving digital payments <a href="https://www.worldbank.org/en/publication/globalfindex" target="_blank" rel="noopener noreferrer">grew from 35 percent in 2014 to 57 percent in 2021</a>, with over one-third of adults paying their utility bills digitally for the first time during COVID. In addition, growth in digital lending <a href="https://www.jbs.cam.ac.uk/wp-content/uploads/2021/03/2020-ccaf-global-covid-fintech-market-rapid-assessment-study-v2.pdf" target="_blank" rel="noopener noreferrer">dropped by 8 percent</a> in the first two quarters of 2020 but showed a <a href="https://openknowledge.worldbank.org/bitstream/handle/10986/36883/9781464817304_Ch04.pdf" target="_blank" rel="noopener noreferrer">strong recovery when lockdowns eased</a>.

While these numbers reveal opportunities to use digital financial services to drive financial inclusion, there is also evidence of rising risks that can increase vulnerabilities among newly included consumers. CGAP’s research found that the frequency, breadth, and complexity of risks <a href="https://www.cgap.org/research/reading-deck/evolution-of-nature-and-scale-of-dfs-consumer-risks-review-of-evidence" target="_blank" rel="noopener noreferrer">have increased since 2017</a>. The <a href="https://finaccess.knbs.or.ke/reports-and-datasets" target="_blank" rel="noopener noreferrer">2021 FinAccess Survey</a> found that 47 percent of Kenyans using mobile money have lost funds, a sharp increase from the 8 percent who had cited the same problem in 2019. Digitalization has rapidly increased identity theft, fraud, and mobile money scams.

The impact of these risks is not experienced uniformly by all consumer segments. This indicates that our approach to consumer protection needs a more nuanced, segmented approach to address vulnerabilities. Data from the United Nation’s 2022 <a href="https://www.unwomen.org/sites/default/files/2022-09/Progress-on-the-sustainable-development-goals-the-gender-snapshot-2022-en_0.pdf" target="_blank" rel="noopener noreferrer">Progress on the Sustainable Development Goals</a> report is not encouraging. According to the report, it will take us approximately 300 years to address discriminatory laws and close prevailing gaps in legal protection for women. In addition to issues of fraud and financial losses that all consumers experience, women are also subject to greater harassment due to breaches of privacy and online harassment.
<h1>Consumer Protection was a Clear Focal Point at FIW 2022</h1>
This rise in consumer risks has not gone unnoticed by the inclusive finance community. The urgency to address these risks, particularly before consumer trust in digital financial services is eroded, was a leitmotif across many of the sessions at Financial Inclusion Week 2022. For example, in <a href="https://www.youtube.com/watch?v=J0QaPM6sDDk&amp;list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY&amp;index=1&amp;t=11s" target="_blank" rel="noopener noreferrer">CFI’s global plenary</a>, we discussed the need to embed privacy into the design and delivery of financial services, and expert panelists highlighted international examples to illustrate how this might be done.
<blockquote class="pullquote--right">The urgency to address these risks, particularly before consumer trust in digital financial services is eroded, was a leitmotif across many of the sessions at Financial Inclusion Week 2022.</blockquote>
Digitalization tends to exacerbate existing risks and introduces new risks that must also be detected and addressed. Standards such as the <a href="https://www.ada-microfinance.org/en/toolbox/social-and-environmental-performance#:~:text=The%20Universal%20Standards%20for%20Social%20and%20Environmental%20Performance,Universal%20Standards%20take%20into%20account%20seven%20fundamental%20dimensions%3A" target="_blank" rel="noopener noreferrer">Universal Standards for Social and Environmental Performance Management</a>, SPTF’s <a href="https://cerise-sptf.org/digital-financial-services/" target="_blank" rel="noopener noreferrer">Standards for Responsible Digital Financial Services</a>, and others emerged as important tools to address existing risks. In a session <a href="https://www.youtube.com/watch?v=CJ9_P7bGOvA&amp;list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY&amp;index=4&amp;t=2540s" target="_blank" rel="noopener noreferrer">hosted by SPTF</a>, there was agreement among discussants that standards provide a guideline for best practices for known risks. However, these guidelines may need to be adapted to specific contexts and may not reflect emerging risks or be sufficient to address them.

A <a href="https://www.youtube.com/watch?v=kYmfrSk094w&amp;list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY&amp;index=3&amp;t=8s" target="_blank" rel="noopener noreferrer">session by Incofin</a> highlighted investors as an important stakeholder group to enforce best practices through due diligence and monitoring. And in <a href="https://www.youtube.com/watch?v=7y8x44tLk2I&amp;list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY&amp;index=6" target="_blank" rel="noopener noreferrer">CFI’s on-demand session</a>, we also spoke to investors about how they shape market-level incentives through advocacy and catalytic capital investments. Catalytic capital investors can spur lending in underdeveloped markets while extending a stamp of responsible lending to companies they invest in at an early stage.
<h1>The Way Forward</h1>
As technology increasingly affects inclusive financial services, consumer protection risks are beginning to arise from areas outside the remit of traditional financial sector regulation. In addition, consumers must face risks from newer sources, which impact their financial lives. These new sources of risk include climate shocks, changes in weather patterns, the evolving nature of work, and factors like changing societal structures and norms. These risks can cause vulnerabilities in consumers’ lives at any stage of their interaction with financial services.

Consumer research, policy advocacy, and legislation must adapt to this new normal to take a different lens on identifying and addressing these challenges. By doing so, the industry can help low-income consumers achieve the goals of financial resilience and well-being. CFI’s consumer protection strategy addresses this by using a <a href="https://www.strivecommunity.org/insights/financial-services/consumer-protection" target="_blank" rel="noopener noreferrer">vulnerability framework</a> that identifies where consumer vulnerability is liable to exist in financial services. Identifying causes of vulnerability at any point in the consumer’s life captures moments where consumer resilience can be eroded and thus requires action by various stakeholder groups – investors, regulators, supervisors, and policymakers.
<blockquote>Identifying causes of vulnerability at any point in the consumer’s life requires action by various stakeholder groups – investors, regulators, supervisors, and policymakers.</blockquote>
CFI also convenes the <a href="https://globalrff.org" target="_blank" rel="noopener noreferrer">Responsible Finance Forum</a> (RFF), a global platform for dialogue and knowledge sharing on responsible inclusive finance and consumer protection. The RFF aims to confront the changing nature of consumer risks and collectively arrive at solutions that the inclusive finance industry can adopt to deliver financial services responsibly.

View the full <a href="https://www.youtube.com/playlist?list=PL30fMMRd3G_4ysbJRWLiVICDCCHEKSTMY" target="_blank" rel="noopener noreferrer">Consumer Protection playlist</a> from FIW 2022.

Financial Inclusion Week 2022 had over 3,300 registered participants from 2,000 organizations across 148 countries. With almost 400 speakers and 125 sessions, FIW 2022 was the largest event to date. All sessions from FIW 2022 can be viewed <a href="https://financialinclusionweek.org/2022-event" target="_blank" rel="noopener noreferrer">here</a>.

And be sure to save the date for FIW 2023, which will take place October 16-19, 2023.

FIW Recap: Consumer Protection – Crucial to Driving the Inclusive Finance Agenda

The impacts of climate change are diverse and wide-ranging. Its most immediate manifestations, such as natural catastrophes and extreme weather events, sea level rise, damage to biodiversity, and communicable diseases, amplify the hardships on developing economies which are often more vulnerable to damage and have fewer resources available to support the recovery. The <a class="Hyperlink SCXW263472838 BCX0" href="https://globalrff.org/december-2022" target="_blank" rel="noreferrer noopener">December 2022 RFF</a> discussions explored the links between responsible finance and the challenges posed by climate change.
<h1>Preparedness, Risk Management, and Insurance</h1>
Along the lines of the three key themes of the December 2022 RFF convening – consumer protection, the role of stakeholders, and the path forward in the face of climate change – insurance has an important role. Insurance can strengthen the resilience of vulnerable communities and help them adapt to the climatic changes impacting their lives. If leveraged systematically for both transition and physical risks, it can contribute to the health of the entire financial sector.
<blockquote class="pullquote--left">If leveraged systematically for both transition and physical risks, insurance can contribute to the health of the entire financial sector.</blockquote>
The role of insurance supervision in this extraordinarily complex challenge is far-reaching and multifaceted. As the guardians of consumer protection and financial stability, enablers of innovation and market development, and policy influencers, supervisors are in a position to contribute to financial literacy efforts, establish standards and expectations for financial institutions, remove regulatory barriers for new or innovative solutions, assess risk management practices, support the efforts of the government bodies, and convene forward-looking multistakeholder initiatives. <a href="https://a2ii.org/en/home" target="_blank" rel="noopener noreferrer">Access to Insurance Initiative (A2ii)</a> has supported insurance supervisors in promoting the development of inclusive insurance markets in low- and middle-income countries, in the context of climate and disaster risk, among other key focus areas.

But strengthening the financial system’s resilience in the face of climate change requires systemic solutions and a comprehensive disaster risk management strategy. This can only be achieved through collaboration and innovative approaches from various stakeholders. Supervisory engagement with the industry players, for instance, develops an understanding of the practical challenges and regulatory barriers that providers face in bringing new products to consumers.
<h1>A2ii’s Work on Climate and Disaster Risk</h1>
In recognition of this, the A2ii launched the third <a href="https://a2ii.org/en/iii-lab" target="_blank" rel="noopener noreferrer">Inclusive Insurance Innovation Lab</a> on climate – the first lab with a thematic focus. As part of the project, regulators and other key stakeholders of the insurance space (i.e., government representatives, the industry, distribution, and the nonprofit sector) convened in a year-long process of finding innovative approaches to closing the protection gap against climate change headwinds.

The selected country teams of Costa Rica, Grenada, Zambia, and Zimbabwe emerged from the lab process with the following:
<ol>
 	<li data-leveltext="%1." data-font="Calibri" data-listid="12" data-list-defn-props="{&quot;335552541&quot;:0,&quot;335559684&quot;:-1,&quot;335559685&quot;:1080,&quot;335559991&quot;:720,&quot;469769242&quot;:[65533,2],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;%1.&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="1" data-aria-level="1">A web-based platform for small hoteliers providing risk assessments and sustainable solutions (Costa Rica)</li>
 	<li data-leveltext="%1." data-font="Calibri" data-listid="12" data-list-defn-props="{&quot;335552541&quot;:0,&quot;335559684&quot;:-1,&quot;335559685&quot;:1080,&quot;335559991&quot;:720,&quot;469769242&quot;:[65533,2],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;%1.&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="1" data-aria-level="1">A mutual risk pool providing direct relief to farmers and fisherfolk after a climate-related disaster (Grenada)</li>
 	<li data-leveltext="%1." data-font="Calibri" data-listid="12" data-list-defn-props="{&quot;335552541&quot;:0,&quot;335559684&quot;:-1,&quot;335559685&quot;:1080,&quot;335559991&quot;:720,&quot;469769242&quot;:[65533,2],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;%1.&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="1" data-aria-level="1">An awareness-raising campaign for agriculture stakeholders jointly with community champions (Zambia)</li>
 	<li data-leveltext="%1." data-font="Calibri" data-listid="12" data-list-defn-props="{&quot;335552541&quot;:0,&quot;335559684&quot;:-1,&quot;335559685&quot;:1080,&quot;335559991&quot;:720,&quot;469769242&quot;:[65533,2],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;%1.&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="1" data-aria-level="1">A bundled product – the Farmer’s Basket – offering Affordable Area Yield Index Insurance with inputs like pesticides, fertilizers, and irrigation equipment (Zimbabwe)</li>
</ol>
On the capacity-building side, <a href="https://connect.a2ii.org/" target="_blank" rel="noopener noreferrer">Connect.A2ii</a>, A2ii’s learning and exchange platform for supervisors, offers trainings on the topic.
<ul>
 	<li data-leveltext="" data-font="Symbol" data-listid="11" data-list-defn-props="{&quot;335552541&quot;:1,&quot;335559684&quot;:-2,&quot;335559685&quot;:720,&quot;335559991&quot;:360,&quot;469769226&quot;:&quot;Symbol&quot;,&quot;469769242&quot;:[8226],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="1" data-aria-level="1">The <a href="https://connect.a2ii.org/supervision-of-climate-related-risks-in-the-insurance-sector" target="_blank" rel="noopener noreferrer">Supervision of Climate-Related Risks in the Insurance Sector</a> training is based on the <a href="https://www.sustainableinsuranceforum.org/publication/application-paper-on-the-supervision-of-climate-related-risks-in-the-insurance-sector/" target="_blank" rel="noopener noreferrer">joint IAIS-SIF Application Paper</a>. The training module includes recommendations for supervisors on five key areas: i. supervisory review and reporting; ii. corporate governance, risk management and internal controls; iii. enterprise risk management for solvency purposes; iv. investments; and v. disclosures.</li>
 	<li data-leveltext="" data-font="Symbol" data-listid="11" data-list-defn-props="{&quot;335552541&quot;:1,&quot;335559684&quot;:-2,&quot;335559685&quot;:720,&quot;335559991&quot;:360,&quot;469769226&quot;:&quot;Symbol&quot;,&quot;469769242&quot;:[8226],&quot;469777803&quot;:&quot;left&quot;,&quot;469777804&quot;:&quot;&quot;,&quot;469777815&quot;:&quot;hybridMultilevel&quot;}" aria-setsize="-1" data-aria-posinset="2" data-aria-level="1"><a href="https://a2ii.org/en/event/inclusive-insurance-training" target="_blank" rel="noopener noreferrer">The Inclusive Insurance Training</a> is delivered multiple times per year in English, Spanish, and French and features an important foundational climate and environmental risk module. The module is designed to provide insight into the nature and effects of climate risks on insurers, economies, and consumers, with a focus on inclusive insurance markets. It also explores the role of financial institutions and the role of the supervisor.</li>
</ul>
Index insurance is undoubtedly on the path forward in the face of climate change. However, in emerging markets globally, regulatory frameworks are adapting cautiously with solutions coming from the industry. Supervisory capacity-building, information, and peer exchange on how to regulate and encourage the development of responsible and sustainable index-based solutions are critical.
<blockquote class="pullquote--right">Supervisory capacity-building, information, and peer exchange on how to regulate and encourage the development of responsible and sustainable index-based solutions are critical.</blockquote>
Looking to support supervisors in understanding the mechanics of index insurance, A2ii has recently partnered with the UNCDF Pacific Insurance and Climate Adaptation Programme (PICAP) to publish a <a href="https://a2ii.org/en/knowledge-center/index-insurance/joint-publication-on-index-insurance-best-practices-for-insurance-regulators-and-practitioners-in-the-pacific-island-countries" target="_blank" rel="noopener noreferrer">best practices report on index insurance</a>, sourcing from the Pacific Island countries. The publication provides valuable insight for the region and beyond and guidance on enabling regulatory frameworks to develop index insurance.

Additionally, the upcoming <a href="https://a2ii.org/en/event/public-dialogues/index-insurance-public-dialogue" target="_blank" rel="noopener noreferrer">A2ii-IAIS Public Dialogue – Index Insurance Best Practices</a> will provide a platform to meet and discuss key insights from the report, including regulatory guidelines for index insurance solutions.

In conclusion, supervisors are increasingly recognizing the importance of addressing climate change impacts as well as the emerging opportunities arising from the challenge. Doing things differently will require building new partnerships for novel products and business models, aligning regulation and technology to be hand-in-hand. The goal is to build more robust insurance value chain ecosystems and resilient communities. A2ii is committed to accompanying supervisors on this learning journey through future capacity building, multistakeholder initiatives, knowledge generation, and dialogue.

&nbsp;

A2ii is a unique global partnership working to ensure that the excluded and underserved have access to insurance, allowing them to take control of their lives and reduce their vulnerability against risks. A2ii supports insurance supervisors and regulators in creating the conditions necessary for an inclusive insurance market to grow.

A2ii is the 'implementation arm' of the International Association of Insurance Supervisors (IAIS) on Inclusive Insurance.

Envisioning Responsible Finance in the Context of Climate Change – the Role of Insurance Supervision

Privacy choices are inherently <a href="https://www.ariewaldman.com/book-industry-unbound" target="_blank" rel="noopener noreferrer">contextual</a>, and individuals make different privacy calculi from one situation to another, deciding each time what and how much to share. The boundaries we negotiate depend on our expectations of what will happen to our information in each situation and how much we trust the recipient. For instance, you probably wouldn’t share the same information about your financial status with an acquaintance at work as you would with your tax advisor.
<blockquote class="pullquote--right">Negotiating privacy boundaries in the digital world, including inclusive finance, has become increasingly difficult.</blockquote>
The trouble is that negotiating privacy boundaries in the digital world, including inclusive finance, has become increasingly difficult. <a href="https://www.ipsos.com/en-us/news-polls/trust-in-the-internet-2022" target="_blank" rel="noopener noreferrer">Trust in digital providers</a> has dropped amidst well-documented data breaches and abuses. Trust is also challenged by consumers’ <a href="https://www.youtube.com/watch?v=lXLY7BsG_fg&amp;list=PL30fMMRd3G_4MWcg0tioe63vFk1WA8Clb&amp;index=3" target="_blank" rel="noopener noreferrer">surprise</a> over what data is collected about them. CFI’s <a href="https://www.centerforfinancialinclusion.org/trust-of-data-usage-sources-and-decisioning-perspectives-from-rwandan-mobile-money-users">research in Rwanda</a> found that mobile money users who had applied for digital credit were upset that inputs such as airtime top-ups might be used as part of the underwriting process.

All of this is why, in honor of Data Privacy Week, which is celebrated every year in late January, we’re calling for the inclusive finance field to rethink privacy – specifically to shift it to the left.  Shifting privacy left means bringing up privacy considerations early on in the product lifecycle and paying attention to privacy concerns from the outset, rather than just a final box to check for compliance once a product is already created.
<h1>Focus on Privacy by Design</h1>
One of the ways that people are rethinking privacy in inclusive finance is through an approach called Privacy by Design (PbD). The premise behind PbD is that because privacy is a core property of an IT system, it should influence the underlying system design, rather than be bolted on as an afterthought. In PbD, privacy considerations must therefore start at the ideation phase and be maintained throughout the product lifecycle. This stands in contrast to the compliance-driven approach that typically brings privacy into the discussion after all major design decisions have been made. Popularized by Dr. Ann Cavoukian in 2009, Privacy by Design is most notably mentioned in <a href="https://gdpr-info.eu/art-25-gdpr/" target="_blank" rel="noopener noreferrer">Article 25 in the GDPR</a>.

Despite enthusiasm for the approach and privacy as a value-proposition to consumers, there are limited resources to operationalize Privacy by Design, particularly for organizations like inclusive finance fintechs operating in emerging markets and serving low-income consumers. Last year, CFI conducted a literature review to better understand how PbD has been implemented and its potential for inclusive finance. The results, shared in a report entitled <a href="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2022/12/Potential-of-Privacy-by-Design-in-Inclusive-Finance-3.pdf">Embedding Trust: The Potential of Privacy by Design in Inclusive Finance</a>, landscape the various approaches to PbD in the legal, engineering, UX/UI, and academic fields. While each of the approaches, outlined in the graphic below, provided valuable tools, there were few examples of holistic approaches that product teams could use to embed privacy throughout the design and development processes.

<img class="wp-image-45694 aligncenter" src="https://content.centerforfinancialinclusion.org/wp-content/uploads/sites/2/2023/02/Screenshot-2023-02-02-at-9.19.21-AM.png" alt="" width="904" height="570" />

&nbsp;

CFI believes that five key considerations should guide any applications of PbD in inclusive finance:
<h3>1. PbD should be positioned as business-enhancing.
</h3>
Because privacy has historically been seen as a compliance-related cost, to encourage private companies and fintechs to employ PbD techniques, PbD needs to be presented as a business-enhancing design benefit.
<h3>2. PbD needs to be adapted to work for resource-constrained companies and emerging markets. </h3>
Because PbD has been developed and largely implemented in developed countries, little work has been done to date to make PbD approachable and operational outside of those contexts.
<h3>3. PbD should incorporate low-income and vulnerable consumers’ offline privacy needs in addition to privacy for their digital data.</h3>
In considering the user and his/her privacy capacities and needs, PbD can bring customer-centricity into the data-intensive aspects of digital financial products.
<h3>4. PbD must balance consumer privacy preferences with companies’ needs.</h3>
When implementing PbD, it will be important to consider both the information that companies must collect to be able to perform their work, as well as the privacy preferences of consumers. A balance must be found to ensure that a product will function without compromising consumer privacy.
<h3>5. PbD must articulate privacy responsibilities across disaggregated value chain and partnerships.</h3>
Consumer data can sit and be shared across multiple organizations in today’s modularized fintech ecosystem, and not all actors in the value chain have equal power and influence.

&nbsp;

Moving forward, CFI is working to create a PbD playbook for fintech product teams to embed and position privacy as a core value proposition to consumers. The playbook aims to help product managers – in their role of facilitating product development by technical staff (data scientists, engineers, UX/UI, etc.) -- define the user journey and set metrics for product success, and ultimately present a strong opportunity to embed privacy. While product teams are key to executing Privacy by Design, a fintech’s executives and leadership must also recognize the business value of investing in privacy for it to succeed. Similarly, investors and funders need to prioritize privacy and realize the value of embedding privacy into design from the outset, not only because it is the right thing to do for consumers, but also because it is increasingly important to their bottom lines. By increasing awareness of Privacy by Design in the inclusive finance space, we can make strides in ensuring that consumers are protected and help build trust in digital finance.

In Honor of Data Privacy Week, Let’s Rethink Privacy in Inclusive Finance

The theme for Financial Inclusion Week (FIW) 2022 was “Inclusive Growth in a Digital Era.” For years, financial products and services have been moving digital, and the pandemic further accelerated the trend toward digitalization. As digital becomes the new norm, we must ensure that these services are safe and inclusive of all people and do not exacerbate the exclusion of marginalized and vulnerable groups. FIW 2022 explored how the global financial inclusion community can harness digital innovation to expand inclusive financial services for all people across the globe, ensuring that products meet customer needs, have appropriate safeguards in place, and contribute to inclusive economic growth.

FIW 2022 hosted 125 live and on-demand sessions, featuring nearly 400 speakers from around the world. With over 3,330 registered participants from 2,000 organizations and 146 countries, FIW 2022 was the largest event to date.

To capture the learnings and key takeaways from the many Financial Inclusion Week 2022 sessions, CFI is compiling short summaries that highlight content and ideas from FIW 2022 sessions on select topics.

FIW 2022 Recap

The pandemic <a href="https://www.worldbank.org/en/news/press-release/2022/06/29/covid-19-drives-global-surge-in-use-of-digital-payments" target="_blank" rel="noopener noreferrer">accelerated the adoption of digital financial services</a>, especially in emerging economies, largely due to the number of people who <a href="https://www.un.org/sustainabledevelopment/blog/2021/12/as-internet-user-numbers-swell-due-to-pandemic-un-forum-discusses-measures-to-improve-safety-of-cyberspace/" target="_blank" rel="noopener noreferrer">began using the internet for the first time</a>. The <a href="https://www.worldbank.org/en/publication/globalfindex" target="_blank" rel="noopener noreferrer">Global Findex 2021</a> found that of the adults in developing countries who paid utility bills directly from an account, one-third did so for the first time during the pandemic. In India, more than 80 million adults made their <a href="https://www.worldbank.org/en/news/press-release/2022/06/29/covid-19-drives-global-surge-in-use-of-digital-payments" target="_blank" rel="noopener noreferrer">first digital merchant payment</a> after the start of the pandemic; in China, over 100 million adults did the same. However, the Findex 2021 data also showed a rise in consumer protection risks and cautioned that less experienced financial consumers were more vulnerable to such risks.

As digital financial services proliferate, new risks emerge. One of these risks is known as <a href="https://www.deceptive.design/" target="_blank" rel="noopener noreferrer">deceptive designs</a>, which are tricks used by companies when designing user interfaces that have the effect – either deliberately or otherwise – of obscuring, subverting, or impairing consumer autonomy, decision making, or choice. In other words, deceptive designs are used to manipulate people into making decisions that may not be in their best interest. Deceptive design is all around us and is increasing with rapid digitalization.

Those most vulnerable to deceptive designs are consumers with low digital capability, low financial means, or are those who are vulnerable because of life events or mental health issues. The use of deceptive designs in financial services, especially when catering to low-income and vulnerable consumers, can cause harm such as loss of agency and risks of data privacy, and can extend to financial losses that increase vulnerabilities and erode trust in the usage of digital financial services.

While the implications of deceptive designs on user privacy and data protection are beginning to be discussed among regulators, consumer protection concerns have yet to be addressed. This is partly because design is hard to regulate, and manipulative design can exploit existing laws and legal loopholes.
<h1>Deceptive Design Patterns Are Ubiquitous</h1>
In the last week, how often have you used an app on your smartphone or a website to order groceries? To shop for clothes? Or logged in to read online news? Chances are at least once. It is also likely that you encountered several deceptive designs during that time. Harry Brignull, who raised awareness of deceptive design, features nearly <a href="https://www.deceptive.design/hall-of-shame/all" target="_blank" rel="noopener noreferrer">400 examples of deceptive design practices</a> on his website. The New York Times, a publication that was one of the earliest to speak about deceptive designs, uses deceptive designs to make their paywall “smarter” and <a href="https://www.techdirt.com/2022/08/19/when-tech-companies-do-it-the-ny-times-calls-it-dark-patterns-when-the-ny-times-does-it-its-called-being-smart/" target="_blank" rel="noopener noreferrer">make it difficult to cancel subscriptions</a>.

In Kenya and Tanzania, <a href="https://www.cgap.org/sites/default/files/Focus-Note-Consumer-Protection-in-digital-Credit-Aug-2017.pdf" target="_blank" rel="noopener noreferrer">CGAP’s research</a> found several challenges with how digital lenders disclose actual pricing to consumers, using monthly or weekly interest rate figures instead of a standardized calculation like an annualized percentage rate (APR). <a href="https://wiredspace.wits.ac.za/server/api/core/bitstreams/d6e32783-24e7-4e50-8bcf-8c58f84bd872/content" target="_blank" rel="noopener noreferrer">Research by Mazer and Rowan (2016)</a> also found that some digital lenders only disclosed the price after consumers clicked the “I accept” button and the loan was executed. Insurance, a financial product that often is accused of mis-sale, can also use deceptive designs when sold online. In the UK, Currys, a well-known retailer, <a href="https://twitter.com/darkpatterns/status/1561031067334844418" target="_blank" rel="noopener noreferrer">nudges online shoppers during check out</a> by preventing them from moving forward unless they choose to buy insurance. In India, until laws changed recently to prevent the mis-sale of travel insurance, it was common to see travel portals use <a href="http://rsrr.in/wp-content/uploads/2021/04/UNPACKING-DARK-PATTERNS-UNDERSTANDING-DARK.pdf" target="_blank" rel="noopener noreferrer">pre-checked buttons to bundle travel insurance</a> with ticket purchase.
<h1>Focus on Consumer Protection by Design</h1>
The nature of these emergent risks requires new partners to work together – including designers, researchers, technologists, civil society actors, and lawyers who work on consumer rights, along with regulators, supervisors, investors, financial service providers, and tech-based providers. To kick off this work, CFI and <a href="https://www.credit-suisse.com/us/en.html" target="_blank" rel="noopener noreferrer">Credit Suisse</a> are partnering to leverage the diverse talent and expertise of Credit Suisse employees through the Innovation for Impact series, a spinoff of the bank’s <a href="https://www.credit-suisse.com/careers-news/en/articles/careers/spark-ideas-explore-new-trails-202012.html" target="_blank" rel="noopener noreferrer">Future of Banking Hackathon</a>. Applying Credit Suisse’s Fresh Perspectives! Framework, the bank’s innovation lifecycle approach, teams of Credit Suisse employees will be guided through addressing the challenges that low-income consumers can face from the use of deceptive designs in financial services. The teams will work together to generate novel ideas, and rapidly test, learn, and adapt their solutions to address the presented challenges.

Through its <a href="https://www.credit-suisse.com/about-us/en/our-company/corporate-responsibility/economy-society/financial-inclusion.html" target="_blank" rel="noopener noreferrer">Financial Inclusion Initiative</a> (FII), Credit Suisse has partnered with Accion for over a decade, including as a founding supporter of CFI. Through the FII, Credit Suisse aims to support the availability of innovative and financially inclusive solutions to help advance progress towards the UN Sustainable Development Goals (SDGs) by providing both financial as well as human resources. The Innovation for Impact series provides a win-win opportunity for Credit Suisse employees to leverage and develop their expertise and innovation capabilities while at the same time contributing to an important challenge facing the inclusive finance sector.

The partnership between Credit Suisse and CFI is a way to begin generating awareness of deceptive designs with investors and financial service providers, and the harms they can cause to low-income consumers. The work on deceptive designs is part of a larger body of work that CFI is developing that looks at how to embed consumer protection by design for systemic change to create digital, inclusive financial systems that are more equitable, less discriminatory, and more empowering.

CFI is launching a strategic area of work around ‘Consumer Protection by Design’ to identify and address newer risks that emerge as inclusive finance is digitalized. This area of work will define the term consumer protection by design, identify newer risks (including deceptive designs), and assess whether these risks tend to be prevalent in specific geographies, industries, and company stages, and if they target specific user groups that are more susceptible. CFI will also conduct a landscape analysis of the specific harms posed to vulnerable consumers with a focus on identifying market monitoring tools and regulatory solutions that can be used to mitigate these harms.