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Consumer Empowerment and Market
Conduct Working Group (CEMCWG)

Consumer Empowerment and Market
Conduct Working Group (CEMCWG)

Consumer empowerment and market conduct (CEMC) refers to policies and practices designed to promote stable and inclusive financial services via two interconnected pillars:
• Empowering consumers to make more informed financial decisions via the provision of information, education and effective avenues for redress
• Protecting consumers via effective regulation, supervision and enforcement of market conduct by financial services providers (FSPs).

Consumer empowerment is a broad concept, which places responsibility on regulators and financial services providers to make use of easier, safer financial services and of greater benefit to consumers. Market conduct policies are used by regulators to shape, enhance and balance these three factors (i.e., the institutional framework, as well as supply-side and demand-side factors) to create a more sustainable, fair and sound financial ecosystem for consumers.

While consumer protection has often been a priority for regulators, alongside financial stability, the developments in financial services have highlighted the need for ‘strengthened, dedicated proportionate policy action to enhance financial consumer protection’. At the launch of the AFI CEMC Working Group (CEMCWG), in April 2011, it was acknowledged that expansion and innovation in products, services and technology have, undoubtedly, delivered many economic benefits –globally expanding the reach of financial services and bringing more consumers, including some who have historically struggled to access the market, into financial services. Nevertheless, the CEMCWG also recognized that the causes and effects of the 2007 global financial crisis clearly demonstrated the risk that innovation can disregard legitimate consumer needs and expectations of fair and responsible treatment by financial services firms. As a result, some consumers remain excluded from the market altogether, while others have access only to poor quality financial products or FSPs that do not treat them fairly. Renewed emphasis on consumer empowerment is often referred to as an attempt to re-balance the focus of financial services regulation towards ‘demand-side’ factors – i.e. consumer needs, behaviours and outcomes. This is viewed as both essential and timely.

CEMC regulation is viewed by policymakers and regulators – across the world and in relation to a range of different markets – as offering potential to improve outcomes for individuals, in general, and, in particular, those who are vulnerable, but also as a route to supporting economic growth by promoting and stimulating healthy competition while, at the same time, reducing the cost and burden of regulation.

CEMC policies deliver two important linked outcomes in relation to financial inclusion. First, they increase the potential for FSPs to extend access and choice to groups that are currently underserved or unserved via, for example, new products and services, alternative delivery channels or innovative technologies. Second, they have the potential to improve the quality of products available in the market to ensure that financial inclusion delivers meaningful benefit to consumers. Without this approach, consumers engaging with financial services for the first time are at significant risk of falling prey to poor quality or unsuitable products, resulting in erosion of income due to unexpected costs and charges, punitive terms and conditions, over-indebtedness, loss of savings, damage to their credit history, and repossession of goods and assets.

Fundamental and emerging topics under CEMC are explored in-depth through AFI’s Consumer Empowerment and Market Conduct Working Group (CEMCWG).

CEMC also has relevance for gender policies. Only five percent of AFI members surveyed perceived that they had gender-sensitive consumer protection mechanisms in place. As such, identifying the differential consumer protection needs for women and men can be important for regulators to meet their consumer protection role.

Consumer protection and empowerment are key to financial inclusion efforts and its aim of ensuring that everyone is included in their country’s financial sector. This is clearly demonstrated in the number of Maya Declaration targets that are categorized under CEMC – including targets on consumer protection, financial literacy and financial education.

PRIMARY THEMATIC AREA 2012 2013 2014 2015 2016 2017
2018 2019 2020

Consumer Empowerment
and Market Conduct

  • Consumer Protection
  • Financial Literacy and Financial Education
Maya Declaration Targets 49 72 99 102 122 134 142 192 192
Completed 31 37 50 51 55 58 58 70 84
In Progress 20 17 14 12 16 9 84 122 106
Completion Rate 63% 51% 51% 50% 45% 43% 40.8% 36% 44%

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AFI’s Consumer Empowerment and Market Conduct Working Group (CEMCWG)

A platform to discuss policy and regulatory issues related to consumer empowerment initiatives and market conduct regulations.

Launched in April 2011, CEMCWG aims to support consumer empowerment and protection in order to help secure access to and improve the quality of financial services. Its prime objective is to develop and share a common understanding of lessons learned and cost-effective policy tools, and to promote their adoption at the national level as well as in a broader international context.

61
Member
Institutions
58
Countries
130
Policy
Changes
14
Knowledge
Products

LEAD

Walter Umaña Solano, Superintendencia General de Entidades Financieras de Costa Rica (SUGEF)

CO-LEAD

Rachael Spiwe Mushosho, Reserve Bank of Zimbabwe

  2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Events 1st: Kuala Lumpur, Malaysia
2nd: Riviera Maya, Mexico
3th: Bangkok, Thailand
4th: Cape Town, South Africa
5th: Lima, Peru
6th: Kuala Lumpur, Malaysia
7th: Minsk, Belarus
8th: Port of Spain, Trinidad and Tobago
9th: Kuala Lumpur, Malaysia
10th: Maputo, Mozambique
11th: Yerevan, Armenia
12th: Nadi, Fiji
13th: Mahe, Seychelles
14th: Sharm El Sheiikh, Egypt
15th: Merida, Mexico
16th: Sochi, Russia
17th: Nassau, The Bahamas
18th: Kigali, Rwanda
19th: Virtual Meeting
20th: Virtual Meeting
21th: Virtual Meeting
22th: Virtual Meeting
Member Institutions N/A 30 41 49 52 59 57 60 62 62 61
Knowledge Products
(aggregate)
2 2 6 6 8 9 11 12 12 15 21
Policy Changes
(aggregate)
5
+20
16
+20
20
+20
26
+20
34
+20
42
+20
62
+20
82 130 157 TBD
Peer Reviews
(aggregate)
0 0 0 7 7 8 9 11 13 15 TBD

 

Develop a shared understanding of good practices and cost-effective policy tools
Promote policy adoption at national and international levels

The CEMC Working Group achieves these objectives by:

Promoting transparency and disclosure
Encouraging effective sales and marketing practices
Promoting the harmonization of international initiatives
Creating avenues for help and redress
Championing the benefits

 

Digital Financial Literacy Subgroup (jointly with DFSWG)

The digitalization of financial landscape and the need to strengthen digital financial literacy are at the heart of regulators agenda. Digital financial literacy (DFL) appeal to different segments of the population, and a main question would be to know how to achieve an inclusive use of digital tools. Financial literacy is still not priority for most adults and there are cost implications for financial literacy and capability campaigns. Other challenges faced in the implementation of digital tools for financial capability include behavioral bias and lack of trust. Jointly with the DFSWG, CEMCWG aims to develop an appropriate and effective guideline to aid regulator in the oversight of safe, accessible digital tools that promote financial capability and builds consumer trust in digital platforms.

Recently published: DFL Guideline Note. Planned deliverable: DFL Toolkit

Financial Education Subgroup

Increased access and usage of financial services and products is a catalyst for economic empowerment and development for marginalized and vulnerable target groups such as women, the youth and forcibly displaced persons. Financial education means a process of providing people with knowledge, understanding, skills and confidence to make financial decisions and take actions which are appropriate to their circumstances and needs. On the other hand, financial literacy is the outcome of financial education programs which means the knowledge, understanding, skills and confidence that people have to assist them in making sound financial decisions and actions. Financial literacy programs can help to promote financial education programs that are scalable and sustainable and can also help to pave the way for their financial inclusion in the medium to long term.

Planned deliverable: Toolkit and Guideline Note on Financial Education, and Toolkit on Measuring the Effectiveness of Fin education/literacy programs.

Institution Framework Subgroup

Until recently, the main objective of a Risk-Based Supervision (RBS) approach was ensuring the safety and soundness of the financial system. Originally used for prudential supervision of banks and insurance companies, RBS has been modified for use in pensions and is now being considered for market conduct supervision. The challenges of supervising consumer protection are the same: deploying sufficient resources, focusing on both present and future risks, preventing risks from escalating and taking early corrective actions. There is still a need to assess the effectiveness of CEMC supervision by regulators especially as it relates to planning and implementation of onsite examinations. To address main challenges related to complaint handling in Central Banks, including (but not limited to) human resource management, feedback mechanism, enabling regulations required for effective complaint handling and effective enforcement mechanisms.

Planned deliverable: Guideline Note on Impact Assessment of Financial Service Providers and Toolkit on Complaint Handling in Central Bank

Transparency and Disclosure Subgroup

A reliable and robust help and redress mechanism is a core component of an effective consumer protection framework. Developing one primarily involves establishing internal and external complaint–handling procedures that ensure disputes between consumers and FSPs are dealt with fairly and expeditiously. A complaint–handling mechanism should therefore be independent, transparent, free of charges, easily accessible and effective. Published:

Planned deliverable: Policy Recommendations on the Effective Redress Mechanisms in AFI Member Countries

 

2021

Risk Sharing Facilities: Mobilizing Finance for Women-led MSMEs Digital Financial Literacy
Risk Sharing Facilities: Mobilizing Finance for Women-led MSMEs
Digital Financial Literacy
Guideline Note on Data Privacy for Digital Financial Services

2020

Framework: Complaint Handling in Central Bank
Experiences in the Implementation of the Principle of Disclosure and Transparency in AFI Member Countries
Policy Framework: The Financial Competency Matrix for Adults
Policy Model on Consumer Protection for Digital Financial Services
Financial Education in Latin America & The Caribbean

2018

Case Study: The effectiveness of short-term financial education workshop in rural areas: the case of Armenia

2017

Survey Report: Digitally Delivered Credit: Consumer Protection Issues and Policy Responses to New Models of Digital Lending
Survey Report: Alternative Dispute Resolution
Special Report: Financial Capability Barometer – A new methodology for measuring the financial capability of a country’s population

2016

Guideline Note 21 – Market Conduct Supervision on Financial Service Provides: A Risk-based Supervision Framework

2015

Guideline Note 17 – Policy Guidance Note and Results from Regulatory Survey

2013

Guideline Note 09 – Help and Redress for Financial Consumers
Guideline Note 08 – National Financial Education Strategies
Guideline Note 07 – Sales and Marketing Practices
Guideline Note 06 – Transparency and Disclosuree

2010

Policy Note – Formalizing microsaving: A tiered approach to regulating intermediation
Policy Note – Consumer protection: Leveling the playing field in financial inclusion

 

Bank of Uganda
Financial Literacy Strategy
National Bank of Tajikistan
Disclosure for Credit Institutions
Papua New Guinea
Financial Consumer Protection Framework
Royal Monetary Authority of Bhutan
Guidelines for Financial Consumer Protection
Central Bank of Seychelles
Consumer Protection Regulation
Royal Monetary Authority of Bhutan
National Financial Education/ Literacy Strategy
Banque de la République du Burundi
Consumer Protection Regulation
Bank of Sierra Leone
National Financial Education/ Literacy Strategy
SBS Peru
Help and redress mechanisms (alternative dispute resolution)
Central Bank of Armenia
Help and redress mechanisms (alternative dispute resolution)
Ministry of Finance Swaziland
National financial education/literacy strategies
Banco de la República de Colombia
National financial education/literacy strategies and help and redress mechanisms (alternative dispute resolution
West African Economic and Monetary Union (WAEMU)
National financial education/literacy strategies
National Bank of the Republic of Belarus
National financial education/literacy strategies
Central Bank of Kenya
Consumer protection guideline

 

Banco Central de Reserva de El Salvador
Banco Central de São Tomé e Príncipe
Banco Central de Timor-Leste
Banco Central del Paraguay
Banco de Moçambique
Banco Nacional de Angola
Bangko Sentral ng Pilipinas
Bangladesh Bank
Bank Al-Maghrib
Bank Negara Malaysia
Bank of Ghana
Bank of Papua New Guinea
Bank of Sierra Leone
Bank of Tanzania
Bank of Thailand
Bank of Uganda
Bank of Zambia
Banque Centrale de la République de Guinée
Banque Centrale de Madagascar
Banque Centrale de Mauritanie
Banque Centrale de Tunisie
Banque Centrale des Etats de l’Afrique de l’Ouest (BCEAO)
Banque Centrale du Congo
Banque de la République du Burundi
Central Bank of Armenia
Central Bank of Egypt
Central Bank of Eswatini
Central Bank of Jordan
Central Bank of Kenya
Central Bank of Lesotho
Central Bank of Liberia
Central Bank of Nigeria
Central Bank of Samoa
Central Bank of Seychelles
Central Bank of Solomon Islands
Central Bank of Sri Lanka
Central Bank of The Gambia
Central Bank of the Republic of Uzbekistan
Centrale Bank van Suriname
Comisión Nacional Bancaria y de Valores de México (CNBV)
Comisión Nacional de Bancos y Seguros de Honduras
Direction Générale du Trésor, Ministère de l’Economie et des Finances, Madagascar
Financial Regulatory Commission of Mongolia
Maldives Monetary Authority
Microcredit Regulatory Authority of Bangladesh
Ministère de l’Économie et des Finances de la Côte d’Ivoire
Ministère des Finances et du Budget du Sénégal
Ministry of Finance Zambia
National Bank of Cambodia
National Bank of Rwanda
National Bank of Tajikistan
National Bank of the Republic of Belarus
National Reserve Bank of Tonga
Nepal Rastra Bank
Palestine Monetary Authority
Reserve Bank of Fiji
Reserve Bank of Malawi
Reserve Bank of Vanuatu
Reserve Bank of Zimbabwe
Royal Monetary Authority of Bhutan
Superintendencia de Bancos del Ecuador
Superintendencia de la Economía Popular y Solidaria de Ecuador
Superintendencia General de Entidades Financieras de Costa Rica (SUGEF)

 

Webinars

When financial service providers offer measures to consumers to cushion the effects of COVID-19, particularly through access to emergency funds, increasing limits for their credit cards or easy access to additional loans, it stringent oversight and enforcement are required to ensure that consumers are not overindebted. Consumer Empowerment and Market Conduct Working Group webinar on Consumer Protection Amidst A Pandemic: Case of COVID-19 discussed policy and regulatory interventions, opportunities for cooperation and partnership, and the role of consumer protection amidst a pandemic.

Policymakers and regulators face the challenge of increasing the level of engagement with financial services while at the same time ensuring consumer protection. Webinar session looked into how to design consumer protection strategies that take into account the behaviors of consumers.

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