These are responses we write to documents that are put out by the government or the regulator in the public domain, often intended for public consultation – such as white papers or regulatory notifications or circulars or committee reports, etc.
In this Response, we present our comments on the RBI’s Discussion Paper on the Guidelines for Payment Gateways (PG) and Payment Aggregators (PA) in response to the call for comments from stakeholders (Reserve Bank of India, 2019c). Our comments are organised into five broad themes...
Recommendations that financial sector regulators can consider applying on regulated financial services providers in order to improve outcomes for households and enterprises.
Response to the Reserve Bank of India on the Draft Enabling Framework for Regulatory Sandbox
In this document, we present our comments on the draft Personal Data Protection Bill 2018 (hereafter “the draft Bill”) in response to the call for comments from the public by MEITy (Ministry of Electronics and Information Technology, 2018)
Comments to the Ministry of Electronics and Information Technology (MEITy) on the draft Personal Data Protection Bill 2018
In this document, we present our responses to the public consultation on the White Paper which is based on our broader approach on data protection. This approach looks past a consent-led approach to data protection, and seeks to embed a bundle of rights for all individuals with respect to their personally identifiable data that apply even where consent has been validly obtained for data collection
The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) and aims to promote policy and regulatory strategies that protect individuals accessing finance given the sweeping changes that are reshaping retail financial services in India. Our vision is for every individual to have universal access to suitable financial services using a range of channels that enable them to transact securely and confidently.
Our comments in response to the Draft Rules are presented in two sections below. In the first section titled “I. Overarching Comments”, we raise two broad points on (1) extending the data protection principles consistently to avoid regulatory gaps, and (2) the need for regulatory coordination to avoid dual regulation, mitigate potential capacity constraints for MeitY and any adverse impact on the ease of doing business for pre-paid instrument (PPI) issuers. In the second section titled “II.
On 8 March 2017, the Ministry of Electronics & Information Technology (MeitY) released a set of draft rules for security of prepaid payment instruments (Draft Rules), inviting comments by 20 March 2017.
The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) and aims to promote policy and regulatory strategies that protect citizens accessing finance given the sweeping changes that are reshaping retail financial services in India.
In all our research efforts, we strive to maintain an independent voice that speaks for the low-income household and household enterprises. Our ability to perform this function is significantly enhanced by our commitment to disseminate as a pure public good, all the intellectual capital that we create.
