AN INTERIM REPORT OF OUR WORK UNDER THE CENTRE FOR CUSTOMER PROTECTION

ACKNOWLEDGEMENTS

We are grateful to the Bill and Melinda Gates Foundation for entrusting us with a grant under the Customer Protection Program housed at Dvara Research. We thank our advisors for the Program – Anna Wallace, Bindu Ananth, Rafe Mazer and Rajesh Bansal.

We thank the several industry experts and our technical, knowledge and implementation partners with whom we are working to solve pressing customer protection problems and from whom we are learning about the challenges faced by customers of financial services in India.

Executive Director’s Message

Dear Readers,

Dvara Research considers itself to be the voice of low-income households. This has been our mission for 15 years now, and during this time, we have built a strong and credible reputation in research and advocacy positions relating to financial inclusion and financial customer protection. We have worked hard to deliver thinking of the highest quality in these two domains using a systematic and multi-pronged approach. It is this approach and its impact that I would like to call your attention to, as you read this report, whose intent is to showcase our work on financial customer protection.
Research institutions like ours strive to support policy makers in their work. We share their concern for low-income households, and it motivates us to provide them with the information and analysis they need to make policy decisions. We commend India’s government and her regulators for envisioning a robust digital public infrastructure for her citizens.

We recognise that policy making has played a crucial role in enhancing and expanding the access to financial services for low-income households. We also appreciate the enthusiasm with which financial service providers have innovated to accomplish the vision of policy makers.
Past developments in this space such as no-frills bank accounts, a widespread agent network for last-mile cash-out access and an advanced digital payments infrastructure are fast enabling digital peer-to-peer transactions at scale. We do believe that the growth of digital financial services have a positive impact on the Indian economy, and we consider ourselves fortunate to be a part of this digital journey.

In our work, we listen intently to government officials and regulators on issues they worry about, and we focus our efforts towards helping them deliver on their mandates for consumer welfare.
We employ a variety of approaches, including one-on-one meetings, stakeholder conversations, participation in various fora, and the continual finetuning and updating of our work priorities and commitments to reflect the most pressing needs of low-income financial services’ customers and the most impactful directions for solution-discovery.

We publish our thinking in a variety of formats, such as blogs, reports, opinion pieces and journal articles, that we make available to all stakeholders in the industry and policy-advocacy networks. In doing so, we seek to communicate to stakeholders the tremendous importance of customer protection as an integral and constitutive feature of meaningful financial inclusion.
That our contributions are valuable in this regard is evidenced by the recognition we have received from well-established domestic and international organisations in the development and financial inclusion domains, ranging from multilateral agencies, non-government thinktanks, private funders and donors, consumer advocacy organisations, as well as researchers and public intellectuals. We have earned the trust and respect of these stakeholders as the go-to experts in financial customer protection. We are invited to many fora to bring views from the customer protection lens, but more importantly we are also helping to create and expand the number of fora where financial customer protection gets its rightful place as an important theme in the larger narrative, so that the quality of discussions that ensue at those venues is thereby deepened.
We also bring in a focus on customer protection by giving it a seat at the table when we are consulted on various themes by external stakeholders, be it by researchers looking to understand the nature of problems that low-income customers face, or consumer behaviour specialists operating in the private fintech, payments and banking sectors, or members of industry bodies, financial service providers, regulators, and others.

Through a carefully chosen portfolio of impactful action-research and solution-testing, we will continue to bring our repertoire of skills and strategies to bear in raising the bar for customer protection in the financial inclusion domain.
We are keen to engage far more with financial service providers to help them achieve customer safety and satisfaction, as our insights can help providers in fuelling innovative product design and delivery. In all its research efforts, Dvara Research strives always to maintain an independent voice that speaks for the low-income household and household enterprise, and its ability to perform this function is significantly enhanced by its commitment to disseminate as a pure public good all the intellectual capital that it creates.

Sincerely,
IG
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Dr. Indradeep Ghosh

Dvara Research considers itself to be the voice of low-income households. This has been our mission for 15 years now, and during this time, we have built a strong and credible reputation in research and advocacy positions relating to financial inclusion and financial customer protection.

Advisors

Anna Wallace
Bindu Ananth
Rafe Mazer
Rajesh Bansal

Consultants

Patricia de Jonge
Patricia de Jonge
Former Consultant
Paul Adams
Paul Adams
Former Consultant

Spotlight Projects

Monitoring and Diagnostic Tools

Other Projects

About Dvara Research

Dvara Research envisions a world in which every low-income household and every enterprise has complete access to suitable financial services and social security through a range of channels that enable them to use services securely and confidently. We identify ourselves as the voice of low-income customers. They are the reason we exist, and we are relentless advocates for their financial wellbeing.

Since 2008, Dvara Research has deeply analysed, and carefully written about, financial inclusion and social protection in India from policy, regulatory, and practitioner perspectives that are anchored to its mission. Its work has gained the admiration and respect of policymakers and regulators, and since its inception, Dvara Research has been a research-partner of choice for such key policy-making bodies as the Reserve Bank of India, Securities and Exchange Board of India, Pension Fund Regulatory and Development Authority etc.

Our work at Dvara Research is categorised into four verticals that conduct transformative research into the various aspects of financial inclusion and social protection. These four verticals are – Financial Systems Design, Future of Finance, Social Protection, and Household Finance Research. The Customer Protection Program, launched in November 2021, is a horizontal program that overlaps across all the areas of work that we do.

POLICY INITIATIVES

Meet Our team

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Anna Wallace

Anna is the Senior Program Officer at the Bill and Melinda Gates Foundation. Her role is to leverage technology to enable financial regulators in managing the risks posed by emerging financial services models without impeding the innovation required to drive financial inclusion. Anna sits on boards for the Alliance for Innovative Regulation and FSD Kenya. Anna has 20 years’ experience in public policy with an expertise in financial regulation, digital financial services and consumer protection. In her most recent senior leadership role, Anna built the innovation department at the UK’s Financial Conduct Authority. This included developing the world’s first ‘Regulatory Sandbox’, creating an international network of financial regulators to promote pro-innovation regulation (the Global Financial Innovation Network) and developing policy on issues like cloud computing, machine learning and crypto assets. Anna was the accountable executive for FCDO-funded technical assistance programs to Nigeria and was a member of UK Financial Services Investment Board and Fintech Delivery Board. This role builds on a broad career across a range of public sector organizations, including the UK Government, European Commission and the Scottish Parliament.

Bindu Ananth

Bindu is the Chair, Co-Founder and Managing Trustee of Dvara Holdings. Bindu is the Founder of Dvara Health Finance. Prior to this, she was Board Chair of Northern Arc Capital from 2009 – 2018. She also worked in ICICI Bank’s microfinance team between 2001 and 2005 and was head of the new product development team within their Rural Banking Group in 2007.

She has an under-graduate degree in Economics from Madras University and Masters Degrees from the Institute of Rural Management (IRMA) and Harvard University’s John. F. Kennedy School of Government.

Bindu has co-edited “Financial Engineering for Low-Income Households”, a book published by SAGE. She has also published in the Economic and Political Weekly, OECD Trade Paper Series and the Small Enterprise Development Journal. She was a member of three RBI Committees: financial inclusion, SME finance and housing securitisation. She was a member of the Taskforce of the Insolvency & Bankruptcy Board of India (2017). She was a member of the Government of India’s High Level Committee on Women (2014-15) and the Tamil Nadu Government’s Expert Committee on Revival of MSMEs (2022).

She is an Independent Director of NeoGrowth Credit, Avanti Finance and Syngenta Foundation. Bindu was a recipient of the ET Prime Women’s Leadership Award in 2020.

Rafe Mazer

Rafe Mazer is the Director of the Consumer Protection Research Initiative at Innovations for Poverty Action. The Initiative collaborates with policymakers, providers, and civil society to develop new methods for consumer protection policy development. Prior to joining IPA, Rafe worked for 10+ years to improve financial advice, pricing transparency, data protection, and competition. He has created innovative experiments with financial service providers and regulators to integrate consumer protection into both product design and policy-making processes. He has a BA from Pomona College and an MA in International Development Policy from Duke University.

Rajesh Bansal

Rajesh Bansal is the Chief Executive Officer (CEO) of The Reserve Bank Innovation Hub. He is a highly regarded thought leader in the areas of digital financial services and digital infrastructure, Mr. Bansal has nearly three decades of global experience in designing digital IDs, electronic payment products, and cash transfers, to enable inclusive development in multiple Asian and African markets. Prior to joining RBIH, he was a senior adviser at Carnegie India, where he led the center’s Technology and Society program.

Mr Bansal has previously served at the Reserve Bank of India (RBI) in various capacities, including in areas of technology, payment systems, and financial inclusion. He is one of the key architects of India’s journey from cash to cash-lite by actively promoting policies, strengthening institutions, governance frameworks, and designing new products and solutions for scale and adoption. Mr Bansal was a member of the founding team of Aadhaar and specifically led the design of India’s Direct Benefits Transfer system which is benefiting hundreds of millions of low-income clients. He also played a key role in creating India Stack, digital ID-based infrastructure for a presence less and cashless service delivery platform in India. He has been a member of a number of committees of the Government of India and the RBI.

Mr Bansal is a frequent speaker, moderator, and panellist on financial innovation and inclusion in academic circles, conferences and fintech festivals nationally and internationally. He has authored a number of articles and opinion pieces in leading publications ranging from The Economic Times to The Print. A recipient of the prestigious Golden Jubilee scholarship scheme of the RBI, Mr Bansal holds a Master’s degree from Duke University in International Development Policy, USA.

Patricia de Jonge

Former consultant
Patricia is a behavioural science researcher and advisor with over a decade of experience in translating behavioural science to policy and regulation, and vice versa. Previously, she worked in supervision and enforcement, and co-founded the Consumer Behaviour Expert team at the Dutch financial regulator AFM. She works for NGO’s, research agencies, firms and regulators worldwide. She holds an MPhil in Development Studies from the University of Cambridge and is currently completing a PhD in Behavioural Research in Marketing at the Vrije Universiteit Amsterdam.

Paul Adams:

Former consultant

Paul Adams is the Director of Financial Inclusion and Consumer Protection at Innovations for Poverty Action. He is an experienced economist, behavioural science consultant and researcher, with 15 years of economic research experience and more than a decade looking at consumers’ financial decision-making. He started working in financial services regulation in 2012, and in 2014, he co-founded the Financial Conduct Authority’s Behavioural Economics and Data Science Unit, leading the organisation’s Behavioural Economics work. He ran the FCA’s first ever large scale Randomised Controlled Trial (RCT) and has since run over 27 large scale RCTs to inform policy in areas such as compensation, retirement, insurance, savings, credit cards, personal loans and current accounts. He has published in academic journals include the Journal of Financial Economics, Economica and the Journal of Marketing research, and is a Senior Visiting Fellow at the London School of Economics. From 2019, Paul worked as a Senior Behavioural Economist at the Dutch financial market supervisor, the AFM. In 2021 he set up his own consulting company working to ethically apply behavioural science in commercial and not-for-profit organisations. As a consultant, he has worked with Shift (the design charity); the European Commission Joint Research Centre; the World Bank Mind, Behavioural and Development team and Innovations for Poverty Action, amongst others.