The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) 1 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. Rule-Specific Comments”, we provide rule-by-rule feedback on particular provisions of the Draft Rules.
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