Our response to the RBI’s Draft framework for recognising Self-Regulatory Organisations (SRO) for FinTech Sector
Our response covers two themes:
Leading from a customer protection perspective, our comments emphasise the need for the prospective SRO to have duties towards the customers, at par with responsibilities towards the regulator.
Consumer protection in financial services is a core component of Dvara Research’s mission, activities and its advocacy agenda. In this regard, I had the opportunity to participate at Consumers International’s Global Congress 2023, in Nairobi, Kenya, in December 2023.
Our Response to RBI’s Draft Omnibus Framework for recognising Self-Regulatory Organisations (SROs) for Regulated Entities (REs)
In this blogpost, we present our comments primarily to the former, but significantly implicating the latter. We include both frameworks since they cover similar subject matter – the creation of an SRO.
The Insurance Regulatory and Development Authority of India (Insurance Products) Regulations, 2023, hereafter “Draft Regulations”, was released by the Insurance Regulatory and Development Authority of India (IRDAI) in December 2023.
This post presents design elements that providers can use to make the consent artefacts more effective for constrained users. These design recommendations emerge from the insights from an immersive behavioural field study we conducted with 60 constrained customers through a gamified simulation of an AA transaction.
Dvara Research and Final Mile are collaborating on a behavioural science informed primary study to unpack the barriers that customers currently face in engaging with and understanding consent artefacts.
Social enterprises will have to conform to much higher standards of reporting than they are conventionally used to.
Read more at: https://www.bqprime.com/opinion/a-social-stock-exchange-for-india
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In this note, we discuss how the current approach of the PCA framework is inconsistent with the objectives it seeks to achieve.
An RBI Working Group has suggested that lending service providers be disallowed from providing credit enhancements such as FLDG (first-loss-default-guarantee). However, a risk-proportionate regulation of FLDG could address its risks, while allowing the ecosystem to benefit from innovation.
In our response, we commend and highlight the more risk sensitive methodology and the corresponding disclosures outlined in the draft guidelines. However, we also point out that not including conduct risk under operational risk is a major lacuna.