Independent Research and Policy Advocacy

Comments dated 14 April 2017 on the draft circular on “Master Directions on Issuance and Operation of Pre-paid Payment Instruments (PPIs) in India” (Draft Circular) released by the Reserve Bank of India (RBI)

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.

A Brief Comparison of Ombudsmen Frameworks – Part 2

Following our initial post on a brief comparison of grievance redressal mechanisms existing in India for financial services, at first glance it can be seen that there is considerable variation in the process elements among the various sector ombudsmen.

Comments dated 20 March 2017 on the draft of the “Information Technology (Security of Prepaid Payment Instruments) Rules 2017” dated 8 March 2017 (Draft Rules) released by the Ministry of Electronics and Information Technology, Government of India (MeitY)

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.