 I'm with Jamie Soli, Senior Policy Advisor at Consumers International and also co-chair of one of the working groups within the focus group on digital financial services, Consumer Experience and Protection Working Group. Hello. Good morning. Okay, so Consumer Experience and Protection Working Group, give me a bit more idea of what your group is working on. Well I like to invert it and call it the Consumer Protection and Experience Group. As the title suggests, we're looking at the legal and regulatory frameworks for the digital money consumer and how that user is protected or not vis-à-vis the legislation in place in the country. And we're going to look at this issue in four countries primarily, Nigeria, Uganda, India and Bangladesh and see where we find gaps. Then we're going to interview the regulators in those countries and see if our understanding of the legal framework is accurate and if they also perceive gaps in terms of protecting the consumer. If they do, we're going to ask them how they intend to deal with that problem through new legislation, new regulation or actually new practical measures to monitor and supervise the industry. And the final part of our research is going to be direct consumer surveys. How protected does the user actually feel when they use mobile money? Are they having problems? Are they having challenges? And is there something that the state needs to do to respond to those problems? Can you tell me why you started with these four countries in particular? We knew that we needed to have a certain mass and level of uptake in terms of users to actually do the direct consumer survey. So we worked backwards a little bit. But also these countries were selected because we have a depth of knowledge from the standard commercial financial services. And we know that there are some problems and some issues in these countries that are perhaps replicated in other countries. So it was a mixed reason. And do you already have some idea of what level of consumer protection exists within this area? And if so, how much? Yeah, we do. We're at the phase now where we've actually taken a look at some of the user agreements and have compared the content of the contract for the user with the legislation in these countries. And we're seeing some very distinct problems that are fairly common, such as forced mandatory arbitration for a consumer. If you have a complaint, your only recourse mechanism is to go back to the provider and to try to work it out. If you can't, in your contract, it will say you must arbitrate. And that is seen as an obstacle for a consumer to actually get redressed. It's blocking them from using the standard judiciary to resolve their problems. We're also seeing a lack of communication and really opaque language with regard to pricing. So you might see that the contract references extra banking fees or penalties for dormancies of accounts. And it doesn't really explain what those fees are, nor does it reference a fee schedule. So the consumer is really in the dark about what these additional fees are going to be. Now, these are the kind of issues that could be translated to any other kind of consumer experience. What do you think you can achieve within this field in particular? Well, with any standard form contract, and we're seeing these online, the consumer doesn't have much choice other than to click and check the box and say, yes, I'll accept this as terms of conditions of service or I won't. I'll not be a client of yours. But we're seeing that this could be a regulatory tool. The regulator could very easily take these contracts, analyze them, and see what the business practices are vis-a-vis the law. And if they don't like something, they're very much in a position to be able to tell the provider this is illegal or this is unfair for the consumer. The consumer, because it's a contract of adhesion, really has no power in the situation. But we still think that there can be a teaching moment here. This is early days for you and your group. You've been going for about a year. What have you managed to get going in that short time? Well, we've done full legal and regulatory reviews of the four countries that I mentioned. We have a very complete understanding of how the consumer is protected vis-a-vis the legislation and regulation or not. From that, we've developed a questionnaire to take to the regulators, the telecom regulators, the financial services regulators. And if there is a competition regulator or a consumer protection regulator, we're going to be interviewing those regulators using our standard form questionnaire. We've also done a review of user agreements in West, East Africa, and South Africa, looking at about seven or eight countries' standard consumer agreements. And we have a report which summarizes the problems, some of which I've mentioned, with regard to these standard form contracts. As in terms of what's planned for the future, we have a law firm that's working with us, Pro Bono, from Africa, from Zimbabwe. And it will be creating a model contract. So the idea is to come up with a contract, a standard form agreement which very clearly protects consumers, but also takes into account the business risks that the providers are trying to compensate for. So we hope to come up with an equitable model agreement that can be useful to regulators as well as to the industry. Okay, so that's the hope of the final outcome of all this. Well, that's one of our final outcomes. Okay, so what else do you think could possibly come out of this working? Well, we're also going to move into, after we conduct our regulator interviews, we're then going to go to the consumers and either do mystery shopping. So we send somebody around who tries to use the mobile money and maybe they have problems, maybe they don't. And that way we can better understand the actual consumer experience. Or we might just do consumer interviews. Have you used a mobile money product? What was your experience? Did you have any time that you sent money to somebody that was unintentional and you lost money? We want to really understand what are the real problems that the consumer faces. And when we have all of these three components in place, we'll then be able to go back to regulators and to say, this is what we found in your market. This is what we recommend you do to resolve the problem. And what difference do you think you'll make? Is it about more faith in this form of transaction? What do you really want to achieve? Well, if the consumer isn't, if the consumer is not confident and doesn't trust the provider, you're not going to have uptake. And ideally, when you're a consumer protection advocate, you want the consumer to have many more choices in terms of financial services providers because more choice tends to mean that there's competition and that there's a lower price that the consumer is going to pay. Ideally, what my hope is for this industry is that it really provides that choice for the consumer, but it really highlights problems that I call legacy consumer protection problems, which are left over from the standard commercial financial services sector. You have problems with contracts. You have problems with the lack of transparency of information on pricing. You have lack of redress mechanisms for consumers. All of these legacy problems have just been now plunked into a new industry, so to speak. So I really hope that we can redirect people's attention and they can start acting on these problems. And do you have a sense that there is a really big potential in this area of digital financial services? Are consumers in your view really keen to jump on this bandwagon? Oh, I think it's a huge potential. I'm in the United States and I'm just waiting for the service to be provided. It's slowly, slowly making its way over, I think. Jamie Sully, thank you very much for being with us today in Geneva. Thank you.