R_Consultant: Development of a Policy Guideline on Consumer Protection during a Crisis

Organization
  • Alliance for Financial Inclusion
Type
  • Consultancy
Career Category
  • Advocacy/Communications
Years of experience
  • 5-9 years
Theme
  • Protection and Human Rights

1. Background:

The Alliance for Financial Inclusion (AFI) is an innovative, member-driven organization that enables policymakers in developing countries to share their knowledge of financial inclusion policies that have delivered positive tangible results. The network currently comprises over 110 central banks, government ministries and other financial policymaking institutions from about 95 emerging markets and developing countries.

By providing members with the opportunity for peer learning and supporting technical level knowledge exchange on key aspects of financial inclusion policy, AFI works with its members to influence policy reforms, which result in expanding the reach of quality financial services to low-income populations and disadvantaged groups.

Project Background
COVID-19 and Financial Consumer Protection
The COVID-19 crisis has had sudden and wide-ranging effects on consumer behaviour. A greater number of consumers are experiencing higher levels of distress caused by direct experience or fear of the health, economic, and social impacts of the crisis, and they are vulnerable to commercial exploitation. This is felt hardest by the most vulnerable segments such as rural women, youth, older people, forcibly displaced persons, disabled people and micro, small and medium enterprises (MSMEs).

The global pandemic and subsequent economic lockdown rapidly diminished the livelihoods and incomes of vulnerable groups. Digital financial services (DFS) appeared as crucial in mitigating the negative effects of the crisis in various ways, including the promotion of digital payments, bolstering the resilience of payments infrastructure and digitizing MSME stimulus packages[1]. However, with the increase in uptake of DFS, financial regulators have the responsibility of ensuring that financial service providers (FSPs) as well as DFS providers conduct their services in a fair manner without disadvantaging any customer. And whilst DFS has potential to be a significant enabler for vulnerable groups financial inclusion, these groups are also more at risk of exploitation when using DFS. With the increased cases of frauds for instance[2], DFS providers need to have an effective dispute resolution mechanisms so that consumers who have fallen victim to financial frauds have access to some recourse. Additionally, short-term responses globally focused on increasing access to funds and liquidity, deferral of payments, changes in repayment terms and extension of loans and extension of loan without additional costs to support the most impacted individuals and businesses. There is a strong need for both authorities and service providers to increase financial literacy, education and awareness efforts to tackle the rising risk of overindebtness resulting from this situation.

AFI members’ initiatives
Amidst the economic turbulences triggered by COVID-19 that are threatening the gains of financial inclusion, AFI members have started, in close collaboration with the Management Unit, to swiftly respond by devising immediate policy responses that mitigate the potential impact of the economic challenges on financial stability and on the most vulnerable households and businesses. These policy and regulatory responses include monetary and fiscal policies to stimulate growth, smoothen shocks and ensure there is enough liquidity in the financial sector; as well as policies that create financial resilience for businesses and financial service providers to weather the reduced debt servicing capacity of businesses and individuals.

Across the AFI Network, members have shared the various Financial Consumer Protection (FCP) measures implemented specifically for COVID-19 (AFI COVID-19 Dashboard[3]). These measures range from amending and implementing policies & regulations, to supporting the financial industry and providing assistance to consumers. Additionally, the role of monitoring and supervision of market conduct within the financial ecosystem now becomes more important than ever.

[1] www.afi-global.org/blog/2020/04/dfs-effective-response-tool-covid-19
[2] A report by the US Federal Trade Commission mentions 18,235 cases to fraud related to COVID-19, resulting in loses of USD14.33 million from bogus text messages, unsolicited calls and emails, www.afi-global.org/blog/2020/04/dfs-effective-response-tool-covid-19
[3] https://www.afi-global.org/afi-covid-19-policy-response

Challenges

The COVID-19 experience has shown that crisis situations create new and heightened risks, especially for vulnerable groups and segments with low financial literacy. These require further targeted interventions to protect customers. In such instances where FSP are offering measures to consumers to cushion the effect of COVID-19, particularly through access to emergency funds, increasing limits for their credit cards or easy access to additional loans, stringent oversight and enforcement is key to ensure that consumers are not overindebted.

Despite members’ immediate responses, there are still remaining challenges, caused by the immediate and long term capacity constraints that AFI members may not have enough fiscal space to sustain and effectively implement that policy responses and the recovery measures to ensure that financial inclusion gains are not thwarted by the aftermath of the effects of COVID-19. AFI members will therefore need enhanced technical and financial support to be able to swiftly and effectively implement and recalibrate their policy response in medium to long-term. In this regard, AFI’s access to vast technical expertise and practical policy experience through the Network members as well as its knowledge and intellectual partners can provide these much-needed inputs in a timely and relevant manner.

2. Objective:

The objective of this consultancy assignment is to support the development of a policy guideline note on Consumer Protection during a Crisis, that will provide practical guide for AFI member countries on consumer protection enforcement actions during a crisis. Specifically, the policy guideline note will:
a) Build on the policy responses that member countries have shared in their experiences during COVID-19 and through the AFI COVID-19 Dashboard.
b) Feature case studies and lessons from COVID-19, including practices and policy interventions to deal with consumer understanding and awareness during crisis given the heightened risks on FCP.
c) Provide guidance on consumer protection issues related to aggressive commercial practices or pressurized sales tactics towards consumers, unfair contract terms and disproportionate default charges and unfair debt collection practices such as a situation where an FSP harass, oppress or abuse a person in the collection of a debt.
d) Highlight how to efficiently integrate most impacted and vulnerable groups – including women, youth, FDPs, rural areas and MSMEs – in the identified recommendations and initiatives.
e) Provide recommendations to sustain FCP initiatives during the post COVID-19 recovery phase and beyond.

3. Scope of Work:

This assignment is expected to involve extensive desk research and key informant interviews. The consultant will be supported and advised by the AFI Management Unit throughout the assignment and will have access to AFI’s extensive knowledge database related to and for the purposes of this assignment. AFI will facilitate and arrange any interviews with members and partners. There is no travel associated with this assignment.

Key Activities
The appointed consultant is required to:
• Submit a metholody proposal.
• Inception meeting: preliminary consultation on the scope, expected deliverable and related timeline.
• Conduct a comprehensive review of all AFI products and services related to complaint handling in central banks, thus complementing the existing knowledge products and link/map these with member-reported evidence/case study.
• Submit the final draft version of the deliverable by 19th February 2021;
• Including the reviews and comments from the CEMCWG members, submit the final version of the deliverable by 17th March 2021.

Additional information:
Branding and Communications
The policy guidance will be branded with the logos of AFI and Consumer Empowerment and Market Conduct Working Group (CEMCWG) on the front page of the document.

4. Consultant Experience:

The consultant undertaking this assignment should have the following qualifications:
• Advanced degree in a field related to Economics, Public Policy, International Development or another related discipline.
• 7-8 years knowledge and experience in consumer empowerment, market conduct and (post-)crisis policy responses.
• Regional/Global experience
• Fluency in English (oral and writing) is compulsory.
• Writing experience, must submit related working papers or research around the topic.

5. Timeline:

The consultancy work will begin in February 2021 until March 2021 (tentatively). The final draft of the deliverable should be completed no later than 19th February 2021.

  • Proposal submission – Jan 2021
  • Start the project – 1st week of Feb
  • Submit Final Draft for Review – 19th Feb
  • Document commented by CEMCWG members – 5th March
  • Finalizing document – 17th March

6. Travel:

No Travelling is required.

7. Reporting:

The consultant will work closely with the Policy Programmes and Regional Initiatives (PPRI) Unit and with the AFI’s Consumer Empowerment and Market Conduct Unit, and other key staff. The consultant will report directly to Head of the PPRI Unit / CEMC Policy Manager.

8. Criteria for Evaluation:

The proposals submitted will be evaluated based on the following criteria:

  1. Academic Qualification; 15%
  2. Experience and competence of the key staff for the assignment related; 40%
    • Adequacy for the assignment – 25%
    • Regional/Global experience – 15%
  3. Adequacy of the proposed work plan and methodology in responding to the Terms of Reference; 30%
    • Technical approach and Methodology – 15%
    • Workplan – 15%
  4. Sample work – Writing experience and English; 15%

How to apply

Interested applicants are expected to submit a proposal with updated CV and using template given by email to AFI’s Procurement & Contracts Office at [email protected] by 25th Jan 2021.

The final decision on selection of a consultant/consulting firm for this project rests with AFI management team and with the Inquiry. Only shortlisted and successful consultants will be contacted.

To help us with our recruitment effort, please indicate in your email/cover letter where (ngotenders.net) you saw this job posting.

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