This course addresses the unique and rapidly evolving challenges of **Consumer Protection in Digital Financial Services (DFS)**, encompassing mobile money, FinTech platforms, and digital credit. It provides a framework for adapting existing laws to the digital context, focusing on new risks such as fraud in agent networks, algorithmic bias in lending, data privacy breaches, and opaque digital disclosures. Participants will learn how to design technology-neutral regulation, utilize SupTech tools for oversight, and implement effective disclosure and recourse mechanisms tailored to the speed and complexity of the digital environment, ensuring responsible innovation.
Consumer Protection in Digital Financial Services (DFS)
Financial Regulation and Operational Excellence
November 30, 2025
Introduction
Objectives
Objectives:
Upon completion of this course, participants will be able to:
- Analyze the specific **consumer protection risks** inherent in Digital Financial Services (DFS) and FinTech models.
- Apply traditional consumer protection principles (UDAAP, disclosure) to the new, technology-driven landscape.
- Develop proportional and **technology-neutral regulation** for mobile money, digital credit, and e-wallet providers.
- Address and mitigate risks associated with **agent network fraud**, operational failure, and liquidity management.
- Design regulatory frameworks for **data privacy, security, and the ethical use of consumer data** in DFS.
- Evaluate the impact of digital disclosures, terms of use, and User Experience (**UX/UI**) on consumer understanding.
- Establish effective and accessible **digital dispute resolution** and recourse mechanisms for DFS users.
- Understand the role of **Regulatory Sandboxes** and innovation offices in testing consumer protection safeguards.
Target Audience
- Regulators and Supervisors from Central Banks and Communications/Payments Authorities
- Compliance Officers and Risk Managers in FinTechs, Mobile Money Operators (MMOs), and Digital Banks
- Legal Counsel and Policy Makers specializing in Technology and Financial Law
- Heads of Product Development and User Experience (UX) in DFS
- Consumer Protection Advocates and Cyber Security Specialists
- Internal Auditors focused on Digital and Operational Risk
- International Development Professionals working on Digital Finance Policy
Methodology
- Case Studies analyzing major consumer protection failures in digital credit and mobile money.
- Group Activities on applying UDAAP principles to a FinTech loan application user interface.
- Discussions on the ethics of using non-traditional data (e.g., social media) for credit scoring.
- Individual Exercises on developing a risk assessment for a new digital payment service.
- Workshop on drafting a data security and liability rule for a FinTech platform.
- Review of regulatory guidance from global bodies on DFS consumer protection.
Personal Impact
- Expertise in adapting traditional consumer law to the complex and fast-moving digital environment.
- Ability to proactively identify and mitigate new risks like algorithmic bias and cyber-fraud.
- Deep understanding of data privacy, security, and ethical data use in FinTech.
- Enhanced skills in compliance, product review, and digital user experience (UX) analysis.
- Increased value to organizations focused on safe, responsible digital innovation.
- Professional recognition as a specialist in Digital Financial Services regulation.
Organizational Impact
- Safe, responsible, and sustainable growth of the digital financial ecosystem.
- Reduction in consumer detriment, fraud, and system failures in DFS.
- Compliance with evolving data privacy and security regulations.
- Enhanced consumer trust in digital services, driving greater uptake and usage.
- Faster and more efficient regulatory oversight through the use of SupTech tools.
- Mitigation of systemic risk arising from large-scale digital platforms.
Course Outline
Unit 1: The DFS Ecosystem and New Risk Landscape
Section 1: DFS Models and Actors- Overview of the DFS landscape: Mobile Money, Digital Credit, InsurTech, Robo-Advisors.
- The complexity of new third-party actors (e.g., Agents, Super-Agents, Platform Providers).
- Identifying the unique risks: **Algorithmic bias, cyber-fraud, data leakage**, and system downtime.
- The challenge of applying traditional, physical-world regulation to digital services.
- Principles for drafting **technology-neutral** laws that apply based on function, not form.
- Regulatory responses to the rapid speed and low-friction nature of digital transactions.
- Balancing responsible innovation with robust consumer protection safeguards.
- The role of proportionate regulation in facilitating FinTech entry and competition.
Unit 2: Disclosure, Transparency, and Digital Conduct
Section 1: UX/UI and UDAAP- Applying UDAAP (Unfair, Deceptive, or Abusive Acts) to digital user interfaces (UX/UI).
- Regulatory guidance on "Dark Patterns" and manipulative design in apps.
- Designing effective **Layered Disclosures** for digital products and click-wrap agreements.
- Ensuring transparent pricing and cost communication in digital credit and payments.
Unit 3: Data Privacy, Security, and Algorithmic Fairness
Section 1: New Frontiers of Protection- Regulatory frameworks for **Data Privacy** and the collection/use of consumer data (e.g., Open Banking).
- Establishing mandatory data security and cyber resilience standards for DFS providers.
- Addressing **Algorithmic Bias** and discrimination in automated credit scoring and pricing.
- Defining consumer rights regarding data portability and the "right to explanation" for automated decisions.
Unit 4: Agent Networks and Recourse Mechanisms
Section 1: Last-Mile Controls- Mitigating **fraud and consumer detriment** in Agent Banking networks.
- Establishing clear liability rules for transaction errors and system failures.
- Designing and advertising accessible **digital and multi-channel dispute resolution** systems.
- Regulatory requirements for effective, timely redress and consumer refunds.
Unit 5: Supervision and Future Trends
Section 1: SupTech and Innovation- The use of **SupTech (Supervisory Technology)** for real-time monitoring of DFS market conduct.
- Regulatory Sandboxes and Innovation Hubs for controlled testing of new products.
- Policy approaches to emerging risks: Crypto-assets, NFTs, and Decentralized Finance (DeFi).
- International and regional regulatory harmonization for cross-border DFS.
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