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Resource Library / What is the Low Bar and What is the High Bar on Client Protection?

Author(s):
Elisabeth Rhyne


Elisabeth Rhyne, Managing Director, Center for Financial Inclusion at ACCION, USA This paper will discuss the Client Protection Principles (CPPs) promoted through the Smart Campaign. It will first examine each of the CPPs and then highlight how the CPPs are evolving (in 2011 this includes adding non-discrimination and broadening the CPPs beyond credit to savings, insurance and payments). The paper will argue that the CPPs are universal standards – applicable to any provider of financial services to low income people. Thus, in principle, there’s one standard, not a high or low bar. (A possible high bar could go beyond individual MFIs to encompass financial education for clients and the enabling environment for client protection.) In practice, application of the principles varies. Institutions can’t transmit principles and policies into action 100% of the time, and some institutions are good at some principles and weak at others. A CPP scorecard needs to take such variation into account. The paper will discuss progress toward a scorecard, self-reporting systems (weak) and third-party verification (much stronger) to certify whether a given provider passes the client protection bar.



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