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Peruvian Authorities Pilot Tool to Improve Consumer Listening

Last year, we discussed how Peruvian authorities are elevating the collective voice of financial consumers by leveraging technology and social media. The financial regulator and supervisor (Superintendencia de Banca, Seguros y AFPs or SBS) and the general consumer protection authority (Instituto Nacional de Defensa de la Competencia y de la Protección de la Propiedad Intelectual or INDECOPI) have been using a range of channels and systems to engage with and analyze data from consumers based on their individual mandates. Despite these important developments, the consumer listening processes in use have not yet been fully integrated within and across authorities. Research showed some opportunities and challenges in their dialogue with consumers during COVID-19

Feedback to authorities indicates that consumers still face issues and aren’t able to use the available channels effectively to ensure their queries, complaints or disputes are addressed by the correct authority. Further, authorities are not taking full advantage of the dearth of information that all channels are receiving, as these data points are not yet captured through an integrated platform that facilitates comprehensive analyses (see Figure 1 below). 

Figure 1: “As-is”: the current financial consumer experience in Peru. Source: CGAP and Accenture LLP. “Analysis of Peru’s Financial Consumer Listening Mechanisms”, June 2022

At the same time, the National Consumer Protection Policy and the National Financial Inclusion Policy, among other statutes, mandate SBS and Indecopi to work together with the aim of building an integrated platform for financial consumer protection. Similarly, the National Digital Government Policy sets the digitization of public services for all citizens as a national goal. 

In this context, CGAP, in partnership with Accenture LLP (Accenture), launched a pilot to help SBS and Indecopi assess their consumer listening mechanisms and determine the necessary steps to design an integrated financial consumer protection platform that will enable customer-centric market monitoring and consumer listening services. Such a platform would use technology to help re-route consumer communications within an authority or from one authority to another so that consumers obtain the help they need without friction and authorities obtain insights on consumer experiences, risks and outcomes of using financial services to strengthen policy, regulation and enforcement.

Co-creating a tool to assess financial consumer listening in the public sector

CGAP and Accenture worked closely with Indecopi and SBS to co-create a consumer listening diagnostic tool for financial consumer protection. The tool was built on a private sector listening framework, which was later transitioned to a public sector listening framework based on global approaches and practical lessons from diagnostics carried out at a central bank (consumer protection diagnostic) and a commercial bank (customer services diagnostic). The tool diagnoses the level of consumer listening maturity (i.e., basic, emerging, leader or advanced) based on three dimensions: 

  • Governance –the degree of internalization of a customer-centric listening culture within an authority, from strategy to policies and reporting;
  • Execution –the efficiency of consumer listening practices, including the management of consumer communications and consumer data;
  • Enablers –the adequacy of the channels, processes, people, tools and technologies used for consumer listening

Piloting the diagnostic tool: identifying strengths and weaknesses in financial consumer listening

The diagnostic tool was piloted at Indecopi and SBS using desk research and interviews with multiple teams. The authorities aimed to use the diagnostic tool to: (i) determine the current level of maturity reached by each institution’s listening systems, (ii) gauge if those systems could be easily integrated into one platform that pulled all gathered data and merged existing listening channels and procedures, and (iii) identify the level of interoperability of the current listening systems.

At an individual agency level, the diagnostic tool allowed each regulator to identify current strengths and weaknesses as well as paths to reach an enhanced state of consumer listening. For example, Indecopi’s Especial Monitoring Center (CEMI per its acronym in Spanish) and Innovation Lab stood out as good initiatives that have already started to adopt technology for better consumer listening and market monitoring. However, they still rely on manual processes that could be digitized or automated (e.g., using cloud processing, natural language processing for social media monitoring, artificial intelligence for labeling a conduct). Furthermore, these processes could be integrated with Indecopi’s complaints handling system (i.e., Pisac) to allow for a more comprehensive, customer-centric monitoring of consumer affairs. Similarly, the diagnostic helped identify SBS’ multi-channel initiatives to better capture the voice of consumers and visualize how SBS could better use technology and customer management tools they recently engaged (like Genesys) to increase the quality of their consumer listening processes and market monitoring activities.

At a consolidated level, the diagnostic showed that Indecopi and SBS’s current listening systems have a similar overall level of maturity (“emerging”), with common areas of improvement in each dimension (governance, execution, and enablers). For example, it showed that the consumer currently bears the burden of determining which authority they should submit a query or a complaint to, and that all consumers are served equally without considering their vulnerabilities (e.g., financial inclusion or digitization levels).

Thus, the diagnostic helped both authorities to better understand the importance of fully integrating the user experience into the design of a customer-centric listening system, and the crucial need for a new interoperable overall architecture, with a unique and simple customer journey. SBS and Indecopi are now well aware of the need to put consumers at the center of their processes and systems. This is especially true of vulnerable consumers that are difficult to reach due to lack of digital literacy, access to financial services, or their status as part of vulnerable populations (e.g., women, indigenous groups, people with disabilities, refugees).

The Peru pilot shows that the diagnostic tool can help a general consumer protection authority and a financial supervisor assess the maturity of their consumer listening mechanisms and develop a collaborative path forward to build an interoperable and customer-centric model.

Using the diagnostic tool as a baseline to enhance consumer listening in Peru

The diagnostic tool provided valuable insights to Indecopi and SBS on the common strengths and weaknesses of their current listening mechanisms. This baseline helped identify recommendations to achieve the common goal of building an integrated platform that will enable customer-centric market monitoring and enhanced financial consumer listening services and contribute to policy, regulatory and enforcement improvements:

  • Develop a single registration process for consumers to communicate with authorities (see Figure 2)
  • Incorporate technology to enhance consumer experience and facilitate capturing consumer voices and analyzing data (e.g., automating processes, creating APIs, building shared data management tools)
  • Foster close and frequent inter-institutional collaboration to develop interoperable processes,  ensure access to financial consumer data by both authorities, and enable the generation of differentiated analysis and reports, based on the different mandates of each authority. 
  • Build a 360-degree view of the consumer and their expectations and risks. This includes building consumer profiles and maintaining a consolidated database of all communications that consumers have raised with authorities and how they’ve been addressed. Profiles help authorities identify which segments (e.g., vulnerable groups) are not elevating their voice, and better leverage data to enhance the quality of their services. 

These recommendations will help authorities better understand the issues different types of consumers are facing at different parts of their journey and address those issues proactively, through monitoring, enforcement or regulatory improvement actions. 

In the coming weeks, we will provide further insights on the initial steps taken by the Peruvian authorities in this collaborative journey to achieve an interoperable consumer listening system.

Figure 2: “To-be” design of an integrated platform for financial consumer listening. Source: CGAP and Accenture LLP. “Analysis of Peru’s Financial Consumer Listening Mechanisms”, June 2022

Resources

Blog

How can low-income customers be better represented in financial policy making? Here are some opportunities for consumer associations, regulators and funders to make a difference.
Publication

Customer outcomes approaches are emerging as a promising consumer protection paradigm where the regulatory focus shifts from provider compliance with prescriptive check-the-box rules to customer results or outcomes achieved through provider actions.
Blog

The steps Peru has taken to ensure consumers have a strong voice in financial consumer protection regulation may be instructive for other countries working to protect vulnerable consumers.

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