Consumer Finance Protection

The cost of energy in the UK is broken. Did you know that even if you used zero gas and electricity, you'd pay ~ £300 a year! This is due to the way energy is priced. Consumers have to pay 2 charges: 1. A standing charge 2. A unit rate based on how much energy you use The trouble with having high-standing charges is that it punishes low-users and low-income vulnerable people. How? 1. A high standing charge reduces the incentive to use less energy as proportionately it won't affect your costs much. Here's a very *simplified* example to illustrate what I mean (the numbers are not real!). Imagine your standing charge was £100 and your unit costs were also £100. If you reduce your energy usage by half (£100 to £50), your total cost would still be £150, meaning you've only saved 25% despite using 50% less energy. 2. Plus this is really bad for low-income people including those on prepayment meters. Imagine that during the summer even though they're not using energy, the meter is still ticking for prepayment users pushing them into energy debt *before* the freezing winter months when they need to use energy. The good news is that Ofgem (the regulator) has finally launched a review into the standing charge in response to pressure from campaigners (the likes of Martin Lewis from MSE and co). What should be done? Standing rates should be lowered and the burden should be shifted to unit rates - the more you use, the more you should pay. Shout to MoneySavingExpert.com for bringing this to light. Photo by Stéphane Juban on Unsplash #personalfinance #energy #uk

𝐊𝐞𝐲 𝐩𝐨𝐢𝐧𝐭𝐬 𝐨𝐧 𝐃𝐢𝐠𝐢𝐭𝐚𝐥 𝐋𝐞𝐧𝐝𝐢𝐧𝐠 𝐃𝐢𝐫𝐞𝐜𝐭𝐢𝐨𝐧𝐬, 2025 𝐛𝐲 𝐑𝐁𝐈 These directions aren't just guidelines; they represent a strong commitment to building a transparent and secure digital credit ecosystem in India. This comprehensive framework puts: ✅ 𝑬𝒏𝒉𝒂𝒏𝒄𝒆𝒅 𝑩𝒐𝒓𝒓𝒐𝒘𝒆𝒓 𝑷𝒓𝒐𝒕𝒆𝒄𝒕𝒊𝒐𝒏: The directions prioritize borrower safety through mandated disclosures (like Key Fact Statement), cooling-off periods to exit loans without penalty, and clear grievance redressal channels. ✅ 𝐈𝐧𝐜𝐫𝐞𝐚𝐬𝐞𝐝 𝐀𝐜𝐜𝐨𝐮𝐧𝐭𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐟𝐨𝐫 𝐏𝐥𝐚𝐭𝐟𝐨𝐫𝐦𝐬: Regulated Entities (REs) are fully responsible for the digital lending activities carried out by their Lending Service Providers (LSPs), necessitating enhanced due diligence and oversight of these third parties. ✅ 𝑺𝒕𝒓𝒊𝒄𝒕 𝑫𝒂𝒕𝒂 𝒂𝒏𝒅 𝑻𝒆𝒄𝒉𝒏𝒐𝒍𝒐𝒈𝒚 𝑵𝒐𝒓𝒎𝒔: The regulations impose stringent rules on data collection (requiring explicit consent and limiting access to phone resources), data storage (mandating storage within India), and comprehensive privacy policies. ✅ 𝑻𝒓𝒂𝒏𝒔𝒑𝒂𝒓𝒆𝒏𝒄𝒚 𝒕𝒉𝒓𝒐𝒖𝒈𝒉 𝑫𝑳𝑨 𝑹𝒆𝒑𝒐𝒓𝒕𝒊𝒏𝒈: REs are required to report all Digital Lending Apps/Platforms (DLAs) they use or are associated with to the RBI, contributing to a centralized directory for increased transparency in the ecosystem. _______________________________________ Let me know in the comments what are your views about these directions?

𝐑𝐁𝐈 𝐃𝐢𝐠𝐢𝐭𝐚𝐥 𝐋𝐞𝐧𝐝𝐢𝐧𝐠 𝐃𝐢𝐫𝐞𝐜𝐭𝐢𝐨𝐧𝐬 2025! RBI recently released new guidelines to make digital lending safer, more transparent, and borrower-friendly. 𝐊𝐞𝐲 𝐎𝐛𝐣𝐞𝐜𝐭𝐢𝐯𝐞𝐬 → Combine all digital lending rules in one place. → Protect borrowers from data breaches and unauthorized lending apps. → Ensure a transparent and compliant digital lending environment. 𝐊𝐞𝐲 𝐔𝐩𝐝𝐚𝐭𝐞𝐬 𝐌𝐮𝐥𝐭𝐢-𝐋𝐞𝐧𝐝𝐞𝐫 𝐏𝐥𝐚𝐭𝐟𝐨𝐫𝐦𝐬: Transparency on loan offers, APR, and tenure. 𝐋𝐒𝐏 𝐃𝐞𝐟𝐢𝐧𝐢𝐭𝐢𝐨𝐧: Only digital lenders qualify. 𝐃𝐚𝐭𝐚 𝐋𝐨𝐜𝐚𝐥𝐢𝐳𝐚𝐭𝐢𝐨𝐧: Data must stay in India; delete foreign data in 24 hrs. 𝐆𝐫𝐢𝐞𝐯𝐚𝐧𝐜𝐞 𝐑𝐞𝐝𝐫𝐞𝐬𝐬𝐚𝐥: LSPs/REs must have complaint officers & online systems. 𝐂𝐨𝐨𝐥𝐢𝐧𝐠-𝐎𝐟𝐟 𝐏𝐞𝐫𝐢𝐨𝐝: Borrowers can exit loans penalty-free. 𝐃𝐋𝐀 𝐑𝐞𝐩𝐨𝐫𝐭𝐢𝐧𝐠: REs must report DLAs by June 15, 2025. 𝐂𝐚𝐬𝐡 𝐑𝐞𝐜𝐨𝐯𝐞𝐫𝐲: Fees paid by RE, not borrowers. These rules aim to protect borrowers, reduce fraud, and keep the lending ecosystem fair. GenZCFO NBFC Advisor #DigitalLending #RBIGuidelines #Compliance #FintechIndia #BorrowerProtection #FinanceUpdates

ASIC isn’t the only regulator speaking up on alleged cyber failures. Remember those superannuation incidents earlier this year where people lost money from their super? 💸 Now APRA is turning up the heat. Executive teams who fail to address cyber risk cannot rely on “I didn’t know” as an excuse. As APRA’s Margaret Cole put it, the safety and security of members’ retirement savings and personal data is non-negotiable — and failing to protect them poses an unacceptable threat to the entire superannuation system. And that means punishment for the boards and executives that ignore the clear and present danger of cyber attacks. This isn’t just about isolated breaches. It’s about whether boards and executives are governing cyber risks proactively, with the right structures, capabilities and accountabilities in place before an incident hits. 🔐 CPS 234 already sets the baseline: maintain information security capability, implement effective controls, and respond swiftly when things go wrong. 📊 CPS 230, coming into force from 1 July 2025, takes it a step further — requiring boards to govern operational resilience end-to-end. That includes having robust response playbooks for ransomware, strong oversight of third-party service providers, and tested business continuity plans to keep operations running through a crisis. These are no longer risks that can be deprioritised. Cyber-style incidents, like ransomware, data theft, or email compromise, are happening now and they demand real investment and consideration all the way through an organisation. And regulators are understandably expecting more than reactive clean-up. Super funds occupy a place of privilege and responsibility in our economy. They’re entrusted with safeguarding Australians’ retirement savings under a compulsory regime. That trust demands more than compliance — it demands leadership. And while this warning is aimed at super, the same will apply across all APRA-regulated entities, including banks and insurers. Govern it, or face the consequences. https://lnkd.in/gB952EBF #cybersecurity #superfunds #CPS230 #CPS234 #cyberresilience #ransomware #governance #datagovernance #risk #compliance #APRA #financialservices #databreach #cyberattack

The recent coordinated cyberattacks on major Australian superannuation funds, including AustralianSuper, Hostplus, Rest, and others, have exposed vulnerabilities in one of the nation's most critical financial sectors. With thousands of accounts compromised and members reportedly losing funds, this incident underscores the urgent need for enhanced cybersecurity measures across the $4 trillion superannuation industry. Why are Superannuation Funds prime targets? Australia's superannuation funds manage massive pools of financial and personal data, making them attractive to cybercriminals. The rising sophistication of attacks—often leveraging AI and advanced social engineering—means traditional defenses are no longer sufficient. 💡 Proactive Threat Monitoring: Funds like Commonwealth Superannuation Corporation (CSC) have started scouring the dark web for leaked member data, demonstrating the importance of proactive threat intelligence. 💡 Member Awareness: AustralianSuper's advice to members on securing their accounts highlights how critical user education is in preventing breaches. Simple steps like using unique passwords and enabling multi-factor authentication can make a big difference. 💡 Regulatory Accountability: APRA has already flagged gaps in cybersecurity compliance across the sector. This breach may accelerate enforcement actions, including capital overlays and stricter operational requirements for underperforming funds.

One of the most important institutions in Australia’s energy framework is the Australian Energy Market Commission (AEMC). This organisation writes the rules that the regulator is charged with enforcing. But just like Australian Energy Regulator and Australian Energy Market Operator (AEMO) this organisation bears some responsibility for allowing the Integrated System Plan (ISP) to become what it is today. Instead of facilitating a much needed critical review of the ISP, the AEMC has used their rule-making power to push their own review forward a couple of years, comfortably clear of the upcoming election. This move was uniformly opposed by everyone representing consumer interests, but was cheered on by the networks lobby, AEMO and the AER. If this wasn’t enough, it appears that the AEMC has actually broken the National Electricity Law to rush the change through, at the direct request of the current energy minister. Instead of running a proper consultation on the change, the request to defer the review was tucked into the folds of a larger rule change that was already advancing on a fast-track. How should we feel about a rule-making body that would break the law to rush through a rule-change that’s blatantly against the interest of consumers, and has clear short-term political benefits for the current government? As an entree in this video I also describe how the AEMC has paved a super-highway for corruption into the heart of the regulatory system, ensuring that there is never an reliable opportunity to review the ISP’s Optimal Development Path before it allows transmission companies to receive the necessary approvals for funding. And for dessert, I detail how the AEMC has abandoned the Terms of Reference for the Residential Electricity Price Trenda report, turning into fan-fiction for the ISP, repeating the most discredited assumptions that the ISP relies upon as though there’s nothing wrong. The trust is very badly broken indeed. https://lnkd.in/gqihPbHD

RBI's Digital Lending Directions 2025, released on May 8, 2025, set a new benchmark for transparency and borrower protection in India's digital lending ecosystem. Here are the key changes and their impact as I see: 1️⃣ Regulated Entity (RE)–Lending Service Provider (LSP) Arrangements with Multiple Lenders (Para 6 | Effective Nov 1, 2025) 𝗖𝗵𝗮𝗻𝗴𝗲: LSPs must display a digital view of all loan offers from multiple REs, including unmatched lenders’ names, with details like APR, loan amount, and KFS links. 𝗜𝗺𝗽𝗮𝗰𝘁: Enhances borrower choice and transparency but increases product development/operations and compliance costs on LSPs in the near term. 2️⃣ Reporting Digital Lending Applications (DLA) to RBI (Para 17 | Effective Jun 15, 2025) 𝗖𝗵𝗮𝗻𝗴𝗲: REs must report all DLAs (own or LSP-operated) on RBI’s CIMS portal, certified by the Chief Compliance Officer, with updates for new/ceased DLAs. 𝗜𝗺𝗽𝗮𝗰𝘁: Creates a public DLA directory, boosting transparency but adding reporting obligations. Missteps in certification could lead to regulatory scrutiny, urging REs to strengthen compliance frameworks. 3️⃣ Enhanced Due Diligence for LSPs (Para 5) 𝗖𝗵𝗮𝗻𝗴𝗲: REs must conduct thorough due diligence on LSPs’ technical capabilities, data privacy, and regulatory compliance before agreements. 𝗜𝗺𝗽𝗮𝗰𝘁: This strengthens risk management, and only serious LSPs will likely prevail, thereby making this a customer-centric and responsible market. 4️⃣ Data Storage in India (Para 13) 𝗖𝗵𝗮𝗻𝗴𝗲: All data must be stored in India; overseas processing data must return within 24 hours. 𝗜𝗺𝗽𝗮𝗰𝘁: Ensures data sovereignty but increases infrastructure costs for REs/LSPs with global operations. 5️⃣ DLG Cap and Structure (Paras 23, 21) 𝗖𝗵𝗮𝗻𝗴𝗲: DLG continues to be capped at 5% of disbursed portfolio; contracts must specify cover extent, form, and invocation timeline. 𝗜𝗺𝗽𝗮𝗰𝘁: Limits REs’ risk exposure and will deter smaller LSPs from offering DLG, which may be seen as dissuading smaller fintech companies, especially those where capital and portfolio risk management capabilities are not mature. 6️⃣ Disclosure of Recovery Agents (Para 8) 𝗖𝗵𝗮𝗻𝗴𝗲: REs must notify borrowers of recovery agent details via email/SMS before contact. 𝗜𝗺𝗽𝗮𝗰𝘁: Enhances borrower safety but requires RE–LSP to streamline communication systems for compliance. These changes signal RBI’s push for a safer, more transparent digital lending landscape that balances innovation with consumer protection. REs and LSPs must act swiftly to align by November 2025 and June 2025 deadlines. #DigitalLending #RBI #Fintech #Banking #NBFC

Australian super funds face an existential threat. Cyber attackers targeted our superannuation sector last week. They accessed member accounts, changed personal details, and attempted unauthorized withdrawals. Traditional security models failed us. The brutal reality: • Most super funds operate below banking security standards • Basic protective measures remain unimplemented • Member experience trumps security controls • Risk scoring rarely exists ACCOUNTABILITY MATTERS MORE THAN REGULATION Super fund trustees who ignore these risks will be held accountable for their negligence. We have enough regulations; we need action. Three immediate priorities: 1. PROCESS TRANSFORMATION Change verification requirements for high-risk transactions. Phone number updates combined with address changes should trigger enhanced verification automatically. Embed security within the customer journey 2. THREAT INTELLIGENCE Every super fund must join government intelligence-sharing platforms. Individual defences crumble against coordinated attacks. 3. AI INTEGRATION Artificial intelligence detects attack patterns faster than humans. It spots document fraud before the transaction process. The attacks will intensify. Super funds managing trillions require cutting-edge defences integrated into core business processes. Members want protection over convenience. They'll accept additional security steps knowing their life savings stay safe. WAKE UP CALL Those treating these attacks as isolated incidents risk an existential crisis of member confidence. The choice: Transform security now or explain why you didn't to members. Agree? I would love to hear your thoughts

Why a dedicated vulnerable customer team is rarely a good idea…and what to do instead 👇 It might sound like a positive step. A clear focus. A specialist team. But in reality, it often creates more problems than it solves. Here’s why: ➡️ It sends the message that vulnerability is someone else’s responsibility ➡️ With around 50% of customers likely to be vulnerable at any time, it’s not a niche issue ➡️ It increases the risk of a customers needs not being met as knowledge between specialists and non-specialists polarises. ➡️ It relies on identification of a vulnerability when not everyone will want to disclose it. So what’s the alternative? ✅ Build inclusive services from the ground up. ✅ Equip (not necessarily with training) everyone, customer facing or not, to understand and respond appropriately. ✅ Make vulnerability part of your culture, not a corner of your org chart. What’s your experience? Have you seen a dedicated team work well? Or have you run into these issues? Like this post? Save it 📥using the 3 dots above ↗️ Repost ♻️ to share with your network 🤝Connect with me to see more Follow #VulnerableCXbyCarolyn #vulnerablecustomers #InclusiveDesign

This document is the “Reserve Bank of India (Digital Lending) Directions, 2025,” issued by the Reserve Bank of India (RBI) on May 8, 2025. It serves as a comprehensive regulatory framework governing digital lending activities in India. Key Highlights: 1 Scope and Applicability: ◦Applies to all regulated entities (REs) including commercial banks, co-operative banks, non-banking financial companies (NBFCs), housing finance companies, and all-India financial institutions engaged in digital lending. ◦Effective immediately, with specific provisions (e.g., para 6 on multiple lender arrangements and para 17 on DLA reporting) to be implemented from November 1, 2025, and June 15, 2025, respectively. 2 Objectives: ◦Encourages innovation in digital credit delivery while mitigating risks related to third-party engagements and borrower exploitation. ◦Consolidates previous guidelines with new measures, such as regulations for Lending Service Providers (LSPs) partnering with multiple REs and the creation of a directory of digital lending apps (DLAs). 3 Structure: ◦The document is divided into seven chapters, covering preliminary definitions, general requirements for RE-LSP arrangements, conduct and customer protection, technology and data requirements, reporting obligations, default loss guarantee (DLG) arrangements, and general/repeal provisions. ◦Includes annexes with data submission formats (Annex I), illustrative examples (Annex II), and a list of repealed circulars (Annex III). 4 Key Provisions: ◦RE-LSP Arrangements: Mandates due diligence, contractual agreements, and oversight of LSPs, ensuring REs remain accountable for LSP actions. ◦Customer Protection: Requires assessment of borrower creditworthiness, transparent disclosures (e.g., Key Fact Statement), a cooling-off period for loan exits, and robust grievance redressal mechanisms. ◦Technology and Data: Enforces need-based data collection with borrower consent, data storage within India, and compliance with cybersecurity standards. ◦Reporting: Obliges REs to report lending activities to Credit Information Companies (CICs) and submit DLA details to the RBI’s Centralised Information Management System (CIMS) portal. ◦Default Loss Guarantee (DLG): Regulates arrangements where a third party compensates REs for loan defaults, with caps (e.g., 5% of the loan portfolio) and strict eligibility criteria for DLG providers. 5 Repeal of Previous Guidelines: ◦Replaces earlier circulars, such as those from June 24, 2020, September 2, 2022, and June 8, 2023, ensuring a unified regulatory approach. This framework reflects RBI’s efforts to balance technological advancement in lending with consumer protection and financial stability, effective as of May 10, 2025. #RBIDigitalLending #DigitalLending2025 #FintechIndia #BankingRegulations #ConsumerProtection #DataPrivacy #FinancialInclusion #NBFC #CybersecurityFintech #LendingInnovation