Good Practices: Banking Sector

TAJIKISTAN: Annex 1: Consumer Protection Issues in the Remittances Market

Introduction and Context

1. 
   Transparency of prices and other terms and features of remittance services is critical for a competitive, safe, and efficient remittance market. Remittance service providers (RSPs) should therefore be encouraged to provide information about their services in clear, understandable terms and in ways that allow this information to be accessed easily by consumers, so that consumers can make informed choices between different services and providers. Full information (transparency) on these services should include the total cost to the sender and receiver: that is, all fees paid on both the sending and receiving sides of any transaction, foreign exchange rates including the margins charged, and any other costs to the sender and/or receiver should be clearly disclosed. It is also important for RSPs to provide transparent, clear and accurate information on the maximum amount of time that it will take funds to move from sender to receiver for each type of transfer service, and the specific locations and operating hours of access points for services in both sending and receiving countries. Each RSP should clearly distinguish the specific terms and other characteristics of the different remittance services it makes available to the market—and spell out clearly the circumstances and conditions when terms on offer may vary. For example, it should be clear to the sender if the price or other aspects of the service vary according to how the receiver is paid (e.g., in cash or by crediting an account).
   
2. 
   Both remittance senders and receivers should have adequate protection of their rights as consumers including access to effective and affordable dispute-resolution procedures. Although many countries have working mechanisms to resolve domestic consumer disputes, the cross-border nature of remittances combined with cultural and language barriers can make such procedures complex and therefore out of reach for many remittance consumers. In the case of international remittance transfers, there may be significant gaps in protection of consumers in some markets, particularly where there is a lack of clarity about which national regulatory regime oversees the remittance activities of RSPs. Where appropriate, authorities may therefore wish to evaluate the adequacy of existing dispute-resolution procedures, national regulatory oversight of remittance services, and other consumer protection provisions in the context of remittance services.
   

The Remittances Market in Tajikistan

3. 
   Officially recorded remittance flows to Tajikistan were estimated at US$2.3 billion in 2010,¹⁶ boosted by economic recovery in Russia, the top remittance-sending economy. Expressing remittance inflows as a percentage of GDP, Tajikistan was the largest single country destination for remittances worldwide, receiving recorded remittances equivalent to 31 percent of GDP in 2011. Migrant remittances are a critical supplement to household incomes in Tajikistan, particularly those of the rural poor. Remittance inflows are also an important source of foreign exchange for Tajikistan, and they represent a largely untapped source of savings and investment for migrants and their families, which, if channeled into safe interest-earning financial instruments, could provide an important spur to Tajikistan’s development. According to the results of a survey of remittance recipients conducted in 2010 by the NBT,¹⁷ 87.4 percent of remittances were sourced from Russia, 4.8 percent from Kazakhstan, 2 percent from Uzbekistan, 1.3 percent from Kyrgyzstan, 1.7 percent from “other close foreign countries,” and the remaining 2.8 percent from “other far foreign countries.”
   
4. 
   The average total cost for international remittance transfers to Tajikistan is relatively low. For example, the cost is 2.0 percent for sending US$200 in the Russia-Tajikistan remittance corridor as of the first quarter of 2012, with Western Union (3.2 percent) at the higher end.¹⁸ Transfers in the Russia-Tajikistan corridor ranked third least costly worldwide of the 212 corridors tracked by the World Bank Remittance Prices Worldwide (RPW) database.
   
5. 
   Fees for international remittance transfers to Tajikistan are also relatively transparent. The vast majority of transfers between CIS countries are conducted in the same currency; that is, the sending and receiving currencies are the same (rouble-rouble; US dollar-US dollar). This reduces the average total cost as the foreign exchange margins are eliminated. Even in those cases where a foreign exchange transaction occurs to enable payout in local currency, participating banks indicated that they inform the remittance recipient of the exchange rate used in the payout (typically the daily spot rate) before he/she receives the money, and the exchange rate is typically printed on the transaction receipt when the recipient cashes out. No fee is charged to the remittance recipient by money transfer operators (MTOs), most banks, and other RSPs in Tajikistan. The remittance sender bears the entire cost of the transfer.
   
6. 
   Receiving international remittances through informal channels is less prevalent in Tajikistan than in many other developing countries, due to the competitive MTO transfer fees. The vast majority of remittance flows to Tajikistan are channeled cash-to-cash electronically through MTOs working with banks. Banks that provide remittance services typically have multiple partnership agreements with the MTOs that serve Tajikistan. A high level of public distrust of banks remains, however, two decades after the massive loss of savings that occurred with the dissolution of the USSR, and continues for a number of reasons, including a tendency of many banks, particularly when encountering liquidity problems, to require clients to wait hours or even days before being able to collect remittance proceeds and/or withdraw money from their accounts. Remittance recipients generally have more trust in MDOs than in banks. MDOs typically also have better physical access than most banks to remote rural areas where some of poorest recipients reside.
   
7. 
   Volumes transmitted via other formal channels are relatively small. Two other channels for remittances are wire transfers of money orders through almost 600 branches of Tajik Post, which has partnership agreements with MTOs Western Union and Migom, and through banks on an account-to-account basis. The microfinance organization (MFO) subsector in Tajikistan has been growing rapidly in the past few years. As of 2011, it geared just under one-third of its loans to the agriculture sector¹⁹ and it sought to reach potential rural clients by making services including financial literacy seminars available by vehicle to those residing in remote areas.²⁰ MFOs may be well placed to play a greater role in remittance delivery to clients in rural areas.
   
8. 
   Banks providing remittance services tend to assume credit and liquidity risks, disbursing funds to the beneficiary before they receive the funds from the sending bank or MTO. Each MTO serving the market has its own transfer system with its associated security and other risks, including risk of theft if a third party were to gain access to transaction PIN codes. A few banks indicated that there have been a few, infrequent cases where money sent via international remittance transfer has been temporarily “lost.”
   
9. 
   International remittance transfers through technologies such as payment cards, mobile phones, etc. are not yet commonly available, largely due to telecoms infrastructure impediments. This could change in the next few years, given that the use of electronic payment instruments and services in Tajikistan has been increasing recently, however, and a number of banks have been introducing debit, reloadable prepaid, and other payment card products, mainly for in-country transactions, particularly in urban areas.²¹
   

Legal and regulatory framework

10. 
    Because there is no specific mention of remittance transactions in existing laws or regulations that govern banks and consumer protection, it is unclear whether existing laws and regulations would apply to consumer protection issues that could arise in the case of remittance transfer services. For example, Article 55, “Protecting bank clients’ interests,” of the Law “on banks and bank activities” (May 2009) legally requires banks to inform their customers about the requirements associated with a transaction prior to the “credit service,” including service charges, interest rates, and “other additional costs to the client.” It is unclear, however, whether this article would apply to remittance transfer services, as it specifies only “credit service[s].” Similarly, to ensure that banks uphold pre-agreed terms of their contracts with customers, Article 55 states that a bank “has no right to unilaterally change… service charges and terms of contracts with customers, except as under contract with the customer.” Where there is a delay or error in transferring a customer’s funds to his account, Article 55 requires the bank to compensate the client for each day of delay in funds’ transfer to the account at the NBT refinancing rate. Again, because there is no specific mention of remittance transfer transactions, however, it is unclear whether delays in these transactions, including cash payout, would entitle the customer to some form of recompense. There is also uncertainty about whether the remittance transactions of MTOs and other nonbank RSPs would be covered by existing consumer protection laws and regulations. Although problems in the area of customer disputes were described by banks as nonexistent or infrequent, the lack of any standard, independent national regulations, mechanisms, and procedures to redress customer complaints related specifically to remittances, complemented by supervisory oversight, appears to be a shortcoming in providing adequate consumer protection.
    
11. 
    NBT “Regulations for Electronic Payments through the Payments System” (Resolution of the NBT Board No. 345 of 24 December 2009) establish the NBT as the owner and operator of Tajikistan’s payment system. This system transacts interbank payments through correspondent accounts held by the following institutions: the NBT, commercial banks, credit societies, MFOs, the Main Department of Central Treasury of the Ministry of Finance of Tajikistan, the Central Stock Exchange of Tajikistan, Interstate Bank in Moscow, and a branch of the Foreign Commercial Bank “Tijorat” of the Islamic Republic of Iran in Dushanbe.²² The NBT’s Settlement Center has responsibility for the security of information transmitted via the system and for timely processing and settlement.
    
12. 
    Under the Law of the Republic of Tajikistan "on banks and banking activities” of May 2009, the Department of Banking Supervision within the NBT grants banks in Tajikistan licenses to perform financial services including international remittance transfers and supervises bank operations. Under Article 20 of the Law “on microfinance organizations,” licensed microcredit deposit organizations (MDOs) are permitted to transact money transfers of customers, as well as provide microloans and other financial services. MTOs, which work in partnership with banks, currently have no direct reporting requirements to the NBT or other national authority in the country, however. The majority of MTOs are Russia-based, so they are supervised by the Russian authorities with no direct oversight in Tajikistan. Remittance services provided by MTOs in Tajikistan are regulated only inasmuch as their services are regulated through the NBT's oversight of the banks acting as their agents. The NBT does not regulate the contracts between banks and MTOs.
    
13. 
    Tajik Post’s remittance services are also not subject to oversight by the NBT or other national authority. Although it accounts for a small and falling share of the remittances market in Tajikistan, the lack of licensing requirements and direct regulatory oversight of Tajik Post’s remittance services, coupled with its financial difficulties, could pose risks to its customers. Moreover, having undergone several restructurings in terms of ministry oversight of its overall operations, the fluid and unclear regulatory and supervisory context poses financial, governance, and operational risks.
    
14. 
    A draft payment system law includes provisions that would formally grant the NBT the power to license all providers of payment services. Under this draft law, NBT would also oversee the specific criteria and procedures applied to the instruments and services they provide, providing for sanction and enforcement authority as warranted, and establish the duties of payment institutions towards customers for the use of new payment instruments (such as ATMs, payment cards, internet, and mobile phones).
    

Institutional arrangements

15. 
    Although not required in law or regulation, the NBT’s Department of Banking Supervision handles RSP customer complaints on issues related to remittance transactions as these relate to the role of banks. Under its current institutional structure, however, the NBT lacks adequate oversight and supervisory powers to monitor activities of MTOs and other nonbank RSPs. Thus, there are gaps in the supervisory institutional framework, in that the NBT does not directly oversee the remittance transfer services provided by MTOs, which are mainly Russian-based. These gaps produce potential vulnerabilities for MTOs’ customers (see also above).
    
16. 
    A draft payment systems law would provide the legal basis for effective NBT powers of oversight over MTOs and other RSPs, including sanction and enforcement authority. The draft law would formally grant the NBT the power to license providers of payment services, authorize payment and settlement systems, impose conditions on their activities, and establish the duties of payment institutions towards customers.
    

Business practices

17. 
    It is not clear whether the banking law protects customers against errors in remittance transfers. Article 55, “Protecting bank clients’ interests,” of the 2009 Law “on banks and bank activities” compels banks to compensate a customer in a case where there is a delay or error in transferring a customer’s funds to his account. Because the law does not specifically mention remittance transfer transactions as a type of “credit service,” however, it is unclear whether the law covers remittance transfer services.
    
18. 
    Each of the MTOs operating in Tajikistan has its own transfer system. Each system has its own security and other risks, including the risk that third party access to a PIN code could result in theft.
    
19. 
    Some business practices may be negatively affecting the use of financial services by remittance recipients. While transfer fees are relatively low and typically do not include hidden foreign-exchange fees, the limited practice (by at least one bank) of charging remittance recipients a fee for transferring remittance proceeds into the recipient’s bank account could encourage cash payout and provide some disincentive to further financial access of recipients.
    

Consumer disclosure

20. 
    There are weaknesses in the legal and regulatory framework and industry practices regarding disclosure of information to remittance customers. There is a lack of clear, mandatory, standard procedures for banks and other RSPs to follow in providing information to consumers on prices, terms, and other service features of electronic fund transfers and remittances.²³ Also, banks and MTOs currently focus their promotional and general information dissemination efforts for remittance and remittance-linked financial services on the sender (typically, migrants residing in Russia), rather than the recipient. In addition, there is currently no centralized, publicly available information source for comparative cost information on remittance transactions.
    

Dispute resolution mechanisms

21. 
    There is no formal out-of-court mechanism, such as an ombudsman service, that deals with consumer complaints or disputes related to remittance transfer services. The only formal external option is the court system, which can be costly, unpredictable, and time-consuming.
    
22. 
    Each MTO serving Tajikistan’s remittance market has its own customer care center, which handles dispute and grievance issues for remittance transfer service customers, should these emerge. Some banks indicated that they will, as a service to customers, liaise between the customer and MTO for communication purposes, if a dispute or problem arises—but are under no legal obligation to do so. Banks and other RSPs do not typically include information on how to make a customer complaint in promotional and/or other information disseminated to prospective or actual customers.
    
23. 
    None of the banks participating in discussions with World Bank staff as part of a remittances market assessment in 2011 indicated that they have a standard procedure for handling customer disputes. Tajik Post’s senior management also indicated that they handle customer disputes that emerge on an ad hoc basis, with no systematic procedure in place.
    

Recommendations

24. 
    Institutional arrangements. Expeditious passage of the draft payment system law would enable the NBT to effectively license all authorized providers of payment services, and it would formally endow the NBT with more comprehensive oversight and supervision of all RSPs’ procedures, activities, and instruments related to remittance services in Tajikistan. The current lack of direct supervisory oversight of MTOs’ activities in Tajikistan, in particular, could render banks and remittance customers vulnerable. The capacity of NBT for providing adequate oversight and supervision of MTOs may need further strengthening,²⁴ particularly if this subsector continues to increase rapidly. By maintaining an official list of all licensed RSPs that pass “fit and proper” (and other specified) licensing requirements, the NBT would further bolster consumer protection by improving public disclosure of the sector’s activities.
    
25. 
    Consumer disclosure. As the national regulator of and repository of information and data on remittance transactions, the NBT would be well placed to regularly publish and disseminate comparative price information on remittance transactions. Disseminating comparative fee information regularly through channels including newspapers circulated to potential recipients in Tajikistan and migrants in Russia, and posting and continuously updating this information regularly on the NBT website, could help maintain and further improve remittance market competitiveness. This would further increase transparency and boost public confidence in remittance and other financial services, and could further increase remittances sent through RSP channels.
    
26. 
    Public authorities, led by the NBT, should require banks and other RSPs to develop, and disseminate at remittance payout points, basic informational materials on their available remittance transfer and other financial services, with clearly presented information on typical transaction times, and other transparently presented information on costs and other terms of remittance transfer and remittance-linked financial services. This could help increase remittance recipients’ awareness of, and confidence in, financial services more broadly. It would also be important to ensure that these materials be developed to reach underbanked and unbanked people of lower financial literacy levels (see below).
    
27. 
    The NBT could raise awareness of the World Bank’s Remittance Prices Worldwide database²⁵, publish its data related to the cost of remittances sent to Tajikistan, and use the database as an example of the type of information that may be collected and published on the NBT’s website.
    
28. 
    Business practices. All MTOs providing transfer services in Tajikistan should be required to secure a license from the NBT and their activities in Tajikistan monitored on an ongoing basis.
    
29. 
    Strengthening NBT oversight of remittance services would improve consumer protection and confidence by enabling it to ensure all RSPs’ compliance with international financial reporting standards, rules on corporate governance, and risk management practices. It will also be important for the NBT to set and implement appropriate standards for MTOs serving Tajikistan’s market in the areas of AML/KYC, capital requirements, consumer information, and dispute resolution. This would help enhance the transparency and overall predictability and efficiency of Tajikistan’s regulatory framework for cross-border remittances. As well as strengthening their compliance with accounting and supervisory standards, banks should revise their operating policies to improve the quality of their customer service and the overall efficiency of their services (e.g., improving service delivery times, putting in place standard procedures for handling customer disputes, assuring customers that the confidentiality of their personal information will be maintained). This would also raise the trust of remittance recipients and other bank clients.
    
30. 
    Requiring that RSPs serving Tajikistan’s remittance market consolidate all fees associated with a transaction to render them payable by the sender upfront (rather than imposing some share of the cost on the recipient) would also further enhance transparency. At the least, the NBT could enhance consumer protection in this area by issuing rules on unfair imposition of fees and other unfair commercial practices and/or unfair contract terms.
    
31. 
    Dispute resolution. In the longer-term, the NBT, in collaboration with local banks and other RSPs, should establish a dedicated and independent ombudsman service—covering transactions related to remittances and all other personal financial services and products. This would give clarity to dispute resolution procedures, which is currently lacking, and enhance and facilitate overall consumer protection. Establishing an ombudsman service for consumer protection in remittance and other financial service transactions could also further increase public trust and confidence in financial institutions, assuming the ombudsman is implemented and operated effectively. In the meantime, the roles of the NBT and the Anti-Monopoly Agency (which is currently authorized to deal with all consumer protection issues) should be strengthened to be better able to address consumer protection in financial services.
    
32. 
    Banks and other providers of remittance services in Tajikistan should be required to improve their internal complaints handling procedures and mechanisms and to standardly include information on how to make a customer complaint (including a toll free phone number) in promotional and other information they disseminate about their services. Consumer protection could also be enhanced by implementing a NBT Department of Monetary Policy and Statistics proposal²⁶ that banks and other RSPs make available a “hotline”/toll free number and complaint boxes in their branches and outlets to provide customers recourse in the event that employees ask for additional charges or unofficial payments in the course of carrying out transactions.
    
33. 
    Financial education. Banks must do more to raise awareness about how remittance and other financial services work. Public authorities, led by the NBT, should motivate RSPs to develop relevant financial literacy materials and gear more of their information dissemination directly to remittance recipients, which could help increase their awareness of, and confidence in, financial services more broadly.
    
34. 
    Banks face the challenge that, even where they develop and raise awareness of innovative savings instruments geared to remittance recipients in underserved populations, they must take steps to address the legacy of public distrust. Such steps must involve changing their business practices including improving their customer service (see above), the overall efficiency of their banking services, and forms of outreach that they provide to this market; and strengthening their compliance with financial standards.
    
35. 
    With more than 70 percent of remittance recipients in Tajikistan residing in rural areas, there is a particular need to improve outreach to increase this population’s access to remittance and other financial services. Microcredit deposit organizations (MDOs) may be well placed for a greater role in remittance delivery to these recipients, having both access to them and typically being more trusted than banks. However, MDOs are at a relative disadvantage to banks in that they typically are less adept at marketing and disseminating information about their services, tending to attract new deposits mainly through informal channels such as word-of-mouth referrals by existing clients.
    
36. 
    Awareness campaigns supported by the NBT that provide for a core financial literacy component about banks’ and other RSPs’ financial services—made available at remittance payout points and perhaps supplemented by individual RSPs with incentives to attract remittance recipients—could increase access of these customers to formal financial services. This may also further reduce and maintain low transfer costs. Banks should also do more to increase awareness of debit/prepaid cards and ATMs outside urban areas of Tajikistan.
    
37. 
    Analysis of Good Practice on Electronic Fund and Remittances from the angle of RSPs:
    

Good Practice	Electronic Fund Transfers and Remittances There should be clear rules on the rights, liabilities and responsibilities of the parties involved in any electronic fund transfer. Banks should provide information to consumers on prices and service features of electronic fund transfers and remittances in easily accessible and understandable forms. As far as possible, this information should include: the total price (e.g. fees for the sender and the receiver, foreign exchange rates and other costs); the time it will take the funds to reach the receiver; the locations of the access points for sender and receiver; and the terms and conditions of electronic fund transfer services that apply to the customer. To ensure transparency, it should be made clear to the sender if the price or other aspects of the service vary according to different circumstances, and the bank should disclose this information without imposing any requirements on the consumer. A bank that sends or receives an electronic fund transfer or remittance should document all essential information regarding the transfer and make this available to the customer who sends or receives the transfer or remittance without charge and on demand. There should be clear, publicly available and easily applicable procedures in cases of errors and fraud in respect of electronic fund transfers and remittances. A customer should be informed of the terms and conditions of the use of credit/debit cards outside the country, including the foreign transaction fees and foreign exchange rates that may be applicable.
Description	The NBT regulates and supervises the systems for clearing inter-bank payment transactions under NBT “Regulations for Electronic Payments through the Payments System (No. 345 of December 2009). There is no legislation yet in place, however, that deals with electronic payments and provides clear rules on the rights, liabilities and responsibilities of the parties involved in any electronic fund transfer. Inbound international remittances sent via electronic fund transfers provided by MTOs, which tend to be Russia-based, are only supervised indirectly, through NBT oversight of banks acting as their agents. Financial innovations linking remittance transfers to electronic payment instruments such as debit/prepaid cards are being introduced for in-country, non-migrant remittance transactions, particularly in urban areas—but they are not yet commonly used for international transfers by Tajik migrants. There is a draft payments system law that would cover electronic payments. Passage of this draft law would enable the NBT to effectively license all authorized RSPs and would strengthen consumer protection by formally endowing the NBT with more comprehensive oversight and supervision of all RSPs’ procedures, activities, and services related to remittance services. There is a lack of clear, mandatory, standard procedures for banks and other remittance service providers (RSPs) to follow in providing information to consumers on prices, terms, and other service features of electronic fund transfers and remittances. Article 55, “Protecting bank clients’ interests,” of the 2009 NBT “Law on banks and bank activities” legally requires banks to inform their customers about the requirements associated with a transaction prior to the “credit service,” including service charges, interest rates, and other additional costs to the client.” Where there is a delay or error in transferring a customer’s funds to his account, Article 55 also requires the bank to compensate the client for each day of delay in funds’ transfer to the account at the NBT refinancing rate. It is unclear, however, whether Article 55 would apply to remittance transfer services, as it specifies only “credit service[s]” and includes no specific mention of remittance transfer transactions. It is thus also unclear whether delays in these transactions, including cash payout, would entitle the customer to some form of recompense. Banks and the largely Russia-based MTOs currently focus their promotional and general information dissemination efforts for remittance transfer services on the senders (based overseas), rather than the Tajikistan-based recipients. The extent to which most banks are reaching out to communicate fees and other terms of remittance services to the remittance recipients, through promotional material and other channels, is unclear. A few participating banks (e.g., AIB and Tojiksodorot) indicated that they make available to customers information about remittance transfer prices and other terms through brochures or pamphlets circulated in the local areas in Tajikistan where they have branches or other outlets, along with advertising their remittance transfer and financial services on their websites. One of the banks further indicated that it advertises customer service telephone numbers, in ads that it runs periodically in newspapers and on promotional pocket calculators, which potential customers in Tajikistan may phone to obtain information about costs and other terms of its remittance transfer services. As reported by the NBT, individual commercial banks in Tajikistan are expected to provide information on prices and other aspects of remittance services to the public in the course of offering these services. However, the banks with which the senders initiate the transaction do not follow a standardized mechanism for providing this information to the senders themselves. The majority of senders are located in Russia, where the services provided by banks and other RSPs would be governed by Russian financial market authorities. Participating banks indicated to a World Bank-FIRST Initiative mission team in 2011 that they inform the remittance recipient of the transaction fee and exchange rate used in the payout (typically the daily spot rate) before he/she receives the money. The exchange rate and fee for the transaction also are typically printed on the transaction receipt when the recipient cashes out. Fees for international remittance transfers to Tajikistan are relatively transparent because the vast majority of transfers between CIS countries (where the vast majority of senders reside) are conducted in the same currency. Because there is no specific mention of remittance transfer transactions in existing laws and regulations that govern banks and consumer protection (such as the NBT “Law on banks and bank activities”), it is unclear whether more generic provisions in laws and regulations would apply to cases of error, fraud and other consumer protection issues that could arise in the case of international remittance transfer services. For example, under Article 55 of the NBT “Law on banks and bank activities,” banks are obliged to compensate a customer in a case where there is a delay or error in transferring a customer’s funds to his account for all “credit service” transactions. Because this law does not specifically mention remittance transfer transactions as a type of “credit service,” its applicability to remittance services is unclear. The use of credit/debit cards by senders outside the country in the transfer of remittances to recipients in Tajikistan is not yet common. Debit/prepaid cards are being introduced for in-country, non-migrant remittance transactions, particularly in urban areas—but improvements to payment infrastructure in Tajikistan would be needed before these financial innovations could be rolled out on a large scale for efficient and cost-effective remittance transfer transactions.^27
Recommendation	There is a need for clear rules on the rights, liabilities and responsibilities of the parties involved in any electronic fund transfer. Tajikistan’s national authorities are urged to expedite passage of the draft payment system law, which would enable the NBT to license all authorized providers of electronic payment services; oversee the specific criteria and procedures applied to the services that they provide; and establish the duties of payment institutions towards customers for the use of new payment instruments for transactions (including ATMs, payment cards, internet, and mobile phones). Formally endowing the NBT with more comprehensive oversight and supervision of nonbank RSPs’ procedures, activities, and instruments under this draft law would level the playing field by providing direct supervisory oversight of all RSPs and could therefore render banks as well as remittance customers somewhat less vulnerable. Public authorities, led by the NBT, should also require by law that banks and other RSPs develop, and disseminate at remittance payout points, clearly presented information on prices, transaction times, terms and conditions, and other service features of electronic fund transfers and remittances in easily accessible, transparent and understandable forms. This information should include all matters referred to in i. through iv. of item b. of this Good Practice. In addition, if the price, transaction times, or other aspects of the service vary according to different circumstances, banks, MTOs and other RSPs should be obliged by law to disclose this information without imposing any requirements on the consumer. Also, an RSP that sends or receives an electronic fund transfer or remittance should be compelled to document all essential information regarding the transfer and make this available on demand and without charge to the customer who sends or receives the transfer. Furthermore, there should be clear, publicly available and easily applicable procedures in cases of errors and fraud in respect of electronic fund transfers and remittances. In the longer term, an effective ombudsman service established by the NBT in collaboration with local market players—covering transactions related to all personal financial services including electronic transfers and remittances—would give clarity to dispute resolution procedures and enhance overall consumer protection. In the meantime, the NBT and the Anti-Monopoly Agency, which is currently authorized to deal with all consumer protection issues, should be strengthened to be better able to address consumer protection in financial services. And finally, a customer should be informed by the card-issuing bank of the terms and conditions of the use of any credit/debit cards outside Tajikistan, including the foreign transaction fees and foreign exchange rates that may be applicable.