Chapter One: Instructions for Protecting Bank Customers' Rights

In the context of the Central Bank of Egypt's interest in developing the banking sector by applying international best practices, which emphasize the importance of protecting bank customers' rights to consolidate the confidence of market participants in the banking sector and enhance competition among banks, thereby raising the efficiency of the banking sector as a whole. The concept of protecting customers' rights includes having clear foundations and rules governing the relationship between banks and their customers at all stages of interaction, ensuring justice and transparency, and guaranteeing the protection of customer data, in addition to specifying a clear mechanism for handling complaints, as well as raising banking and financial awareness and culture among customers.

Given that protecting customers' rights is considered one of the main elements for achieving financial inclusion, which is one of the current priorities of the Central Bank of Egypt, due to its effective role in enhancing financial stability and achieving sustainable development, it has become necessary to issue instructions to protect bank customers' rights aimed at establishing the policies and internal procedures that banks must have, and the principles of dealing with customers while considering providing suitable products and services for them that match their requirements and their ability to fulfill the resulting obligations, which leads to encouraging individuals and increasing their interest in using banking services.

1. Concept of Protecting Bank Customers' Rights and Key Definitions:

The general concept of protecting bank customers' rights according to international best practices refers to a clear regulatory framework that defines the relationship between banking service providers and their users, to ensure that customers receive their rights in terms of justice, transparency, and maintaining data confidentiality, with the guarantee of having a mechanism for handling complaints. In addition to raising banking awareness among customers, enabling them to make sound decisions.

We list below the definitions of the most important terms mentioned in the instructions:

1-1 Customers: Refers to natural and legal persons who deal directly with the banking sector or through payment service providers and their agents, or those represented by them from outsourcing companies.

1-2 Outsourcing Companies: Entities that the bank contracts with and entrusts with providing any service or product on its behalf.

1-3 Service Providers: Entities that the bank contracts with to provide payment services using mobile phones according to the controls issued by the Central Bank of Egypt in this regard.

1-4 Loans and Credit Facilities: Loans and facilities granted to natural and legal persons.

1-5 Return Rates: Are the actual annual return rates according to the provisions of the Central Bank Law.

1-6 Financially Excluded Categories: Divided into:

• Customers outside the scope of banking sector services.
• Customers registered in the banking sector but do not use the service or product offered to them.

1-7 Guarantor: Is the person (natural/legal) who provides a guarantee (personal/real) against financing or a credit facility granted to a customer.

1-8 Customer Rights Protection Unit: A separate unit in the bank or with the service provider specialized in dealing with customer complaints, and it is subordinate to and reports to the Compliance Department.

2. Scope of Application

These instructions apply to all banking services and products provided by all banks registered with the Central Bank of Egypt, including branches of foreign banks.

3. General Rules

3-1 The Board of Directors of the bank must ensure that the policies, procedures, and systems in operation fully comply with the instructions for protecting customers' rights, and ensure that all bank employees comply with them, and that the policies and procedures of payment service providers or their agents or those represented by them from outsourcing companies comply with the instructions through contracts concluded with them, which must include at a minimum the following:

1-3-1 Product and Service Design and Pricing: 1-1-3-1 Determining the categories of targeted customers and the suitable products and services for each category.

2-1-3-1 Dividing customers into categories and segments based on income, educational level, geographic distribution, and age groups, and giving due care to the needs of excluded financial categories, the elderly, and people with special needs, with innovating and designing various products and services to suit all customer segments.

2-3-1 Ensuring that specialized employees in the bank - as well as employees of payment service providers or their agents or those represented by them from outsourcing companies - understand the characteristics, conditions, and costs of products and services, enabling them to explain them and answer customer inquiries.

3-3-1 Ensuring that the terms and conditions of products and services are drafted clearly and understandably for all customer categories and segments.

3-2 The Compliance Department in the bank must ensure the application of systems and work procedures that ensure compliance with what is stated in these instructions and prepare periodic follow-up reports on this matter and submit them to the Audit Committee for presentation to the Board of Directors.

3-3 In the event that payment service providers or their agents or those represented by them from outsourcing companies provide any product or service on behalf of the bank, whether directly or indirectly, customers must be treated with justice and transparency, and the bank bears full responsibility for the results of providing that service and for any damage that may be caused to the customer as a result thereof.

4-3 Strengthening the role of the Customer Rights Protection Unit by the Board of Directors, through providing the necessary mechanisms and means to resolve complaints as quickly as possible.

4. Rules for Protecting Bank Customers' Rights

1. Dealing with Customers on the Principle of Justice and Fairness

1-4-1 Emphasizing that the culture of the bank and payment service providers or their agents or those represented by them from outsourcing companies includes dealing with customers with high professionalism characterized by justice and transparency.

2-4-1 The bank and payment service providers or their agents or those represented by them from outsourcing companies must treat all customers at all stages of banking transactions without discrimination and on the principle of justice, fairness, and honesty.

3-4-1 Presenting the terms and conditions of products and services when marketing them transparently, and in accordance with the bank's presentation of the product or service to the customer before or at the time of purchase.

4-4-1 Measuring the customer's financial ability to fulfill all obligations, including installments, commissions, and any other additional expenses the customer may incur.

5-4-1 The bank and payment service providers or their agents or those represented by them from outsourcing companies must assist the customer in choosing the suitable service or product that matches their needs and their ability to fulfill the resulting obligations, without forcing the customer to buy a group of products to obtain a specific product.

6-4-1 In the event that a product or service cannot be provided to the customer, they have the right to know the reasons for rejection - if possible - and in a manner that does not conflict with relevant laws, and they have the right to retrieve the original documents they submitted when requesting the banking product or service.

7-4-1 The bank and payment service providers or their agents or those represented by them from outsourcing companies must clarify the method of canceling the service or product, the time required for that, and the expenses and deductions resulting from it.

8-4-1 The bank and payment service providers or their agents or those represented by them must commit to using fair, non-complex contracts/forms, with readable and clear wording that defines the rights and obligations of the bank, the service provider, and the customer, including all terms and conditions of the product or service, using simplified banking terms, and committing to including the following clauses at a minimum:

1-8-4-1 Data of the bank, or payment service providers or their agents or those represented by them (in case of signing directly with the customer), and the customer.

2-8-4-1 Contract duration.

3-8-4-1 Return rates used, specifying whether they are variable or fixed.

4-8-4-1 All expenses and commissions applied to the product, considering specifying a suitable mechanism that ensures the customer is aware in advance in case of any modifications to them.

5-8-4-1 Expenses and deductions applied by the bank in case the customer wishes to transfer the account or close it, or stop dealing with the product or service subject to the contract.

6-8-4-1 Procedures that the customer must follow in the event of tampering with their accounts, theft, or loss of banking cards, specifying the responsibility of each party in these cases.

7-8-4-1 The language and means of communication through which communication with the customer will be conducted.

8-8-4-1 A summary of the procedures taken by the bank in the event of non-payment in the specified deadlines or breach of any clause of the concluded contract, and the consequences thereof, as well as all additional costs associated with them, including commissions, interest, fees, etc.

9-8-4-1 Indicating the possibility of escalating the complaint to the Central Bank of Egypt in case it is not resolved by the bank.

9-4-1 In all cases, contracts/forms must not include unfair clauses that may cause harm to the customer in the following manner:

1-9-4-1 Omitting or modifying any obligation stipulated in these instructions.

2-9-4-1 Obliging the customer to any conditions not included in the contract clauses.

3-9-4-1 Excluding any condition mentioned or promoted to the customer, including advertisements and conversations with customer service.

4-9-4-1 Automatic renewal of the contract without obtaining prior consent from the customer or without notifying them in advance and giving them a time limit to cancel the renewal (except for products whose nature necessitates automatic renewal).

5-9-4-1 Preventing the customer from canceling the product or service, while retaining the bank's right to obtain any dues it is entitled to from the customer according to the contract terms.

6-9-4-1 Limiting the customer's right to set off or settle their accounts, except in cases where the product conditions require not disposing of the amounts related to it for a specific period.

The customer also has the right to review the contract before contracting and obtain a copy of it at any time before contracting.

10-4-1 In the event of card theft or account tampering and after notifying the bank thereof, the bank must refund any amounts/expenses that were deducted, unless it is proven from the bank's or service provider's systems and records that the transaction was carried out with the customer's consent or through their deception.

11-4-1 In the event that the customer is asked to provide guarantees for granted facilities, the size of the required guarantees must be proportional to the size of the granted facilities.

12-4-1 In the event that there is a guarantor for the customer, the following must be followed:

1-12-4-1 Informing the guarantor of the obligations resulting from providing the guarantee, including the size of the financial commitment.

2-12-4-1 Obtaining a commitment from the guarantor to maintain the confidentiality of the customer's information and obtaining the customer's consent to disclose that information to the guarantor.

3-12-4-1 Providing the guarantor with a copy of the contract upon request.

4-12-4-1 Notifying the guarantor in a timely manner in the event of any signs of default or breach by the customer regarding their obligations related to the guaranteed facility only, and the consequences thereof.

5-12-4-1 Notifying the guarantor before listing them as an irregular customer with both the Central Bank and the Egyptian Credit Bureau (Score-I).

13-4-1 The customer shall not be asked for expenses or commissions (including expenses and commissions of outsourcing companies) that apply to any of the following conditions:

1-13-4-1 They were not included in the contract clauses.

2-13-4-1 Expenses or commissions for banking services or products that were not activated.

3-13-4-1 Expenses resulting from electronic services if the customer was not notified of them before executing the transaction, allowing them the freedom to choose whether to complete it or not. (For example: ATM transactions).

14-4-1 The customer has the right to cancel their request for any banking product/service that has not been activated (except for savings products) within two working days from the date of signing the contract without imposing any expenses or fines.

15-4-1 In the event of canceling any product or service, the bank and payment service providers or their agents or those represented by them must do the following:

1-15-4-1 Paying the amounts due to the customer - including any accrued returns, if any.

2-15-4-1 Not retaining any amounts previously collected for a product/service that the bank did not provide - if any.

3-15-4-1 Canceling any standing instructions made through direct debit from the account to pay obligations resulting from the stopped product or service.

16-4-1 In the event of payment (whether full or partial), the bank must not exaggerate in imposing expenses or fines, and specify them based on the actual cost incurred by the bank resulting from the cancellation of the contract.

17-4-1 In the event that the customer pays off their debt in full, the bank must notify the Egyptian Credit Bureau (Score-I) of the completion of the debt, as well as provide the customer with checks signed by them - if any - and a clearance from the bank, which must include at a minimum the following data:

1-17-4-1 Customer data.

2-17-4-1 The facility account number at the bank.

3-17-4-1 The type of facility.

4-17-4-1 The payment date.

5-17-4-1 The nature of the payment. (Full payment / Payment within the framework of settlement / Settlement with the bank and the bank waives part of its dues).

2. Disclosure and Transparency

1-2-4 The bank must disclose actual annual return rates and banking service prices in customer reception halls at its headquarters and branches, or on its website, or in various media, or in private correspondence and newsletters sent to customers, in accordance with what is stated in the Central Bank, Banking, and Monetary Authority Law in this regard.

2-2-4 All rules and provisions related to all banking services must be available on the bank's website.

3-2-4 When the bank markets or advertises its products, it must use simple and understandable language for the general public and avoid complex or unclear terms.

4-2-4 The bank and payment service providers or their agents must provide the customer with sufficient, clear, and non-misleading information before contracting, making them fully aware of the terms, characteristics, and costs of the product or service.

5-2-4 In the event that the bank deals with outsourcing companies or payment service providers or their agents regarding products or services provided to the customer, the bank must inform the customer that the bank bears full responsibility for all services provided by those companies.

6-2-4 In the case of a fixed return rate for credit facilities, the bank is not allowed to modify it without obtaining the customer's consent.

7-2-4 The customer must be notified according to the mechanism agreed upon in the contract of any changes in the return rate - in the case of a variable return rate for credit facilities - or fees or agreed expenses and the impact of that on the conditions of the granted facility.

8-2-4 The bank and payment service providers or their agents must notify the customer of an account statement according to the provisions of the law, and the account statement must include at a minimum the following:

1-8-2-4 All customer transactions carried out during the period, including the balance at the beginning and end of the statement period.

2-8-2-4 What was credited to the account in terms of returns, expenses, and fees (if any).

3-8-2-4 The deadline required to approve the account statement.

In addition to the above, the bank must commit to disclosing the following clauses in the event of issuing account statements for credit cards:

4-8-2-4 The granted credit limit.

5-8-2-4 The current balance.

6-8-2-4 The minimum payment.

7-8-2-4 The payment due date.

8-8-2-4 Total accrued interest.

9-8-2-4 The number of days of delay.

9-2-4 In the event that the customer objects to the data sent by the bank, before the end of the period stipulated according to the provisions of the Central Bank, Banking, and Monetary Authority Law, the matter must be investigated and corrective procedures taken if necessary within a period not exceeding fifteen working days from the date of the customer's objection, except for objections related to transactions with external parties, where investigating them may take a longer period.

10-2-4 In the event that the customer requests any detailed data about their accounts or about any transactions carried out during the last five years at the latest or according to the bank's procedures in this regard, the bank must provide the customer with their request within ten working days at the latest, and this applies to customers who have stopped dealing with the bank or service provider.

11-2-4 In the event of the customer's default according to the terms of the contract, the bank or service provider must take the following:

1-11-2-1 Providing the necessary advice and counseling to the customer at this stage.

2-11-2-1 Giving the customer sufficient information about their rights and obligations.

3-11-2-1 Considering that the repayment period is suitable for the customer's circumstances under the study prepared for them in the event of restructuring or settlement.

4-11-2-1 Notifying the customer of all procedures that will be taken in the event of non-payment.

12-2-4 The bank should announce in advance the plans related to the operation and alternatives available to customers in sufficient time, for example:

1-12-2-1 Procedures that may lead to the disruption of providing any services.

2-12-2-1 Terminating some banking services.

3-12-2-1 Closing or relocating any of the branches.

3. Mechanism for Dealing with Customer Complaints

The bank must apply policies and procedures that ensure providing a fast and free mechanism for dealing with customer complaints fairly, transparently, and effectively, which must include at a minimum the following procedures:

1-3-3 Creating a separate unit in the bank specialized in dealing with customer complaints under the name "Customer Rights Protection Unit," equipped with qualified human resources (for example, banking, legal expertise, etc.), and it is subordinate to and reports to the Compliance Department in the bank, with including in the bank's internal policy and the unit's work procedures the right to access files, records, and transactions of customers with complaints.

2-3-3 The decisions of the Customer Rights Protection Unit in the bank are binding on electronic payment service providers and outsourcing companies, and this must be stipulated in the contracts concluded with them.

3-3-3 Preparing a unified internal form for customer complaints made available at branches, with agents, or through the bank's and payment service providers' websites, which must include at a minimum the following:

1-3-3-3 Date of submitting the complaint.

2-3-3-3 Customer data, including ID number and means of contact.

3-3-3-3 Summary of the complaint.

4-3-3-3 The department concerned with the complaint.

5-3-3-3 Attaching any documents related to the complaint.

In all cases, the bank and payment service providers must consider any complaint submitted, even if the mentioned form is not used or if it is submitted directly to the bank.

4-3-3 Informing customers about the mechanism for submitting and following up on complaints, through printed materials, informational boards, or electronic messages via email or mobile phone, or including in correspondence and account statements sent to customers the means of communication with the bank's Customer Rights Protection Unit.

5-3-3 Providing means for submitting complaints as follows at a minimum:

1-5-3-3 A complaint box at branches, and the compliance officer or their deputy at the branch opens the box daily and sends complaints to the specialized Customer Rights Protection Unit to register and examine the complaint.

2-5-3-3 Electronic means, such as fax, email, or website, with the complaint being registered at the latest on the next working day.

3-5-3-3 A phone number, with the complaint being recorded on a recorded line or in writing, and notifying the customer thereof.

4-5-3-3 Through the customer's direct contact with the Customer Rights Protection Unit.

6-3-3 Providing the customer with a reference number within two working days from the date of registering the complaint to enable them to follow it up easily, with the possibility of following it up through the bank's or payment service provider's website or by phone.

7-3-3 Banks must inform their customers that they cannot submit their complaints directly to the Central Bank of Egypt before referring to the concerned bank first.

8-3-3 The customer's complaint must be responded to within a period not exceeding fifteen working days from the date of receipt (except for complaints related to transactions with external parties, with the customer must be notified of the time required to study the complaint). The Unit responds to the complaint in writing or electronically, including appropriate justifications or corrective procedures, if any.

9-3-3 The concerned departments must take corrective procedures and verify the non-existence of similar cases.

10-3-3 The customer may escalate the complaint to the Central Bank in the event of no response to their complaint within the stipulated period.

11-3-3 In the event that the customer does not accept the bank's or service provider's response, they must notify the bank or service provider in writing within fifteen working days from the date of receiving the response, including the reasons for non-acceptance, and in the event that they do not do so, it is considered implicit acceptance.

12-3-3 In the event of notifying the bank or service provider of non-acceptance of the response, the bank must reconsider and examine the complaint with appropriate justifications again, and respond to the customer finally within fifteen working days, accompanied by clear justifications, especially if the response has not changed, and notify the customer of their right to escalate the complaint to the Central Bank of Egypt in the event of the customer not accepting the bank's second response.

13-3-3 The bank's Customer Rights Protection Unit submits periodic reports on its work through the Compliance Department to the Audit Committee and the Board of Directors, such that these reports are considered a means to access the customers' opinion and work on improving performance, and the reports must include at a minimum the following:

1-13-3-3 The number of complaints, their nature, and classification according to the nature of the customer (individual/company), gender (male/female), age, and geographic location.

2-13-3-3 The procedures taken regarding the complaints.

3-13-3-3 Complaints that have been closed.

4-13-3-3 The reasons or systemic problems that led to the appearance of complaints, and the procedures taken regarding them.

14-3-3 The Unit must analyze the submitted reports to determine the reasons and problems that led to the appearance of complaints, take corrective procedures regarding them, and recommend studying the situations of other customers to verify the non-occurrence of similar violations or problems.

15-3-3 The Audit Committee and the Board of Directors of the bank must consider the procedures proposed by the Complaints Unit and supervise their implementation in case of approval.

16-3-3 The bank must provide the Central Bank of Egypt with a quarterly report on customer complaints according to the form prepared by the Central Bank of Egypt for this purpose, including at a minimum the following:

1-16-3-3 The number of complaints, the procedures taken regarding them, and the consequences thereof.

2-16-3-3 An analysis of the nature of the submitted complaints.

17-3-3 The bank must keep records of all complaints so that they can be easily referred to if necessary, for a period of five years from their submission at a minimum.

4. Disseminating Banking and Financial Culture

1-4-4 The bank and payment service providers must be interested in disseminating banking culture among customers, through simplified informational brochures and communicating with customers to introduce banking services and products. The bank must also inform the customer of their rights and obligations, which include at a minimum the following:

1-1-4-4 Clarifying how to use the bank's services and products, and raising awareness of how to use debit cards and bank accounts according to the terms and conditions.

2-1-4-4 Clarifying the consequences of non-regularity in payment for credit customers and what may result from negative effects on their dealings with banks and payment service providers (for example: listing on negative lists).

3-1-4-4 Raising awareness of fraud and forgery operations that accounts may be exposed to and how to deal with them.

4-1-4-4 The importance of reading contracts.

5-1-4-4 The importance of providing accurate and clear information to the bank or payment service providers that enable them to provide suitable services and products for the customer.

6-1-4-4 Not disclosing any confidential information about accounts to any other party, and taking all necessary measures to maintain the security of debit or credit cards, as well as the username and password.

7-1-4-4 The importance of updating personal data with dealing banks, including residential and work addresses, email, and phone number.

8-1-4-4 The necessity of notifying the bank or service provider immediately and without delay upon realizing any transaction involving theft, embezzlement, account tampering, or unauthorized deductions from the customer on debit or credit cards.

In the event that the customer does not comply with the provisions mentioned above, the customer bears full responsibility for any transactions carried out without their consent and the resulting commissions and expenses.

2-4-4 The bank and payment service providers must work on developing the professional performance of their employees, especially those who have direct contact with customers, and strengthening the principles of protecting customers' rights must include the following:

1-2-4-4 Training employees on the rules for protecting customers' rights, and following up on their effective and continuous application.

2-2-4-4 Training employees on providing banking products and services, including evaluating the suitability of their needs for customers and the ability to meet all resulting obligations.

3-2-4-4 Providing specialized training programs, whether internal or external, for employees concerned with dealing with customer complaints in banks.

3-4-4 The website of each bank or payment service provider must include a special page for financial and banking awareness.

5. Protecting Customer Data and Account Confidentiality:

With due regard to what is stated in the articles of the Central Bank, Banking, and Monetary Authority Law regarding maintaining account confidentiality, as well as what is stated in the law and rules for combating money laundering and terrorist financing, banks and payment service providers or their agents or those represented by them from outsourcing companies must commit to the following at a minimum:

1-5-4 Considering all customer financial and personal data and information as confidential information and not using or sharing it with third parties without obtaining the customer's prior written consent, without prejudice to relevant laws.

2-5-4 Providing a suitable environment to protect the financial and personal data and information of customers, whether this data and information are stored by the bank or by any third party dealing with the bank.

3-5-4 Not disclosing any information related to customers or their accounts except after verifying their personal identity - or that of their legal representatives.

5. Rules for Protecting Customers' Rights Regarding Automated and Electronic Services

1-5 When providing automated and electronic services to the customer, the bank or payment service providers or their agents or those represented by them must provide them with the following information related to the service at a minimum:

1-1-5 An explanation of how to use it properly (for example: a simulation of how to use the service).

2-1-5 All costs.

3-1-5 Potential risks.

2-5 The bank or payment service providers or their agents or those represented by them from outsourcing companies must have secure systems that ensure the integrity and confidentiality of information.

3-5 The bank and payment service providers are responsible for managing all risks that the customer may be exposed to as a result of providing services by automated or electronic means.

4-5 The bank and payment service providers must bear full responsibility for any damages or losses that may be caused to the customer due to service failure or system failure or fraud or hacking that occurs for any reason, except for the following:

1-4-5 Negligence on the part of the customer.

2-4-5 Service failure due to circumstances beyond the bank's control.

5-5 The necessity of notifying the customer of the importance of protecting cards and information related to electronic services (for example: banking services via the internet and mobile phone) and maintaining the confidentiality of the username and password.

6-5 Providing suitable means to inform customers of all operations carried out electronically on their accounts.

7-5 Ensuring that payment service providers do not impose any additional expenses on the bank's customers when providing various banking services.

8-5 The bank must notify the customer immediately of any modification to the rules regarding the use of the service, such as withdrawal limits or imposing any additional expenses.

9-5 The bank must ensure that electronic banking services meet the needs of customers and facilitate the provision of banking services according to the latest means.

10-5 Banks must take into consideration planning to ensure business continuity when providing banking services through electronic banking channels.

11-5 Customers should be informed of the procedures to be followed to report cases of theft, loss, fraud, and hacking.

12-5 Providing appropriate electronic communication channels and a 24-hour phone line to enable the customer to easily report cases of theft, loss, fraud, and hacking, and any suspicious operations on their data and accounts.

Banks are granted a compliance period of one year from the date of issuance of these instructions, with providing the Supervision and Inspection Sector with a specific timeline plan for implementation stages, approved by the Board of Directors.

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Book of the Governor of the Central Bank issued on February 19, 2019 1

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