Recommendations on the Service of Consumers of Banking Services

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Date of creation: 2024-12-30

Appendix to the resolution

of the Committee on Supervision

of the National Bank

of the Kyrgyz Republic

of December 20, 2024

No. 51/3

RECOMMENDATIONS

on the service of consumers of banking services

1. General Provisions

2. These Recommendations on the service of consumers of banking services (hereinafter referred to as the Recommendations) are developed to enhance the protection of consumers of banking services (hereinafter referred to as clients), ensure transparent and informed choice by consumers of banking products and services, stimulate socially responsible behavior by banks, and increase public trust in the banking system.

3. For the purposes of these Recommendations, the following terms and definitions are used:

Consumer Risk

– the probability of circumstances arising related to the acquisition and/or use of a product due to a violation of the rights and/or legitimate interests of consumers of financial products.

Corporate Social Responsibility – a set of obligations undertaken by a bank, including the bank's contribution to the development of society in the social, economic, and environmental spheres, ensuring sustainable development of both the bank itself and society as a whole.

The application of these Recommendations is aimed at ensuring that banks take into account the interests of clients purchasing their products and services, minimize risks associated with ignorance of the terms of their provision, and the consequences of non-compliance with contract terms by clients, as well as to implement the principles of responsible banking.

3. Banks are recommended to continuously develop their own internal procedures in accordance with the nature and size of their business and with best local and international standards and practices.

4. Responsible Banking and Social Responsibility

5. Responsible banking in the context of consumer protection should be understood by banks as the active participation of banks in ensuring fair and transparent relationships with clients. This is not merely compliance with the formal requirements of the legislation of the Kyrgyz Republic, but the voluntary assumption of additional obligations to protect consumer interests, taking into account sustainable development.

6. Responsible banking for the purposes of these Recommendations implies:

• ensuring transparency and accessibility of information for the client (including terms, risks, and social/environmental aspects);

• protection of consumer personal data (compliance with legislative requirements, taking measures against information leaks);

• ensuring service quality (high standards of customer service, as well as evaluation of banking services taking into account client opinions and needs);

• dispute resolution mechanisms (transparent and accessible procedures for considering client complaints, fair and prompt resolution of disputed situations);

• promoting financial literacy;

• social responsibility;

• ensuring that clients have a comprehensive understanding of sustainable development goals;

• working with clients to encourage sustainable practices and achieve sustainable development goals;

• working with clients to help them understand their current impact on the environment and society;

• working with clients to help them develop a transition path to more sustainable business models;

• supporting with appropriate consulting and sustainable banking solutions regarding financing to achieve/implement clients' sustainability goals.

6. Banks should implement the principles of corporate social responsibility and, when interacting with and serving bank clients, adhere to a socially responsible approach.

7. Social responsibility includes support for socially significant projects, the application of environmentally friendly technologies, minimization of negative impact on the environment, and conducting training events for clients to increase their financial literacy.

8. When serving clients, banks are recommended to pay special attention to such aspects as advanced age, disability, etc.

9. To enhance security when using banking products, banks are recommended to develop rules that may be offered to socially vulnerable persons, provide the right to limit the volume and number of transactions with certain limits, appoint an assistant for additional control over these transactions, and compile a closed list of persons to whom remote money transfers are possible.

10. Rules for Providing Information to Clients

11. Banks are recommended to ensure the existence of internal regulatory documents related to the order of client service, including at least:

• the necessity of following the main principles in providing banking services and considering consumer appeals, established by the Regulation

"On Minimum Requirements for the Order of Providing Banking Services and Considering Consumer Appeals," approved by the resolution of the Board of the National Bank of the Kyrgyz Republic (hereinafter – the National Bank) dated June 24, 2015, No. 35/10 (hereinafter – the Regulation on the Order of Providing Banking Services);

• competent, effective, and professional performance of bank employees' duties and providing potential and existing clients with information about the provided service in accordance with the requirements of the legislation of the Kyrgyz Republic and normative legal acts of the National Bank;

• employees having sufficient knowledge of the terms of provision of products and services, their characteristics, essence, as well as the risks and responsibilities of their use;

• providing exhaustive and reliable information about products and services;

• a procedure for preventing the client from assuming risk due to insufficient financial literacy;

• warning and reminding clients of the need not to disseminate personal data to minimize the risk of fraud;

• compliance with ethical norms and business ethics when interacting with the client.

11. Banks should avoid the client signing consent to the terms of services provided by the bank through formal familiarization with them. Responsible bank employees directly accompanying the client in the process of providing the service should clearly ensure that the client understands and accepts the terms of the product or service through negotiation and explanations in accordance with the Regulation on the Order of Providing Banking Services.

12. When creating new banking products, the bank should:

• conduct an assessment of consumer risks of new banking products before offering them to clients and create protective mechanisms aimed at preventing the realization of consumer risks;

• ensure that the banking product corresponds to the characteristics and needs of the target client group;

• qualitatively and reliably inform clients about the properties and risks of banking products.

13. When providing services, banks are recommended to identify actual and potential violations of the rights and/or legitimate interests of clients without waiting for client complaints, monitor the implementation of banking products, including through welcome calls.

14. Service for Persons with Disabilities

15. For the purposes of these Recommendations in this section, "clients" refers to a person with a disability.

A person with a disability is a person who has a health impairment with a persistent disorder of body functions, caused by diseases, consequences of injuries, or defects, leading to a limitation of life activity, and causing the need for their social protection and rehabilitation.

15. Within the framework of the general provisions of providing banking services, banks are recommended:

• to conduct work to inform the population about the availability of adaptive technologies for obtaining services in banks;

• when developing websites and mobile applications, it is recommended to take into account the opinions of experts from among public associations of persons with disabilities, as well as to preliminarily test developed products and services for possible subsequent adjustment;

• to provide persons with disabilities with special reference sections on websites and mobile applications containing frequently asked questions, easy-to-understand information about products and services, as well as information about services and special products (if available);

• to provide information on the website and in the mobile application about the location and working hours of branches and ATMs adapted for them, as well as about the list of services provided in these branches;

• to place information for familiarization about the availability in the bank of assistive technologies, devices, and the location of ATMs available to clients, as well as instructions for using such ATMs;

• to implement training of employees on providing situational assistance to clients, including assistance to minimize stressful factors during client service, and to ensure that contact center employees, online chats, and online video consultations have pre-prepared communication scenarios (scripts) that guarantee correct and effective interaction with clients;

• to develop the possibility of providing individual home visits upon client request;

• not to restrict the presence of an accompanying person during client service if the client has given consent for this.

16. It is recommended to conduct training for bank employees in skills for interacting with clients and providing prompt assistance, including:

• timely visual identification of client needs, such as the presence of a guide dog, wheelchair, glasses, white cane for the blind, hearing aid, or other assistive devices;

• compliance with etiquette rules when communicating with the client, taking into account the features of their health condition;

• the application of accessible methods to ensure maximum comfort in service;

• direct communication with the client, not with their accompanying person, unless the client has indicated another method of interaction;

• rules for accompanying the client when performing necessary operations during service;

• focusing on minimizing stressful factors and creating a comfortable atmosphere during service;

• paying special attention to the development of emotional intelligence and improving the professional skills of employees, including those who directly interact with clients, such as specialists working with banking operations, cashiers, and operational hall specialists;

• training bank employees in multiculturalism and inclusive service.

17. For persons with visual impairments, the bank is recommended to create the following conditions for providing services:

• providing assistance in orienting within the bank premises, including assistance in obtaining an electronic queue ticket, and escorting to the required specialist. The bank should provide priority service for the client;

• to ensure the availability of special devices and equipment (magnifying glass, electronic video magnifier) for the convenience of visually impaired clients when reviewing information and conducting transactions;

• to clarify with the client which method of reviewing information and documentation, including that provided for signing (contract, consent to provide services, etc.), is preferable for them.

The bank may offer several alternative channels of interaction:

• providing the document on paper medium, matte paper, excluding glare, with enlarged font (font size not less than 16);

• providing the document in an accessible format in person (on paper medium) and/or in an accessible electronic format (sending to the email address specified by the client, copying to the electronic medium provided by the client, etc.) with protection against changes, in a format accessible for reading by screen reader programs (PDF, RTF, TXT, DOC(X));

• audio playback of the text of the contract for banking services and other documents signed by the client.

18. For persons with hearing impairments, the bank is recommended to create the following conditions for providing services:

• clarification of the client's preferred methods of interaction;

• the specialist should not interrupt, try to speed up their speech, or continue phrases in the client's speech;

• offer alternative convenient methods of communication for the client, for example, using paper and pen, using a phone, etc.;

• if asked to repeat information, the phrase should be repeated in other words, simplifying the sentence if possible while preserving its essence;

• the specialist should speak clearly and distinctly, using understandable gestures, or offer the services of a sign language interpreter;

• if a personal sign language interpreter or deaf-blind interpreter comes with the client, do not prevent their presence. If the accompanying person says they are a sign language interpreter (sign language interpreter, deaf-blind interpreter), it is appropriate for the employee to ask the sign language interpreter to present relevant documents and make copies of them. In addition to the identity document (passport), request a document from the interpreter regarding education and qualification;

• to ensure video recording of the service process for security purposes, warning the sign language interpreter and the client in advance, and also asking the sign language interpreter to sign the document (credit contract, mortgage contract, etc.) indicating that the text of the document was translated by them without distortion;

• the bank should ensure the signing of a confidentiality agreement regarding information that became known to the sign language interpreter (including banking, commercial, and other secrets protected by law, protection of personal data).

19. For persons with musculoskeletal disorders, the bank is recommended to create the following conditions for providing services:

• to ensure the availability of ramps, anti-slip coatings, handrails on stair flights, and buttons to call bank employees for assistance;

• to help the client enter the premises if they have difficulty doing so independently;

• to provide designated places in the waiting hall for wheelchair users and seating areas for waiting, and to escort the client to the place in the waiting hall;

• to ensure unimpeded access to the client service window, including for those moving in a wheelchair.

20. When serving clients with other impairments of body functions in banks, it is necessary to combine and not be limited to the provisions set forth in these Recommendations, as well as to apply international practice and standards for adapting banking services for persons with disabilities.

21. Disclosure of Information and Transparency

22. General rules for disclosing information during bank-client interaction:

1. information disclosed by the bank is provided in a language accessible to the client's choice (state/official or other languages);

2. information disclosed by the bank contains the most understandable terms and expressions for the client and cannot be contradictory or misleading (avoid using complex professional terms);

3. the bank ensures that the information disclosed allows the client to understand the essence of the service offered to them and the associated risks;

4. information disclosed by the bank does not hide important provisions or minimize their significance, creating the impression that they are not important;

5. the bank does not exaggerate the significance of the services provided by it through false, incorrect, or incomplete information;

6. the bank ensures that the information disclosed is presented accurately, reliably, and in a timely manner;

7. the bank ensures that information concerning the client or documents provided to them are not accessible to third parties (oral communications are conducted in such a place or in such an order that third parties cannot hear the information transmitted during communication (for example, information about the provided service, personal information about the consumer: place of residence/work, position held, salary size, etc.);

8. the bank does not discredit another bank and does not form a negative attitude in the consumer towards the banking system.

6. Final Provisions

7. Banks are recommended to publish reports to demonstrate social and environmental indicators, including:

• the bank's corporate behavior;

• special industry programs in the field of support for socially significant projects;

• organization and participation in events aimed at protecting and preserving the environment;

• creating conditions for persons with disabilities;

• events aimed at increasing the financial literacy of the population.

23. Banks are recommended to implement international customer service standards to develop and implement processes that ensure continuous improvement of service quality and satisfaction of client needs.

24. Banks must conduct regular training of employees in knowledge, skills, and communication skills with clients.

Contacts

Public Reception

+996 (312) 61-04-86 +996 (312) 66-90-15 +1257, +1256

Department for the Protection of Consumer Rights

+996 (312) 66-90-15 +1671, +1666

Report Corruption

+996 (312) 66-90-15 +2120 +996 (312) 61-04-00

Auto-informant of Official Exchange Rates

+996 (312) 61-07-11

Numismatic Museum

+996 (312) 66-90-15 +1232 +996 (312) 61-24-14

E-mail

mail@nbkr.kg

For work with the media

press@nbkr.kg

720010, Kyrgyz Republic, Bishkek, Kievskaya St., 189