Identity

Who can serve as an agent?

Identifying and maintaining quality of agents is important for well-functioning agent networks that provide consumers with a safe and accessible channel for DFS. Regulators may set minimum eligibility requirements in some cases, while DFS providers may develop further criteria to support business objectives.

Arguments for Stricter Requirements

Consumer protection

Certain types of providers (e.g., for-profit shops, individuals rather than legal entities, unregistered businesses) should be prohibited from serving as agents due to the risk to consumers.

Permissible activities

Certain providers (e.g., faith-based organizations, not-for-profit entities, entities licensed by another regulatory agency) should not be engaging in agent business.

Arguments for Greater Flexibility

Principal responsibility

Regulators can protect consumers by

1. requiring that the principal (DFS provider) conduct due diligence on potential agents.
2. holding the principal responsible for the actions (or omissions) of its agents.

Cost

Heavy restrictions can affect the viability of agent networks, particularly in rural and remote areas.

• In countries with high levels of business informality, requiring DFS providers to use legal entities may limit uptake, particularly in rural, remote, and other underserved areas.
• To mitigate the risk of allowing DFS providers to appoint a broad range of individuals and legal entities as agents, regulators could
  1. require providers to conduct due diligence on prospective agents.
  2. hold providers responsible for the actions (and omissions) of their agents.
  3. ensure effective supervision of DFS providers.