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Hi everyone,

Again, highly last minute, but TRAI has come out with a paper on
"USSD-based Mobile Banking Services for Financial Inclusion" and is
seeking comments on the same. It appears that comments are open till
the 11th.



I have attached the paper. Please go through it and respond with your
thoughts on how Mobile Banking can benefit persons with disabilities
and what are the specific technological solutions which may already
exist in this regard. I hope groups like AccessAbility, BarrierBreak
and CIS can specifically aid in this regard. Of course this paper
concern's TRAI's role but if there is something that the RBI needs to
mandate through TRAI's recommendations I am sure that there is a role
to play here.



Please feel free to include anyone I may have missed. I hope to get
your initial responses by 6pm on the 4th.



These are the issues which have been identified by the TRAI as
relevant, and they seek specific input on these:



Q1: Do you agree that USSD is one of the most appropriate modes for
mobile banking for financial inclusion? If not, which mode do you
think is more appropriate? Please support your viewpoint with reasons.

(Here, I think we need to specify whether USSD based services are
accessible for persons with disabilities. The alternative is SMS and
IVR but USSD is preferred by the TRAI for reasons specified in the
paper.)

Q2: Do you agree that the Mobile Banking (Quality of Service)
Regulations, 2012 should be amended for mandating every TSP, acting as
bearer, to facilitate not only the banks but also the agents of banks
acting as the aggregation platform providers to use SMS, USSD and IVR
to provide banking services to its customers? Please support your
viewpoint with reasons.

Q3: Do you agree that in the case of USSD transactions for mobile
banking, TSPs should collect charges from their subscribers as they do
in the case of SMS-based and Application (App) based mobile banking?
Please support your viewpoint with reasons.

Q4: Do you agree that records for USSD transactions must be generated
by the TSPs to provide an audit trail for amounts deducted from
prepaid subscribers and bills raised to postpaid subscribers? Please
support your viewpoint with reasons.

Q5: Would it be appropriate to fix a ceiling of Rs. 1.50 per USSD
session for mobile banking? Please support your viewpoint with
reasons.

 Q6: In case your response to Q5 is in the negative, please suggest an
alternative methodology to fix a ceiling tariff for a USSD session for
mobile banking. You may also support your viewpoint with a fully
developed model with associated assumptions, if any.

 Q7: Is there any other relevant issue which should be considered in
the present consultation on the use of USSD as a bearer for mobile
banking services?

Apparently ICICI and SBI are already using these services. Please do
share if you have any experiences with the same.

The scope of this paper for intervention is pretty low, but all the
same I think we should be making our presence felt.

Looking forward to your responses.

Best,



Amba.






---

Inclusive Planet Centre for Disability Law and Policy

12/21, Custain Beach Road,

Santhome, Chennai,

INDIA 600004

+914424611313

----

www.inclusiveplanet.org.in





-- 
Avinash Shahi
M.Phil Research Scholar
Centre for The Study of Law and Governance
Jawaharlal Nehru University
New Delhi India

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