Duration 3 days – 21 hrs
Overview
This course equips banking teams in the Philippines with a practical, implementation-focused understanding of the BSP Financial Consumer Protection Framework under MORB Section 1001 / Part Ten and its enabling bases under the Financial Products and Services Consumer Protection Act (RA 11765). It also deep-dives into credit card billing and disclosure controls—covering billing cycle governance, statement and fee transparency, interest/finance charge rules, customer communication requirements, and complaint/dispute handling—aligned with BSP regulations for credit card operations and consumer assistance mechanisms.
Objectives
- Explain and apply the financial consumer rights and BSP expectations under RA 11765 and BSP’s consumer protection regulations.
- Translate BSP consumer protection requirements into bank controls: governance, monitoring, training, third-party oversight, and issue management.
- Design or enhance a Consumer Protection Risk Management System (CPRMS) and consumer assistance/complaints operating model aligned with BSP expectations.
- Implement compliant credit card billing and disclosure practices (billing cycle, statement integrity, charges/fees transparency, and customer notices).
- Apply BSP rules on interest/finance charges and customer notification requirements for credit card-related changes.
- Set up an escalation-ready complaints pathway aligned with FCPAM (BSI-level) and BSP-CAM (second-level) procedures.
Audience
- Compliance / Regulatory Affairs / Legal
- Risk Management (Operational Risk, Conduct Risk, ORM)
- Cards Business / Credit Card Operations / Billing & Collections
- Customer Experience / Contact Center / Complaints Handling Teams
- Product Managers (Retail, Cards, Digital Channels)
- Internal Audit / Quality Assurance
- Third-party / Vendor management teams supporting card servicing
Pre- requisites
- Basic understanding of banking products and customer servicing operations
- Familiarity with credit card lifecycle (application, issuance, billing cycles, payments, disputes)
- Helpful (not required): prior exposure to BSP circulars / MORB navigation and internal policy writing
Course Outline
BSP MORB 1001 Consumer Protection Framework (Governance + Controls)
Module 1: Regulatory Context & Key Concepts
- BSP financial consumer protection direction and scope
- RA 11765: policy intent + core consumer rights (fair treatment, transparency, fraud protection, data privacy, complaint redress)
- BSP Part Ten / MORB Section 1001: how the framework is applied to BSIs and products
Module 2: Consumer Protection Operating Model (What BSP Expects to See)
- “Customer outcomes” and market conduct expectations
- Product governance: product design, suitability/affordability thinking, and controls for vulnerable segments
- Third-party and outsourcing considerations (what to enforce in vendor SLAs/monitoring)
Module 3: CPRMS — Consumer Protection Risk Management System (Build/Enhance)
- CPRMS components: governance, policies, processes, measurement, monitoring, mitigation
- Roles and accountability: Board oversight & Senior Management responsibilities
- Practical workshop:
- Identify top consumer protection risks in your card business (fees, disclosures, collections conduct, disputes, fraud, data privacy)
- Map risks → controls → evidence
Module 4: Standards of Conduct (Hands-on Controls)
- Transparency & disclosure: what “clear, accurate, understandable” means in practice
- Fair and equitable treatment across lifecycle (marketing → onboarding → servicing → collections)
- Effective recourse: channels, turnarounds, root-cause analysis, and reporting expectations
Module 5: Complaints & Assistance Mechanisms
- FCPAM: first-level recourse inside the BSI
- BSP-CAM: second-level recourse; when and how complaints escalate
- Minimum process design: intake → classification → investigation → response → closure → corrective actions
- Mini-workshop: draft a complaints SLA + escalation matrix for card billing disputes
Credit Card Billing Compliance Deep Dive (Credit Billing “100/1003” Focus)
Module 6: Credit Card Billing Fundamentals (Definitions + Controls)
- Billing cycle, statement cut-off, statement of account/billing statement concepts
- What must be consistent and reconcilable: transactions, fees, interest, reversals, adjustments
- Payment posting and allocation controls (avoid unfair/unclear practices)
Module 7: Interest, Fees, Finance Charges, and Disclosures
- BSP rules on interest/finance charge caps and related controls (including installment and cash advance considerations)
- Disclosure requirements: presenting the “full cost” clearly (fees, penalties, interest computation method)
- Notice requirements for changes that affect customers (e.g., computation method/fees)
- Workshop: build a Billing Disclosure Checklist (statement content + fee table + change notices)
Module 8: Billing Errors, Disputes, and Complaint Handling Playbooks
- Common dispute scenarios: unauthorized charges, duplicate postings, merchant disputes, installment disagreements, fee reversals
- Investigation workflow design: evidence gathering, timelines, communication templates, decisioning and goodwill adjustments
- Documentation and audit trail requirements (what regulators/audit will ask for)
Module 9: Monitoring, Reporting, and Internal Assurance
- KPIs for billing and complaints: response time, resolution time, repeat complaint rate, upheld vs rejected disputes, root causes
- Quality assurance controls for statements and notices
- Internal audit/testing approach: sampling methodology + red flags
Module 10: Capstone Exercise (Implementation Plan)
- Create a 30–60–90 day action plan:
- Policies to update
- Process gaps to close
- Training and monitoring to deploy
- Evidence pack to maintain for BSP exams
