Inadequate regulatory oversight by financial market regulators resulting in regulated entities practising random ways to generate extra revenue
In anxiety to improve the earnings under ‘miscellaneous income category,’ many business entities in the financial sector are looking at various opportunities and do mischievous things. I am focussing the banking segment for discussion. This, however, equally applies to other segments like Insurance (Life, Health and General), SEBI regulated entities like /brokers/MFs, Mobile companies etc.
1. Levy of SMS charges & GST (on it): Banks are not service providers to SMS. Banks are ‘user of SMS facility’ provided by ‘mobile’ / ‘telecom’ companies (and are the actual beneficiary of SMS service as such charging customer for SMS (the service banks do not offer) and on top of levying GST on such SMS charges is inappropriate and tantamount a fraud by misrepresentation. Banks can claim reimbursement for non-mandatory SMSes it has sent, on an actual basis, like seeking reimbursement postal, courier, hand delivery, conveyance, on an actual basis, provided they are not-integrated with fees for related banking service/s.
2. Customer Care/service: Service entities are gradually moving from toll-free to ‘premium toll’ customer care service: Currently, there are three types of telecom options available in India.
1. Toll-free customer care service centre numbers
2. Premium Toll service centre numbers (where charges paid by calling party to a mobile service provider which many cases are partly shared with the ‘called’ partly service centre/organisation)
3. Normal tariff/Toll customer care/service with normal call /toll charges paid to a mobile service provider.
The focus of my discussion is on the second aspect.
Customer service representatives help customers with complaints and questions, give customers information about products and services, take orders, and process returns. By helping customers understand the product and answering questions about their reservations, they are sometimes seen as business promoters, sometimes the role of customer care is role retaining the customers and building goodwill.
Customer service representatives who work for banks answer customer questions on their complaints, grievances on basic banking services and routine information such as account balances, last few transactions (phone banking), blocking/unblocking debit /credit cards, information about interest rates, fees etc.
Customer service in banking is one of the most important ways to keep customers coming back. It includes responding to customers questions and complaints in a thorough/timely manner and interacting with customers through face-to-face meetings, telephone, mail, fax and email. Customer service is important to your business because it retains customers and extracts more value from them.
Customer service/care is also called a contact centre and is a type of call centre that is equipped to handle a large number of customer telephone requests for an organization.
Now that bank branches have become only service delivery outlets majority back-office operations of any bank are done at the central processing centre. Customers don’t know the fate of a particular pipeline transaction by contacting the branch. To address their concerns, grievances, complaints and information they are diverted to the customer service centre. As per RBI all Mobile-Wallet, all e-commerce platforms with wallet need to have a customer service/care centre. Most of the Banks offer 24×7 customer care centre. These days running a customer service centre is a mandatory expense for any bank or financial sector organisation. To put a check on major cost component banks house them far off from the main city where property prices /rents are high and provide telephone connectivity at least cost to the company.
What customers community is missing and what regulatory oversight is missing?
In India, Numbers numbers starting with 1800-xxx-xxxx followed by a six or seven-digit number are toll-free which means the caller does not incur any costs the called party pays for it. Free to any caller if calling from any service provider mobile phone or landline.
In India, numbers starting with 1860 series numbers are not toll-free. Some ignorant callers will assume it’s toll-free. Hear the caller does not incur any costs and called party does not pay for it. These 1860- xxx-xxxx special series, in many cases, do have call charges higher than normal local/STD calls. Companies do this to avoid paying hefty bills (on the toll-free number) and reduce the number of calls and time/duration of each call and at the time get a reasonable return on each incoming call due to premium charges sharing arrangement with 1860 xxx-xxxx telephone service provider.
The “1860” prefix followed by seven digits is used for local numbers, the calling party pays the local rate and is used for non-local numbers the called party pays long-distance call charges (if any) or calling party pays for both the parts as per the arrangement. No mobile operators include 1860 numbers in the unlimited prepaid plans for mobile in India also. In India, many mobile operators don’t include 1800 numbers also in the ‘unlimited prepaid plans’ for mobile
Many mobile service providers do not offer 1800 (toll-free service) to their own customers having some grievance with mobile operator’s services.
1860 xxx-xxxx has thus become a source of making money or saving money at the cost of gullible customers.
Some Banks have two sets of customer care/service centre numbers: e.g This Private Sector Bank Bank 1860 series premium toll number series for all other banking services
1800 series toll-free number for Agril Business (as it helps bank to reach its Agriculture sub-target within the Priority Sector). Thus Aix Bank depending on their priority decided type of number (call) to render customer service customer care/call centre.
I see Tata Sky/Tata Broad Band does have both set toll free and normal toll tariff (chargeable) numbers to their customer care and customer have a choice (with give and take benefits) and they advertise both the numbers.
Recent experience related to Credit Card of a Private Sector Bank
A few days ago I wanted to make one international payment. As my credit card was not active for international payment hence I had to enable activate it for international usage.
Banks website did not have an RBI mandated customer-initiated dynamic activation/deactivation mechanism. I had to talk to call centre to know how it can be done. It took around 8-9 minutes from the time I got connected to premium toll number to get moved from ‘IVR’ to a human voice. The bank call centre executive could not give me a solution, which is a different thing. Instead of offering call-back bank expected me to call the call centre again (of course going through the whole process to reach the call centre service officer) and spend 8-10 minutes to reach him and pay for the premium toll charges from my pocket.
Service/Call centre told me to get the Bank App downloaded from play store and go through the appropriate menu. Funny thing is that there was no mechanism to enable or disable the facility dynamically even on the app. There existed provision to only block or unblock card and register for the international facility at that time. Thus I had to call the call centre to know if there is another way out. In the process, I had to waste call @ 2.50 per minute for a considerable amount of time (it thus helped Bank to get a share in the premium tariff I paid to telecom service provider). All this was due to lapses of the said bank. Many people make calls to call centre for these purpose out of sheer necessity to do a business transaction. In any case upon its completion bank is going to earn revenue.
Banks feel had this been toll-free service people / Public / Customers will misuse (!) and lines would be busy for a longer duration of time resulting engaging more staff and have to pay more for longer usage of the telecom time.
On the other hand, the experience I had from the above example was a premium charge service (with income sharing for the called party, “bank”) the called party / Bank took its sweet time to connect the call to the concerned. In the meanwhile lot of unnecessary communication/advertisement was pushed (one has to compulsory listen to proceed further) at a cost to the calling party/customer. In the above case, I had to hear COVID-19 announcement in two languages, about banks products, the credit card balance and last 5 transactions etc compulsory at my monetary and financial cost, Many other too would have also experienced similar things.
These days many mobile subscribers opt for ‘unlimited calling’ facility. But this facility is available only for calling to normal numbers and not to ‘premium toll’ call service. So call from this number cannot be put through from pre-paid mobile numbers with ‘unlimited calling’.
If such mobile number is registered with the bank and also with a mobile service provider, under a pre-paid plan, the subscriber cannot use it for 1860/1800 and has to use a landline phone or other mobile number that has normal top-up / open recharge plan and call from such another number. If that other number happens a mobile number not registered with the called party (bank) for underlying credit /Debit card/banking account, one has to pass through the lengthy customer verification process (which is both time and money consuming for the client) and the real purpose of 1800 / 1860 followed by 6-7 digit number is defeated.
As mentioned above many mobile service providers do not offer 1800 (toll-free service) as it doesn’t generate any revenue to them. Many mobile service providers do not offer 1800 (toll-free service) to their mobile numbers for calling mobile operators customer care for reporting grievance about mobile services and expect people to call to normal fee toll services.
Toll-free numbers come with basic as well as premium toll-free numbers and are capable of providing add-on services like a welcome message, Multi-level IVR, Multiple Language, web interface,
Benefits of 1860 series to banks, Finance companies, Wallet service providers
1. Keep a tab on call duration
2. Substantial earning sharing of premium charges with mobile operators
Unethical practices:
playing product advertising, Playing COVID caller tune in two languages, delays in putting the caller to right segment/person. Prolonging call using voice chat, during are few unethical things that are noticed the premium toll call. Instead of this call-back option can be provided in a programmed manner via IVR if the caller wants to get inputs on it.
As mentioned at the beginning of the write-up in India 1800 series numbers are free throughout the country but 1860 and other numbers are charged Re 1 (normal toll) or Rs 2.5 to Rs 3 per minute (to premium toll number). Some banks like “ICICI Bank, Citi Bank, Karur Vaysa Bank mention on their website against series 1860 numbers that local charges apply. Some banks after getting connected, inform the caller that premium charges would apply to this call.
It is normally claimed by public utility service providers, telecom companies, banks Insurance companies that premium toll numbers service is used as a strategy to keep the inbound call flow under control.
It, not only banks, Insurance, Finance, Broking companies moved from a ‘toll-free service’ to ‘normal toll’ or ‘premium toll service’ but companies like Airtel who are in the business of mobile/fixed-line telephone too want to make money by offering ‘premium toll’ or normal toll service who can easily offer toll-free service. The telecom regulatory authority should make it mandatory for such service companies who have in house facility to render/allocate toll-free numbers to call service centre.
Copying every revenue-generating opportunity most of the banks and institutions in insurance, investment sector nowadays has switched to the helpline numbers ‘1860’ instead of the traditional toll-free numbers starting with ‘1800’.
As mentioned above many people take an unlimited calling plan. Unfortunate thing is that many service providers don’t cover calling to a number starting with 1860 followed by 6 or 7 digit numbers. But for few exceptions calls to toll-free numbers are also not normally put through under such plans as it does not yield any revenue to caller’s mobile company.
Govt can introduce separate series to normal toll number so that these calls can come under the unlimited calling plan.
Many times numbers starting with 1860 have built-in IVR facility. Running through IVR menu takes time like 4-5 minutes or more than that, in certain interactive cases, genuine callers may end up paying a huge amount if they frequently call on 1860 numbers.
What can be done:
To balance both aspects Regulators, Govt (RBI, TRAI, and IRDA) may consider the following:
Service centres for banking, insurance (both Life and General), mobile wallet, credit card issuers/service establishments should be told to provide a toll-free customer care/centre facility for common complaint, grievances relating to product and services. This toll-free number should be with 4 to 10 hunting lines, depending on the size of an underlying entity.
Customer care for special services (other than complaints and grievances): A number with normal tariffs (series 1860) can be used. These numbers should be however free from ‘push advertisements’/product offering and unnecessary information.
Provide special numbers for missed call / call back service numbers for registered mobile users/customers for certain specific services
Premium numbers (toll-free or normal toll) for phone banking transaction like Balance Enquiry, Account statement, payment query (in case of Banks) etc.
For 1860 series the called party entity, depending on its traffic, maybe given choice to decide.
The service personnel attending the calls to 1800/1860 should be groomed to treat them on a different footing.
Premium toll numbers should not be permitted to the essential services and public utilities as these entities should not treat ‘normal toll and premium toll’ as a source to a generation of revenue for the called party.
Can consider 1800 series numbers to police, fire, hospital, senior citizen, Child/women protection services in additions to 3 /4 digits special numbers.
So next time you call any bank and are in for a long wait please check whether your call is to 1860 series or 1800 series number.
*****
Disclaimer: The contents of this article are for information purposes only and do not constitute an advice or a legal opinion and are personal views of the author. It is based upon relevant law and/or facts available at that point of time and prepared with due accuracy & reliability. Readers are requested to check and refer relevant provisions of statute, latest judicial pronouncements, circulars, clarifications etc before acting on the basis of the above write up. The possibility of other views on the subject matter cannot be ruled out. By the use of the said information, you agree that Author / TaxGuru is not responsible or liable in any manner for the authenticity, accuracy, completeness, errors or any kind of omissions in this piece of information for any action taken thereof. This is not any kind of advertisement or solicitation of work by a professional.
Author Bio
