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SupTech Case Study for Financial Consumer Protection Consumer Complaints Chatbot in Rwanda

SupTech Case Study for Financial Consumer Protection
Consumer Complaints Chatbot in Rwanda

The following case study outlines the development of  INTUMWA (which means “Messenger” in Kinyarwanda), a multilingual consumer complaints chatbot deployed by the National Bank of Rwanda (NBR) in 2022. This technology solution has been developed with financial and technical support from the African Development Bank’s Africa Digital Financial Inclusion Facility (ADFI) in partnership with suptech vendor Proto, along with facilitation and evaluation provided by BFA Global, as part of a suptech portfolio of consumer complaints chatbot solutions deployed in Ghana, Rwanda, and Zambia.

The sections below cover the following topics relating to the development of this ground-breaking Supervisory Technology (suptech) solution:

  • The need for suptech solutions to continue the advancement of effective and accessible consumer protection to support increased financial inclusion
  • AFDI’s role in accelerating greater digital financial inclusion in Africa through investment in initiatives to build on and scale inclusive consumer protection, sharing suptech success stories from across the global ecosystem to foster secure and accessible financial services
  • Rwanda-specific opportunities to be seized and market pains to relieve for financial supervisors, financial service providers, and customers of financial services
  • Update on the Intumwa chatbot’s progress to date to improve access to consumer protection in Rwanda, particularly for customer groups who face access barriers due to location of services, channels or language used. These statistics will be updated here regularly as customer uptake continues beyond launch
  • Next steps to work towards better access to consumer protection for excluded groups, associated tools, and lessons learned

Key highlights of the deployment include:

  • TBC

Financial Inclusion, Consumer Protection, and SupTech

Financial inclusion’s great strides over the past decade must be sustained. 

As evidenced in the table below and detailed in our associated publication, the share of adults with access to a formal financial account has grown substantially at the global, regional, and country level during the past ten years.

TABLE = Source: Global Financial Inclusion Database, 2022

The customer’s journey toward financial inclusion begins with trust, which can be bolstered by effective consumer protection policies, and powered by suptech

For the notable growth in financial inclusion of the past decade to continue, customers must be able to easily access channels that are tailored to their needs and worthy of their trust. Past work from BFA Global (2020) demonstrated via primary research that the primary factors in uptake of digital financial services for customers in four prominent African markets include reliability (including trust and security) and accessibility (including language and channels).

To protect past growth and to foster any future growth, ADFI, CGAP (2018) and others note that financial authorities play a critical role in the implementation of effective financial consumer protection and market conduct supervision to ensure advances in inclusion are protected, and customers are ensured such reliable, secure, trustworthy, and accessible digital financial services.

Since before the term “suptech” was formally adopted in 2017, authorities in the public sector have noted the potentially transformative power of digitized data and associated technologies to streamline supervisory processes and produce more effective consumer protection and market conduct supervision to this end. With the advent of suptech, there is strong potential to realize this promise of transformation for the sake of effective financial inclusion.

Today, suptech applications for consumer protection are indisputably happening – but require acceleration through additional support.

As most recently evidenced in the State of SupTech Report 2022 study of 146 financial authorities, most (71%) have engaged in suptech initiatives, and most of those initiatives (59%) include a focus on consumer protection. However, limitations in budget, data quality and technical skills remain the most significant barriers to implementing suptech. 

The same report notes that financial authorities in emerging markets and developing economies are later adopters of suptech, less often have sufficient digital infrastructure, less often assign dedicated suptech roles and departments, have seen less substantial internal outcomes than those in advanced economies, seek trainings, technical assistance, digital tools, and pursue funding primarily for solutions design and development.

Project Context

ADFI is funding the next generation of suptech for consumer protection

To address many of the challenges listed above, ADFI supports innovative digital products related to financial services that have a broad reach across all population segments across the African continent.

The digitisation of Government platforms such as suptech for consumer protection can serve to empower customers of digital financial services, by creating a more reliable and accessible environment within which to transact. Specifically, introducing suptech into consumer protection frameworks can mitigate capacity insufficiencies and dependence on manual processes, enabling financial authorities to effectively adopt the monitoring component into these frameworks.

 In February of 2021, following a RFP-initiated grant award, Proto and BFA Global kicked off their partnership with ADFI, to establish a complaints-handling system for financial regulators, using multi-lingual chatbots and Artificial Intelligence that will interface with key financial service providers in Ghana, Rwanda and Zambia.

The project sought to respond not only to financial authorities' perceived needs, but also explicitly to customers' and supervised financial institutions' concerns in the marketplace. A series of questionnaires, surveys, and human-centered design (HCD) exercises were conducted by BFA Global to empower Proto in developing the technology to fit the needs of each market.

Notably, this work comprises the latest chapter of an ongoing suptech story, building on the success of the chatbot launched by Bangko Sentral ng Pilipinas (BSP) in partnership with R2A, which served as proof that this multilingual, AI-based, accessible model can work. The ADFI engagement serves as a “Chatbot 2.0,” by introducing global scale, and offering a white labeled chatbot deployments for financial service providers, which integrate directly with that of the financial authority.

This opens the door to a world in which supervisors enjoy a composition of suptech-based consumer protection solutions (e.g., advanced analytics, sharing of data and insights across supervisory use cases, and integration of additional channels like social media monitoring, website reviews, and web scraping), further empowering the end customers of financial services through reliable, secure, and accessible services.

Key Areas of Impact 

Financial supervision

The National Bank of Rwanda (NBR) has been an early leader in suptech.

NBRhas previously launched suptech, and is familiar with the resulting benefits. Perhaps most prominent is their Electronic Data Warehouse (EDW). This supervision information system (SIS) initiative was based on an end-to-end regulatory reporting data platform with both prudential and market conduct applications, and introduced three new dimensions to NBR’s regulatory reporting infrastructure (State of SupTech 2022):

  1. Data-pull technology that allows supervisors to connect directly to databases of the 600+ supervised firms and collect data from the source rather than sharing data via Excel spreadsheets
  2. The collection of more granular account-level data, provided daily, rather than aggregated by an institution monthly or quarterly
  3. Data analytics and reporting that is now automated and linked to interactive dashboards

Thus, the opportunity to enjoy a similar transformation of their consumer protection via the ADFI project was well received. NBR Director of Market Conduct Supervision Gérard Nsabimana said: 

“The National Bank of Rwanda is pleased to deploy the complaints handling and customer engagement system in partnership with ADFI, Proto and BFA. This partnership comes at the right time as the law relating to financial service consumer protection was enacted on March 3, 2021. The system will facilitate financial service consumers to raise their complaints and get feedback via different virtual channels. Our expectation is that the system will be beneficial for both financial service consumers and financial service providers.”

To Director Nsabimana’s point, the following opportunities were identified via a questionnaire distributed to NBR prior to the design sprint at project inception:



Financial Service Providers

Given that the INTUMWA complaints chatbot was to be deployed across the websites of Rwanda’s banks, insurers, and other financial service providers (FSPs) for maximum exposure to consumers in need of protection, the chatbot had to be equipped with additional capabilities such as general customer support, payments, account management, claims, and coverage applications.

To this end, and in order to better understand the needs of FSPs, BFA Global developed a questionnaire that NBR distributed to their supervised institutions. We received 73 responses, and extracted the opportunities summarized below:


Customers of Financial Services

The primary focus – for the ADFI consortium, the financial authority, and the financial service providers alike – is positive impact for end users of financial services. So naturally it was critical to understand and account for their perceived successes and potential areas of improvement in the previously existing complaints processes, such that NBR could be confident in launching the most effective system possible to meet these expressed needs.

To this end, a quantitative survey was conducted with 402 existing complainants, drawn from a database of complainants to the NBR and to various FSPs, spanning urbanicity, sex, age, marital status, education status, and employment status. These results, a small selection of which is included in the table below, directly informed the design of the solution.


Central Bank


Frequency of complaints

92% have only raised the complaint once. 

Notably, only 65% were aware that they could raise an FSP-related complaint with NBR.

72% percent have only raised the complaint once. 

Notably 84% were not aware that they could raise a complaint in the financial institution

Nature of complaints

46% reported raising complaints when they had loan issues. 

23% who had misplaced funds reported to NBR when the FSPs took long to resolve them they saw it deem fit to escalate the matter to NBR. 

These issues generally aligned to what was reported qualitatively, e.g., when FSPs continued charging interest despite COVID forcing many businesses to close, and jobs lost:

“I decided to raise a complaint because I could not understand how the amount of interest rate exceeds the loan itself in the period of only 4 months. And I wanted to raise a complaint because the bank did not consider the pandemic situation while they already knew that the beer shops were closed.” 

– NBR complainant

25% who raised the complaint mentioned when they misplaced their funds.

24% reported that excessive/hidden fees were debited in their accounts, especially loan interest, during the covid period.

These issues generally aligned to what was reported qualitatively, e.g., when respondents visited ATMs, the ATM would not dispense the amount at times; when transacting from their bank to mobile wallet others found their balance less than what it was. 

“​​It was in the beginning of this year where I went to collect my salary at a teller machine located in Nyarugenge market by using an ATM card but I could not get it while the message sent on my phone showed that my account was debited.”
– FSP complainant


The top 5 channels were:

  • Call in (31%)
  • Email (29%)
  • Branch or HQ visit (21%)
  • WhatsApp (7%)
  • Website (2%)

Main challenges faced 

29% reported having experienced delay or no response when they raised the issues.

39% said their issues were yet to be resolved. 

Issues like the lack of a centralized complaint system at NBR were reported qualitatively as part of the reasons that no response and delays are experienced.

The top 5 channels were:

  • Call-in (49%)
  • Email (15%)
  • Branch or HQ visit  (11%)
  • Website (9%)
  • WhatsApp (8%)

Main challenges faced 

29% reported having experienced delay and no response from the financial institutions. 

23% said their issues are still pending.

“When you raise a complaint, it is better that they send you a message or give you a call telling you how the process of treating your issue is going on.”
–FSP complainant

Complaints process

62% suggested increased channels of raising complaints would work well for them:

"To find other ways of raising complaints that would be easier to someone not familiar with technology or who can't even access devices like computers and phones."
– NBR complainant

This was followed by 39% of complainers who indicated that better technology would work well.

57% also suggested increased channels of raising complaints would work well for them, followed by 37% who indicated that better technology would also work well. 

Ease of use of digital skills needed in raising complaints was notable. Due to COVID-19, some complainers were asked to send emails and struggled to do so.

Quality of service

While 53% of the complainers got to know the progress of their complaint, 65% were not satisfied with how the complaint was handled.

70% of the complainers did not get to know the progress of the complaint.

"[C]create awareness to bank clients otherwise, some people are losing money unknowingly due to the errors done by the banks, and if they don't follow up losing money continuously."
– Respondent R

Additional Demand-Side Insights

As part of the surveys, the team also conducted qualitative in-depth interviews, surfacing the following opportunities for improvement from the customer perspective.

Improve customer care services at the FSPs by monitoring end to end customer journey. Customers tend to report to NBR primarily when issues with their FSP take longer to be resolved. In particular, two banks were mentioned by several respondents as having significant room for improvement in resolving complaints, and that would benefit from a complaints system such as the one NBR would be launching.

Digital skills play a massive role in the current processes for raising complaints.

This was especially the feeling during the peak of the COVID-19 pandemic, during which these interviews were conducted. In particular, one respondent felt the primary digital channel at the time (email) can easily be skipped or ignored, and preferred to take a handwritten letter to file complaints.

Timely complaint handling system is critical for user trust and perceived value. 

The survey results contained a mixed reaction on receiving confirmation after raising a complaint: for straightforward matters, the complaint is acknowledged immediately, but as a problematic matter, complaint acknowledgment takes longer.

Information gaps should be reduced wherever possible. 

All interviewed felt a need for NBR’s toolset in particular to create awareness because there was previously inadequate information on how to report complaints, especially for illiterate people and people who don't live in major cities.

Progress to Date

Since deployment in July 2022, the following progress has been made:

  • 591 financial institutions covered
  • 5 channels
  • 3 languages
  • 28,000 messages even before formal launch

In the 4 months following deployment, Proto has reported that the automated consumer protection system already demonstrated significant results in engagement and inclusion, delivering the following results from July to October 2022.

  • 1009+ complaints lodged
  • 260k+ messages received
  • 1.5s response time
  • 31k+ chats handled
  • 20% FSPs webchat
  • 2% SMS, WhatsApp and Messenger
  • 78% NBR webchat

Next Steps

  • Listing in suptech solutions tracker
  • Composition of additional solutions
  • Webinar / panel upcoming
  • Impact assessment report

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