complaints, and how unresolved complaints may be escalated to the Bank of Ghana. The Guidelines also provide for how customers may lodge complaints with the Bank of Ghana if they are unsatisfied with the manner in which their complaints have been dealt with by the licensed institution, after which they may proceed to court for redress if they remain unsatisfied. In pursuance of section 7 of the Borrowers and Lenders Act, (2008), the Bank of Ghana also issued the Disclosure and Product Transparency Rules for Credit Products and Services in 2017, to help ensure that borrowers are able to make informed decisions before signing up for credit products or facilities. The Rules also seek to promote fair and equitable credit practices by lenders by: Prohibiting discriminatory lending practices for reasons that are non-commercial in nature (i.e. lenders cannot discriminate on the basis of tribe, religion, political affiliation, etc.); Requiring lenders to strictly ensure the suitability of credit products for various types of consumers; Requiring mandatory disclosure of all fees, interest rates, charges, and other terms and conditions prior to loan approvals and disbursements, and the signing of a Truth-in-Lending Agreement with each borrower; Limiting loan prepayment penalty fees which were previously set at the discretion of licensed institutions, to 0.25%. Customer Complaints Following the completion of the banking and SDI sector clean-up in 2019, the Bank of Ghana has intensified its market conduct supervision.
On-Site Conduct Supervision The Market Conduct Office undertakes both off-site and on-site supervision of licensed institutions with the aim of ensuring that these institutions comply with all consumer protection requirements under relevant laws and as prescribed by the Bank of Ghana. The maiden on-site conduct examinations were conducted by the Office from November 2019 to February 2020. The exercise involved officials of the Market Conduct Office visiting eight selected banks to examine the structures, systems, and processes in place to promote consumer protection and the early resolution of customer complaints, and to generally assess compliance with relevant market conduct rules. Specifically, the examinations covered a number of key areas including (i) Board and Management oversight of the complaints handling function; (ii) unfair banking practices; (iii) privacy and data protection issues; (iv) ambience of banking halls; (v) disclosure and transparency; and (vi) the content of marketing material. A summary of the major findings of the examination is presented in the table below. The relevant banks have committed to addressing the identified issues within timelines agreed with the Bank of Ghana. Summary of Findings from Maiden On-Site Market Conduct Examinations Area of Examination Findings A.Board and Management oversight of Complaint handling function consumer Reporting Officers (CROs) were not submitting reports on customer complaints to the Board.There was no evidence of Board of Directors reviewing the CROs reports for policy directions. Complaint reports of CRO were not shared with the Bank of Ghana. Complaint resolution procedure posters were not prominently displayed at banking halls for the attention of the public. Inadequate training of staff especially frontline/customer service officers and loan officers on the two consumer protection directives issued by the Bank of Ghana and other conduct related topics.