Countries take different approaches to supervising and enforcing consumer protection, reflecting variation in legal frameworks. Multiple regulators are often involved in overseeing consumer protection in relation to financial services. In countries with broad consumer protection legislation in place, the agency responsible for implementing this legislation may also have a responsibility for consumer protection in financial services along with other goods and services. Financial regulators, including central banks in many countries, also often have a responsibility for overseeing consumer protection in financial services as part of business conduct regulation of financial service providers.

Each approach has its challenges. The institutional approach to regulations, where for example a central bank implements consumer protection provisions in relation to regulated financial institutions, excludes unregulated financial service providers. Such an approach also poses implementation challenges, as it would likely entail multiple regulators with varying levels of capacity. A functional approach, with the focus on the service received by the consumer regardless of the type of the provider, can address the problem inherent in the institutional approach. However, agencies responsible for implementing broader consumer protection such as consumer protection authorities, competition authorities, or ministries of trade and industry, often face the challenge of assuming the responsibility for financial consumer protection as they lack the capacity and knowledge of the financial sector.<sup>7</sup> Regardless of the chosen approach, effective implementation of the law requires clearly defining the role of the agencies involved and assigning a single entity for handling complaints and inquiries by consumers. In recent years several countries established a single agency responsible for consumer protection issues for retail financial services. Among them are the Financial Consumer Agency of Canada and the National Credit Regulator in South Africa that is solely responsible for retail credit. The United States and United Kingdom are also moving in this direction following the recent crisis.

In the survey, 70 percent of countries (99 countries) report that central banks or bank regulators are responsible for at least some aspect of financial consumer protection.<sup>8</sup> Of these, 68 countries assigned this work to a specific department or unit, the majority of which are relatively recent. Out of the 60 countries that provided their units’ date of establishment, 65 percent were created after 1999, and 45 percent after 2005.

> 7 Rutledge (2010)  provides  detailed examples of various institutional arrangements in Europe and Central Asia.

> 8 It should be noted that only Central Banks were surveyed by _Financial Access_ about consumer protection, but in some countries it is not the Central Bank that is responsible for consumer protection. Thus, the survey results may understate a country’s scope of involvement in consumer protection where an agency other than the Central Bank is responsible. The analysis of this section and subsequent sections is based on the agency the country lists as responsible for consumer protection, regardless of whether it is the Central Bank or not. Nevertheless, BIS (2009) reports that, based on a BIS (Bank for International Settlements) survey of central banks in 2008, 50 percent of central banks play some role in consumer protection.

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