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Case Study


FINANCIAL CONSUMER PROTECTION AUTOMATION IN THE PHILIPPINES

The automated consumer protection system at the Central Bank of the Philippines
(BSP) set the standard for accessible recourse in emerging markets, handling a
4x surge in complaints without expanded wait times nor operational costs.

Client
Central Bank of the Philippines
Client





87%

initial average annual case growth


776

financial operators covered


4X

surge in complaints handled during COVID-19


1,932,514

messages handled in 2021


Case study
ProblemSolutionResultsApproachConclusion

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The multilingual Proto chatbot empowers financial consumers by giving them a
more accessible channel for raising complaints. This is in line with the central
bank's commitment to pursue innovations in financial services for the benefit of
Filipinos.
Benjamin E. Diokno
Governor, Central Bank of the Philippines
I talked to Bob on January 28… on February 3, the bank replied to confirm that
the amount was reflected back to my account. It was a smooth, quick, easy and
stress-free transaction. The amount I was waiting for was significant enough and
could greatly help us in paying our bills and buying essentials. In this
pandemic, every bit helps.
Kitty Elicay
Financial Consumer


ACKNOWLEDGMENT

The automated consumer protection system at the Central Bank of the Philippines
(BSP) was developed via the RegTech for Regulators Accelerator's competitive
process, with sponsorship from the Bill & Melinda Gates Foundation, Omidyar
Network, and USAID, and administration from Rockefeller Philanthropy Advisors.
Proto was selected from nine bids across seven countries, primarily due its
competency in Natural Language Processing (NLP) for under-resourced and
mixed-languages, which addressed the BSP's key requirement for Tagalog and
Taglish (Tagalog + English hybrid) understanding. The BSP's Center for Learning
& Inclusion Advocacy participated as a beneficiary and design partner during the
pilot-phase, following which, the system was procured directly by BSP for
consumer protection across the entire regulated financial ecosystem in the
Philippines. A very special thanks goes to the BSP's late, former governor
Nestor A. Espenilla Jr. for his vision and enabling role.



PROTO

‍Proto is the leader for inclusive chatbots and multilingual contact centre
automation in emerging markets. Proto’s AI Customer Experience (AICX) platform
is powered by proprietary natural language processing (NLP) for under-resourced
and rare languages. The Proto team has successfully developed novel
deep-learning techniques and regulatory partnerships to maximize consumer
experience, protection, and lifetime value across 20+ emerging markets.

BANGKO SENTRAL NG PILIPINAS

The Central Bank of the Philippines is the national supervisory authority for
all financial operators in the Philippines, overseeing commercial banks to
e-money providers to lenders. The BSP has a strategic mandate to promote broad
access to high quality financial services, and to undertake policy initiatives
aimed at enhancing financial inclusion, financial literacy, and consumer
empowerment. The BSP is also a founding member of the Alliance for Financial
Inclusion.




PROBLEM

The BSP manual complaints handling process had multiple limitations that caused
protracted complaint resolution times for consumers and administrative burdens
for consumer protection staff.

On the consumer-side, traditional channels such as written letter and walk-in
kiosk were outdated in the context of rising mobile penetration in the
Philippines, the texting capital of the world. Additionally, channels such as
email required a level of literacy and digital infrastructure out of reach for
low-income, rural, and historically-marginalized Filipinos. The overall recourse
process therefore had an urban, male, and high-income bias, resulting in the
vast majority of complaints to originate within the Metro Manila area, while
leaving customers outside the capital with fewer to no options in cases of
financial misconduct.

On the BSP-side, the laborious nature of case management was a binding
constraint on the ability to process complaints scaling 87% year-on-year during
the pilot-phase and 300% most recently (2020-21). Delays impaired timely
remediation, with the risk of discouraging usage of the consumer protection
mechanism. Additionally, human data entry was prone to errors and omissions,
resulting in an inconsistent consumer protection database for informed
policy-making. At the core of the problem was the question:



> How does a regulator discover and resolve consumer protection problems if it
> is only receiving a small fraction of total complaints?




SOLUTION

Proto deployed the BSP Online Buddy (BOB) chatbot as a replacement for the
manual process, enabling consumers to seek financial misconduct recourse
regardless of geography, gender, income status or education level. From the
consumer perspective, the chatbot is widely-available via Messenger, SMS,
Webchat and Viber.

The chatbot is capable of understanding emotional and typo-heavy complaints in
Tagalog, English, and Taglish (mixed Tagalog and English) across 776 of
financial operators and 24 product & service categories. Initially deployed with
an average chat-level intent classification accuracy of 92.84% for local
languages, the chatbot has gathered training data from over 12,200 consumer
chats per quarter in order to refine the NLP models for continuous dialogue and
accuracy improvement.



All complaints are automatically categorized, converted to cases within Proto's
Track dashboard, and disseminated to the financial operators for reply within 7
days. All ongoing communication between the consumers and financial operators is
monitored by BSP. The consumer protection staff are thus repurposed for
higher-order functions such as consumer case investigation, overdue case
follow-up, and policy development based upon the consistent data set gathered by
the automated system. Additionally, the data offers efficient insight into
potential market misconduct, with gender disaggregation, which was not provided
by the previous manual system. Crucially, the data also includes insights via
the SMS channel from rural and historically-marginalized populations that may
not yet own smartphones.





RESULTS

The automated consumer protection system delivered the following results as of
the end of 2021. In several cases with the previous manual system, the stats
were not gathered, thus limiting regulator insights and policy-making.


11%

more female usage


1,932,514

messages handled in 2021


92.84%

Chat-level accuracy


99.75%

Message-level accuracy


40%

cases via FB Messenger


35%

cases via Webchat


3%

cases via SMS


69%

consumer satisfaction

‍





APPROACH

From an innovator's perspective, working directly with regulators is not an
intuitive approach to scaling a certain technology. However, Proto's market
entry strategy focuses on first deploying its AICX solutions with industry
regulators. In the emerging world, this approach provides multiple, unparalleled
benefits.

First, localized Al technology has inherent capacity for good by including and
protecting underserved and marginalized people who face historical access
barriers. The regulators are empowered by consumer protection mandates and legal
frameworks, but they have resource constraints limiting their ability to keep
pace with disruptive technologies that pose potential risks for consumers.

Second, and most essential, the regulator is effectively a "data hub" by way of
its mandate to gather and monitor consumer protection communication in its
industry. For example, the BSP gathers structured local language data from 776
financial operators. For an Al innovator, this training data from a single
source is a highly efficient pathway to achieving a continuous machine learning
loop or network effect at massive scale. The result of this approach is
superior, localized NLP models for the industry domain that lead by example and
set a new the standard for consumer engagement for the private sector to
emulate.




BANKS

The INTUMWA complaints chatbot is deployed across the websites of Rwanda’s banks
for maximum exposure to consumers in need of protection. These banks can choose
to upgrade the chatbot with additional capabilities for general customer
support, payments, and account management.

Bank example
www.gtbank.co.rw


INSURANCE

The INTUMWA complaints chatbot is deployed across the websites of Rwanda’s
insurance providers for maximum exposure to consumers in need of protection.
These insurance providers can choose to upgrade the chatbot with additional
capabilities for general customer support, claims, and coverage applications.

Insurance example
www.radiant.co.rw



CONCLUSION

The multilingual Proto chatbot empowers financial consumers by giving them a
more accessible channel for raising complaints. This is in line with the central
bank's commitment to pursue innovations in financial services for the benefit of
Filipinos.
Benjamin E. Diokno
Governor, Central Bank of the Philippines
I talked to Bob on January 28… on February 3, the bank replied to confirm that
the amount was reflected back to my account. It was a smooth, quick, easy and
stress-free transaction. The amount I was waiting for was significant enough and
could greatly help us in paying our bills and buying essentials. In this
pandemic, every bit helps.
Kitty Elicay
Financial Consumer

The impact of this Proto AICX deployment is best captured with the story of
Kitty Elicay, a financial consumer in Manila who suffered an 8 month credit card
refund problem during the COVID-19 pandemic – she used the BSP chatbot to effect
a monitored resolution with her financial institution that saw the funds
returned within six days.

The Central Bank of the Philippines is pursuing a balanced approach to the risks
of digital financial services by keeping pace with technical innovation,
deploying leading NLP capability, and addressing known gaps in consumer
protection. In recognition of this effort, the automated consumer protection
system went on to win the Central Banking Fintech & Regtech Al Prize and
contributed to Proto's award of the Inclusive Fintech 50 by Visa, MetLife,
Accion and IFC.

As digitization expands financial services into underserved population segments,
regulators need to match this increased volume of first-time consumers with
protection systems designed for equal scale and complexity. Reliance upon
existing manual processes risks failing to comply with consumer protection
legislation and abandoning financial consumers to misconduct without recourse.
Failure to protect consumers from these risks also affects confidence in
financial technology, which could stifle growth of indigenous financial
providers. Consumer protection is therefore closely entwined with efforts to
improve inclusion and stability.



If you represent a regulator that faces a similar problem with accessible and
scalable consumer protection, please book a demo with the Proto team.

Free trial
PROFIT TECH
Controlled costs for scaling services across new and existing markets.

CONSUMER PROTECTION
Automated complaints processing for regulated digital ecosystems.

INCLUSION FOCUSED
Designed for consumers at the bottom of the pyramid.

Network effects
Powered by constant HermesAI™ learning across language domains.
Regulator compliance
Built in partnership with supervisory authorities across industries.
Global security
End-to-end encryption and secure connector for local databases.
PROFIT TECH
Controlled costs for scaling services across new and existing markets.

CONSUMER PROTECTION
Automated complaints processing for regulated digital ecosystems.

INCLUSION FOCUSED
Designed for consumers at the bottom of the pyramid.

Network effects
Powered by constant HermesAI™ learning across language domains.
Regulator compliance
Built in partnership with supervisory authorities across industries.
Global security
End-to-end encryption and secure connector for local databases.





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