This is with reference to the Report of the GIRO Advisory Group, wherein comments from general public were invited.
The following are my comments:
01) Unique ID for every customer:
a) Each Biller has a unique allotted to their customers under which various sub-accounts are operated. Each customer in the Bharat Bill Payment System domain should be allotted a unique number. The number has to be quoted by the customer while entering into a service contract with the biller. This unique number can be compared with the “Unique Customer Identification Code for banks’ customers in India”, as advocated by Reserve Bank of India vide Notification No: RBI/2011-12/594 DBOD. AML.BC. No.109/14.01.001/2011-12 dt.June 08, 2012.
b) In the initial stages this number might be kept optional, as the rural customers might find it difficult to adhere to this rule. However, incentives should be offered to customers who opt for the Unique Number.
c) All the Billers should populate this number while on boarding new customers and aim to migrate the existing customers in a reasonable time-frame.
d) This unique number will be beneficial to students as the education timeline can be tracked over a period of time, thereby reducing educational certification fraud.
e) This unique number can also be incorporated for scholarship payments i.e the same number can be utilized for receipts and payments into a customer’s account
f) Over a period of time, it is expected that substantial sensitive data will be associated with the Unique Numbers. Hence, appropriate access levels to be in place.
02) Loyalty Points:
a) To motivate quick migration of customers to the BBPS graded loyalty points should be introduced.
b) The loyalty points to start with registration of the customer and be added as and when payment is made.
c) Loyalty points can be redeemed against Outstanding Bills.
3) Billers: The scope of the billers can be extended. Payment can be on a generated bill or on demand.
a) Monthly Railway season tickets
b) Monthly Bus passes
c) Metro season passes
d) Monthly Toll way passes
e) Religious institutions
f) Club / Association fees
g) Monthly Maintenance charges of housing societies
h) Cinema Tickets
i) Event Tickets
j) Life Insurance
K) Non-Life Insurance
l) Magazine subscriptions
4) Single BBPS website:
a) Multiple payment modes should be made available viz Debit Card, Credit Card, Net Banking, Semi-closed cards, IMPS.
b) Each payment is authorized through OTP (One-Time Password).
c) This OTP can be in addition to the authentication done by the Payment provider.
5) APPS :
a) Appropriate APPS be developed for BBPS payments.
b) The focus should be on fewer footfalls at Customer Service Points (CSPs)
6) Gas Companies – Special Category
a) A substantial amount of cash is collected by LPG Gas Agencies and deposited at the Banks. The cash collection will be double in case the subsidy amount is also included.
b) Concerted efforts should be made to migrate the cash payments to the LPG Gas agencies to the BBPS platform. This will substantially reduce the retail cash collections in our country.
c) Option: – i) BBPS to have a eWallet. ii) LPG cylinder amount to be blocked on LPG refill booking. Iii) On delivery, the amount to be released and transferred to the LPG company.
07) Late Payments:
a) Late payments up to a certain number of days after the due-date should be accepted.
08) Settlement model:
a) Settlement Model B is preferable
09) BBPS Head Office:
a) It should be in Hyderabad,
b) IDBRT is already in Hyderabad
c) Centralization in Mumbai is avoided
a) Billers should have access to the billing information of only their services
b) They should not have access to the billing information of other service providers, as the data might be misused
c) No companies should be allowed to scan the billing information especially credit agencies
11) ACH (Debit) Integration:
a) Customers would have given ACH (Debit) mandates to the billers. Online updation of ACH transactions should be in place
b) Once the bill amount is received through ACH (Debit) mode, no demand for the same bill to be made on the BBPS platform
12) Complaint Resolution:
a) The website to have a complaint resolution module.
b) Customers to be penalized in case of frivolous complaints.