Chetna Batra, Gausia Shaikh, Bhargavi Zaveri
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This technical note is a response to the RBI proposal for the issuance and operation of pre-paid payment instruments in India. The response note discusses issues concerning (a) competitive neutrality; (b) entry barriers; (c) excessive operational burdens; (c) consumer protection; and (d) the rule of law in the licensing process for issuers of pre-paid payment instruments. It makes recommendations on the changes required to the draft framework to align it with current thinking on payment systems and global standards for regulating this segment of the financial sector.
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