Financial consumer protection framework

The CBK's framework should establish clear timelines and enforcement mechanisms for transparency disclosures, particularly around fee structures and product terms, to prevent the information asymmetry that currently exists between retail customers and financial institutions in the Kenyan market.

Data privacy standards within the framework must address the specific operational challenges of Kenya's distributed banking infrastructure, including mobile money platforms and agent networks, where customer information flows across multiple third parties without standardized protection protocols.

Fair treatment provisions should include explicit dispute resolution pathways and compensation thresholds for retail customers, moving beyond advisory standards to create enforceable remedies that align with CBK's supervisory capacity and the maturity of Kenya's financial ombudsman mechanisms.