seniors and those with limited access to digital technologies at the mercy of banks regarding exclusion.<\/strong><\/p>\nAccording to the organization, the current draft grants a level of discretion to issuers<\/strong> on whether customers can continue to access services or be excluded from the financial system<\/strong>. This could disproportionately impact older individuals and consumers facing real access barriers, such as limited connectivity, a lack of technological skills, or mobility issues.<\/p>\nODECU argues that instead of safeguarding rights and protecting vulnerable groups, the proposal is too weak and overly reliant on the discretion of individual banks.<\/strong><\/p>\n\u201cThe CMF cannot settle for a rule that lets each issuer determine, based on their own criteria, who deserves support and who does not. When access to basic financial services<\/strong> is at stake, regulation cannot hinge on open formulas,\u201d stated Stefan Larenas Riob\u00f3, president of ODECU.<\/p>\nThe organization criticized the consulted proposal for not even acknowledging basic rights for customers<\/strong>, such as the ability to request inclusion in the exceptional regime, receive a well-founded response from their bank, or access clear complaint mechanisms.<\/p>\nAdditionally, ODECU questioned that the CMF only requires informing customers of the risks associated with maintaining coordinate cards<\/strong>, without setting minimum standards for how to deliver that information or ensuring it is understandable and accessible.<\/p>\n\u201cProviding information is not enough<\/strong>. It is essential to ensure real understanding, effective support, and conditions that enable informed decision-making. Otherwise, the consumer bears the cost of technological migration<\/strong>,\u201d Larenas Riob\u00f3 concluded in a press statement.<\/p>\nThe organization warned that the digital transition must not become a factor for financial exclusion. They believe that if authorities \u201cacknowledge that there are people for whom technological change is not feasible, the exception should be designed as a regulated right<\/strong>, with objective criteria and clear procedures.\u201d They also proposed to incorporate compensatory security measures<\/strong> due to the increased vulnerability associated with coordinate cards.<\/p>\nAmong their suggestions, ODECU<\/a> recommended establishing \u201ccommon criteria for defining exempt groups<\/strong>, creating a right for requests and reviews, requiring support for assisted migration, and publishing metrics to monitor the impact of the regulation.\u201d<\/p>\nFinally, the organization urged the CMF to correct its course<\/strong>, with Larenas Riob\u00f3 emphasizing that \u201cfinancial inclusion requires clear regulation<\/strong>, with a rights-based approach that guarantees access, security, and dignified treatment for all consumers.\u201d<\/p>\n<\/div>\n