RESPONSIBLE BUNDLING OF MICROFINANCE SERVICES to ensure that clients remember the pertinent details. This would involve trade-offs, however, given that the product’s complexity is closely tied to its attempt to cover a broad range of products with large differences in probability of damage due to weather events. A narrower product for the three main permanent crops (coffee, cocoa, and citrus), might be simpler but could also exclude some farmers who do not grow these crops. However, even with simpler products, recall should not be assumed to follow from initial understanding, but rather encouraged throughout the lifetime of a customer’s engagement with the provider. In the case of Crezcamos, the microfinance institution offering the insurance is the party best-suited to provide these reminders. It is a trusted institution that has an ongoing relationship with the client in connection with the “lead” credit product. Clients are aware of the physical location of branches and have regular contact with their loan officers, as well as the ability to contact them when a need arises. The delivery channel is thus well-positioned to be a resource for clients who need reminders of the crop insurance. The case of Crezcamos suggests that the responsibility to protect consumers in low-income settings might fall disproportionally on the distribution channel. In an ideal setting, consumers, distribution channels, insurers, and regulators would all share the responsibility of ensuring that consumers have the information 31 and support they need. However, in practice, the allocation of responsibility may not be equal. In rural Colombia, our study found that consumers generally understood but did not remember important details of crop insurance they purchased. The insurance company is located in the capital, far (in both distance and culture) from the farms of its end clients, and is not prepared or well-suited to communicate directly with them. At the same time, regulation generally emphasizes the disclosure of information at the time of sale, rather than post-sales support. This ecosystem leaves the distribution channel with the burden of providing ongoing support, which is not mandated but needed in practice to protect the consumer. Microfinance institutions and other distribution channels close to clients may be well-suited to bear this responsibility, but may not always have the tools. In the case of Crezcamos, shifting into a voluntary insurance offer may have been a first step in ensuring client understanding and awareness of their purchase decision. However, the lack of recall found in our study suggests that this may not be sufficient to ensure that consumers are fully protected. In the immediate term, the delivery channel is likely best suited to provide the support necessary to fill this gap through post-sale support. Over time, efforts to further empower clients both to make sound decisions and to seek information when needed would benefit clients and the institutions serving them. 31. Zimmerman et al. (2014) discusses the allocation of responsibilities for consumer protection in microinsurance among consumers, insurers, delivery channels, and other stakeholders. The authors suggest that responsibilities be allocated in accordance with stakeholders’ capacities, with a view to increasing the capacity of all stakeholders (and in particular of consumers themselves) to improve consumer protection outcomes over time. 31

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