The futility of utility bills for address verifications

I was recently working with a traditional financial service provider to launch a product online. And they insisted on applicants providing utility bills. Then the trouble started! Even though argued strenuously against this, but they also brought valid arguments. So, I had to take a step back to ask; why the hell do we need utility bills to start with?

I’m sure you’ve all experienced this at different times – your bank tells you a sexy story about applying for something, and bam, they hit you with a request for a utility bill. To make it worse, the strident officer across the desk or on the phone doesn’t even know why a utility bill was required.

Before you start cursing at them or berating their bosses, let’s ask – why does anyone need utility bills? Forget about the fact that the officers that ask for these may not know their left hands from their right nostrils; the truth is, there are legal requirements for, not for utility bills, a verifiable address of every customer within the financial services industry.

Thou shalt know your customers

There is an arcane financial rule called Know Your Customer (KYC), which is the same thing your mum does when your sister drags in that funny looking boyfriend of hers. She goes, “Who is your dad? Where’s your family from?”. After taking loans sending her to school, she ain’t gonna risk that for some supposed slimeball.

OK, that’s a little bit over the top.

The rules of financial services require that banks, insurers, brokers, etc., should know their customers well enough. I have previously written a playbook for digital KYC here, so if you like to bore yourself to death, you can read more.

A critical element of KYC is verifying that the customer lives where they say they do. And how do you go about that? Require that they produce a utility bill, issue in their name against the address where they purportedly live.

Like everything Nigerian, we have forgotten the spirit and just tack ourselves to the letter. KYC never require that utility bill must be produced; the utility bill is a means to an end. If you get on the CBN rules for KYC and the SEC rules for the same, there is a gazillion way for a customer to prove the veracity of their address.

What the hell are utility bills?

And what are utility bills to start with? These are receipts from the likes of PHCN, water corporation, etc., that show they deliver some modicum of services to you.

And that’s where all the problems start.

Using utility bills to prove the veracity of addresses in Nigeria is just plain dumb. And there are a gazillion reasons for that:

Most people don’t have utility bills because they don’t even get served any services to start with. Only a few Nigerians have services from recognized billers: Over 100m Nigerians don’t have water delivered to them; 43% of those who have electricity don’t have meters which means no proper bills, And nobody has landlines anymore. After all, NITEL has gone to be with the lord. So, what then do they use?

Many people live in places they don’t have access to the PHCN bills. At best, they know the meter number and use that to buy electricity tokens. As long as the tokens power the meters, who cares if it’s the name of a dog that’s on the utility bill?

Worse still, utility bills can’t be validated, and nobody validates them. Any idiot can just clone a bill, and that’s it. That part is what pains me; why go through the hassles of asking for a utility bill, creating a donnybrook in the process, and you can’t even confirm if that important utility bill is legit or not?

But but but, dearest fintech, before you join me on a foolish quest to bash utility bills, watch your back; you could find out the expensive way when fraud happens on your platform, and the Government asks for your KYC. Kirikiri doesn’t have Gucci uniforms!

How then can one solve the problems of address verifications to meet the requirements of verifiable addresses for customers?

KYC as a service

Over the last few years, a flurry of digital KYC companies, such as VerifyMe and YouVerify, has cropped up in Nigeria. They have pretty solved a few of the problems, but gaps and challenges exist.

First, they are not cheap to start with; the cost ranges from N750 per check and above. Scale that on thousands of customers, and your cost of customer acquisition starts to look like a nightmare. Attempts by a few brave fintechs to have customers to pay for this haven’t gone well. Customers don’t find that cost funny at all!

Secondly, these guys have also not put in the best of names to do the verification for them. I’ve personally seen these guys not able to verify clear addresses that Google, far away in the US, can find with a single click. Addresses that the likes of DHL and UPS can deliver to become impossible unless someone adds “Nearest bus stop or landmark.” Obviously, they use poorly trained officers who can’t find their own names on large billboards.

Thirdly, verifying addresses within gated estates is a challenge. They require that your customers are around or call the gates ahead. And if they can’t get them on the phone (most people don’t pick unknown numbers), then they mark the addresses as unverified, and there goes the N750 verification cost. That’s it!

Lastly, they also save previous addresses, which means even when the addresses ain’t valid anymore, they still validate it, giving those who rely on this feedback a false sense of hope.

Paper OTP as an alternative

Interestingly, while I haven’t tried this directly, I find the methods that Google for Business use for address verification ingenious. They simply post a paper OTP to you, and then if, and a big if, you receive it, you come to enter the code into your app, and we can all rest assured that someone got to your house.

While this sounds nice and interesting, the jury is out on first, the cost-effectiveness of this and the ability to scale it out.

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