Designing fair and effective disclosures

How do we balance Bureau values, like transparency and free access to information, with facts about cognition, emotion, and shopping behavior?

Project year
2014
Organization
CFPB
Project role
User experience
Project team
Mollie Bates, Elizabeth Bond

For those of us who function comfortably in our plastic-driven economy, it's easy to ignore the prepaid cards found at the bottom of most card kiosks in stores.

But for individuals who are unable to join our banking and credit system, or have been burned by it one too many times, these cards are crucial. And getting basic information, like a card's balance, can be hard or expensive to find out, making already-vulnerable consumers even more susceptible to predatory practices.

The CFPB is working to protect consumers by regulating the prepaid card industry. Part of this initiative involves a standardized, mandatory disclosure that consumers can access before buying a prepaid card. As the user experience designer on the team responsible for designing the disclosure, I drove design decisions through user research and testing.

It has been a formidable challenge to balance observed user needs with policymaker goals.

Personas

Through focus groups, I defined three major types of prepaid card users.

However, in government, it's tricky to define audiences, because we must serve everone.

Instead, the insights from in this part of the design process helped shape a behavioral design strategy later on.

Designing for behavior change

My psychology background allowed me to identify common behaviors and decision points throughout the prepaid card purchase experience.

The design challenge was to create a solution that disclosed information, but also served as a way for consumers to make better decisions about these cards in the first place.

Working with the legal and behavioral economist team responsible for writing these federal regulations required the design team to provide a rigorous, evidence-based rationale for all decision decisions. I chose to apply BJ Fogg's Behavior Model to define testable design goals that made sense to both graphic designers and subject-matter experts.

Designing the short disclosure

This disclosure will appear on the back of every prepaid card package, like a nutrition facts label. Its purpose is to help consumers comparison shop.

Often sold in the checkout line, consumers have very little time to make shopping decisions about which prepaid card to get. A major challenge was choosing what information to emphasize, and reducing the amount of fine print.

Here's how we chose what ended up on the short disclosure:

There are two special use cases for this disclosure: payroll cards and government benefit cards. People are often not informed of their right to receive funds in other forms of legal tender–oftentimes because issuers receive kickbacks from banks.

Even people who hadn't been burned by the system described an almost emotional attachment or response to certain fees. These fees drive decision-making for many consumers, regardless of how attractive or ludicrous the rest of a card's fees are. This informed what fee information we chose to emphasize on the short disclosure.

These four emphasized fees on the top lines of the short disclosure were described as immediate and unavoidable by consumers.

The first three fees below the emphasized lines were not emphasized because consumers ignored them in testing. They were not seen as immediate, but faraway and avoidable. If a fee was seen as avoidable, it was usually not a deal-breaker.

Squeezing all terms and conditions in a short space is unreasonable, but fine print is usually ignored. Indicating the total amount of fees on the card serves as a behavioral trigger, and providing many ways to access more information makes the fine print in our disclosure clear and actionable.

Designing the long disclosure

The long disclosure includes what's on short disclosure, plus all other fee information about the card. It will be included inside of every prepaid card package and can be seen online.

We decided to create a short disclosure to give consumers a sense of control without feeling overwhelmed when shopping. For those who do want to consult all the information before making a purchase, or need to look up information afterward, the full disclosure will be available online, accessible on all devices (including screenreaders), and clock in at a whopping 7kb.

The design team helped write this portion of the regulatory text, so that industry publishes uniform, honest, future-friendly content that doesn't do uncool things like mysteriously disappear, or show different information to different users. We'll be providing the code and the assets on Github, so there shouldn't be any excuses :).

Designing an SMS disclosure

It's one thing to have fee information before buying a prepaid card, but most consumers will not take the time to memorize that information.

Consumers need a way to look up information in a hurry, after packaging and inserts have been thrown away.


The prepaid card industry will be asked to provide consumers with these disclosures in mid-2015.

The design team's proposed disclosure is based on the insight that to best help consumers, we must design for their behavior. It is better to focus on a handful of elements to make a connection with them, rather than an assumption that full disclosure is the only good disclosure.


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