UK FCA findings on digital design of loan processes in customers' online journeys

The UK Financial Conduct Authority (FCA) has published the findings from its review on digital design in customers' online journeys when accessing consumer credit, with related press release, identifying good practices and areas for improvement. Although the findings relate to consumer credit providers, other firms with a digital presence may find the examples of good and poor practice useful. The FCA found that some firms' digital design supported good consumer outcomes, such as using simplified language and offering explainer videos. Other firms had less well-designed digital platforms. A particular issue was a lack of "positive friction", meaning consumers were driven towards making quick decisions that did not align with their best interests.

Other areas identified for improvement include testing and quality assurance, where the FCA expects firms to test whether customers understand key product details, including fees; and management information and oversight, where the FCA found firms could better analyse data on customer journeys to identify where customers may be missing key information or progressing too quickly.

The review builds on research conducted by the FCA into deceptive design and "sludge" practices (i.e. unjustified frictions that make an option less attractive to consumers), with a research note also published on the same day, and forms part of the ongoing efforts to support the implementation of the consumer duty.

The FCA confirms it will continue to monitor firms' digital design strategies and app design under the consumer duty framework.

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