The FCA has reviewed how firms design digital and in-app loan processes, and, while it has seen much helpful behaviour such as clear, simple language and explanations, it also found that some processes:
- lack the positive friction the FCA likes to see to give customers time to think – and generally put speed over ensuring good consumer outcomes;
- failed to tell customers some key information, such as on cost;
- did not allow the identification of vulnerable customers;
- used pre-selected defaults and other practices that could inappropriately exploit customers’ biases
The FCA urges all firms to consider its conclusions, although its survey comprised only lenders.