In its response to the FCA Discussion Paper on the Future Disclosure Framework, Aegon has called for the new approach to reflect the digital age and how consumers obtain and use information in the ‘real world’ including in other walks of life.
Steven Cameron, Pensions Director at Aegon said: “We strongly support the FCA’s desire to improve the disclosure regime in today’s digital age to make communications engaging, understandable and relevant. The days of having a single static document containing all possible relevant information are long gone in other walks of life, with individuals basing decisions on information often obtained in bite size chunks from a range of different sources. A future disclosure framework should take a lead from the Consumer Duty, which is encouraging firms to ‘reflect how consumers actually behave and transact in the real world’ *.
“In today’s digital age, the use of layering and allowing individuals to ‘click through’ to obtain more detail has huge potential. Encouraging and enabling firms to explore other creative approaches such as personalised animation or video should also play a big part in the future disclosure framework.
“Ideally, as a natural extension of the Consumer Duty, firms should have more control over the design, delivery, presentation and content of their disclosures to meet the needs of the target market for their products and services. Some checks and balances will always be needed for example to allow individuals and / or their advisers to draw comparisons between products, or to assess information in a meaningful and clear context.
“However, we need to learn from past issues with the likes of PRIIPs disclosures. Too great a focus on standardisation and comparability mustn’t take priority over making communications engaging, understandable and relevant to the individual.”