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PDCOB 8.5 Presentation of the choice architecture

PDCOB 8.5.1R

1A firm must ensure that the choice architecture is designed such that the presentation of the choices is:

  1. (1)

    accessible to the customer from the point at which they access their pensions dashboard view data onwards;

  2. (2)

    impartial, so that the customer is able to easily identify all of the choices available to them; and

  3. (3)

    designed in a way that enables the customer to understand all the choices available to them and to make choices based on this understanding.

PDCOB 8.5.2G

1A firm may choose the design, form, language and delivery for the presentation of the choices.

PDCOB 8.5.3G

1The following are examples of factors which may be relevant to a firm when designing the choice architecture:

  1. (1)

    whether each choice should be presented in the same way (this does not necessarily mean that the choices must be presented together as a whole); and

  2. (2)

    the use of pop-ups, layering, or drop-down functionality to present the choices. The choices may be grouped in common themes, but a firm should ensure that all choices remain easy to locate and that certain choices are not hidden or obscured.

PDCOB 8.5.4G

1Firms are reminded of their obligations under Principle 12 in relation to the consumer understanding outcome and communications to retail customers, in particular:

  1. (1)

    PRIN 2A.5.3R, which requires firms to support retail customer understanding and to communicate information to retail customers in a way which is clear, fair and not misleading; and

  2. (2)

    PRIN 2A.5.10R, which requires firms, where appropriate, to test and monitor communications to identify whether they are supporting good outcomes for retail customers and correct any deficiencies identified.

PDCOB 8.5.5G

1Firms are reminded they must comply with the requirements of Principle 12 and PRIN 2A on product design and product testing. In particular, firms are reminded of the requirements in PRIN 2A.3.4R, PRIN 2A.3.9R and PRIN 2A.3.10R, and should assess whether the presentation of the choice architecture:

  1. (1)

    is designed to meet the needs, characteristics and objectives of the target market;

  2. (2)

    does not adversely affect groups of consumers in the target market including groups with characteristics of vulnerability; and

  3. (3)

    avoids causing foreseeable harm to the target market.

PDCOB 8.5.6G

1Firms should make changes to improve their communications if common areas of consumer misunderstanding are identified through a firm’s testing or monitoring.