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Fair Digital Finance Evaluation Framework

Principle 5: Support for Financial Well-being

Digital finance products and services center user needs and experiences.

 

  • Digital finance companies have a clear commitment to building financial well-being.
    • Explicit and clearly articulated commitment to build the financial wellness of users included in a meaningful document, not just marketing materials.
    • Company has built in way of measuring financial well-being.
    • Company or organization demonstrates, with data, that product use supports financial well-being.
  • Digital financial products and services are designed to support users’ financial well-being.
    • Product does not utilize dark patterns nudging users into more costly product or services.
    • Timely and actionable notifications and reminders are provided when payments are due.
    • Users are not penalized for early repayment.
  • Digital financial products and services facilitate savings.
    • Offers round-up saving.
    • Offers automated saving.
    • Offers direct from paycheck saving.
    • Offers regularly scheduled saving.
    • Asks customers how much of their tax refund they want to put into savings before they receive the refund, and diverts the funds automatically.
    • Offers an option to move all extra money left in a customer’s checking account into their savings account just before they are paid their salary each time.
    • Supports savings goal-setting.
    • Offers savings products built into loan plans.
    • Offers other features that are supportive of saving.
  • Digital financial products and services protect consumers against overextension.
    • Engages in responsible lending.
    • Reports loans to credit bureaus.
    • Facilitates permissioned data sharing.
  • Digital financial products and services help consumers reduce debt, or at least don’t exacerbate debt.
    • Offers ways for customers to manage debt, such as a dashboard to see all accounts in one place, or selected debt consolidation.
    • Provides referrals to debt counseling or credit counseling.
  • Digital financial products and services help consumers protect or build their credit scores.
    • Offers a savings feature structured as a loan that helps build credit.
    • Uses cash flow-based underwriting.
  • Digital financial products and services provide financial information and promote financial education.
    • Provides clear information about how the offered services work and how they fit in with an individual’s larger personal financial strategy.
    • Provides a dashboard that shows all of a consumer’s accounts in one place.
    • Provides wealth building messaging.
  • Digital financial products and services support consumers to engage in pro-financial well-being behaviors.
    • Behavioral nudges.
    • Just-in-time reminders and alerts about payments due, overdrafts, other time sensitive responsibilities.
    • Incentives such as better interest rates or rewards for pro-FWB behaviors such as increasing savings or reducing debt.
    • Supports goal setting.
    • Overdraft protections.
    • Offers Balance After Bills: a feature that shows the consumer how much discretionary income they will have left after their regular bills are paid.
    • ffers spending analysis: a feature that shows the consumer where they are spending their money by category.
    • Offers budgeting tools.
    • Offers a voluntary block on spending at gambling establishments.
    • Offers voluntary cash withdrawal limits that customers can set for themselves.
    • Analyze eligibility for government benefits such as the EITC, notify the consumer, facilitate application for benefits.
  • Digital financial products and services track their customers’ financial well-being.
    • Regularly measure customers’ financial well-being with an established scale such as the CFPB’s scale and include the score as a KPI.
    • Provide customer-facing tools so that customers can track their own financial well-being score.