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68% of consumers don’t 
comparison shop before 
buying a card. 
1
“It was a lot of information.” 
The most common reason given for not reading disclosures 
before purchase.
How do we balance things that 
impact protect consumers, like 
transparency and full 
disclosure, with facts we know 
about cognition, emotion, and 
shopping behavior? 
3
Thinking beyond the fine print 
Thinking about fee disclosures beyond printed information. The 
entire purchase experience as a set of actions, behaviors and 
decisions.
Consumer wants to buy a prepaid card 
At a bank In-store Online 
Consumer compares two 
simple tables side-by-side 
on packaging. 
B B A B 
Consumer purchases best prepaid card for them 
Consumer compares two 
simple tables on two 
different websites. 
Consumer compares two 
simple tables side-by-side 
on brochures. 
Visits websites on phone for 
full disclosure table. 
Clicks prominent link to 
full disclosure table. 
Refers to handouts with 
full disclosure table. 
DECISION 
MADE 
DECISION 
MADE 
DECISION 
MADE 
DECISION 
MADE 
DECISION 
MADE 
DECISION 
MADE 
NEEDS 
MORE 
INFO 
NEEDS 
MORE 
INFO 
NEEDS 
MORE 
INFO 
A A 
A 
A B 
B 
A B
Design goals 
1. Trigger comparison shopping 
2. Full disclosure of fees 
3. Easy to understand 
6
Less is more. 
7
Visual hierarchy (salience, visual cues) 
Visual hierarchy guides the viewer through content in an 
ordered way. It is created through visual contrast, which is 
made up of size, alignment, negative space, or proximity of text.
We use visual hierarchy to emphasize four fees by increasing the font size and weight of the fee, leading the 
viewer’s eye to these fees first. These first four fees deserve the viewer’s attention first because users cited 
these fees as the dealmakers or breakers in choosing a card, either based on what they see at the store, or 
more often than not, their previous experience with other cards.
An example of the alert/call-to-action proposed for prepaid cards used for payroll purposes.
Plain language 
The fees should be clear. They should feel in control. Full 
disclosure, but not in the way.
Plain language also means less fine print, less jargon.
Delegating information elsewhere 
Whatever is not on the outside of the card packaging is on the 
“long form,” a full disclosure inside the package, or online.
Testing
Testing 
Last testing took place in Kansas City, Missouri in April. Hour-long 
in-depth interviews with consumers to understand their 
comprehension of the disclosures, and get background info on 
their experiences with prepaids. 
We tried to set up realistic shopping scenarios with card 
package prototypes, each with different fees. Consumers were 
asked to select what they thought was the best product for 
them.
Prototype 
Uses the most-common industry paper package. Main 
disclosure is on the back, full disclosure is inside.
The form’s design allowed participants to easily find and 
understand fees. In shopping scenarios, most participants made 
decisions based on the four top-line fees on the label, which 
have the least cognitive overload.
“The fees were just lower” was the most common reasoning for 
their choice, yet it meant something different for each 
person.
Testing insights 
Consumers may not always compare those fees with other 
products, but they are comparing them to their own previous 
experiences, bad or good. The final shopping choice is usually 
based on “gut.” 
If this is how consumers are behaving, it’s important for us to 
make those main fees appear as clear as possible. To best help 
consumers, it may be better to focus on a handful of elements 
and connect with them, rather than “full disclosure.”
Now vs. later 
Top line fees are usually fees with immediate impact on the consumer. The incidence-based fees are long-term 
fees or services that may never be used.. The now is more important at purchase time than the later.
Supporting Research 
22 
Less is more
Less fees enable more comparison 
Research suggesting limits on our capacity for processing 
information. 
George A. Miller, “The Magical Number Seven, Plus or Minus Two: Some Limits on Our Capacity for 
Processing Information” Psychological Review, 1956, vol. 63, pp. 81-97.
Less choice reduces shopping stress 
Research suggesting that less consumer choice greatly reduces 
anxiety and stress for shoppers. Increases confidence. We want 
consumers to feel like they have agency. 
Barry Schwartz. "The Paradox of Choice: Why More is Less.” 
Sheena Iyengar, Mark Lepper. "When Choice is Demotivating: Can One Desire Too Much of a Good 
Thing?" Journal of Personality and Social Psychology, 2000.
There is no “best” card for consumers 
Some groups advocate for more information so that people can 
make the best choice for themselves. Research suggests though, 
that people make decisions based on information we’ll never 
know: their past experiences and gut feelings at time of 
purchase. 
Norbert Schwarz. "Meacognitive Experiences in Consumer Judgment and Decision Making." Journal of 
Consumer Psychology, 2004.
Insights from the Fogg Model 
The likelihood of someone looking at the redesigned simple label and eliciting the desired outcome 
(comparison shopping) depends on their motivation, ability, and triggers. We identified some 
constraints based on what we knew about shopping behavior, our focus groups, testing, and interviews 
with prepaid card consumers. 
Shoppers show low motivation to comparison shop because of cognitive overload due to disparaging 
information (e.g., fees don’t match up between products) 
Triggers are created by information that shoppers are familiar with (e.g., they’ve been burned by it 
before). 
Shoppers show low motivation to go through a full disclosure because of cognitive overload due to sheer 
amount of information. 
Low Ability – consumers need to do all of this while waiting in the checkout line, they’ll give up. 
Applying basic principles from the Fogg model supported our approach of emphasizing a handful of 
elements using visual hierarchy and plain language. Some of these were triggers to look up more 
information or remember past experiences. By lowering the amount of things to read or consider pre-purchase, 
we increase motivation to consult disclosure, and increase shopping decision ability.

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Design for Action Conference: Modernizing fee disclosures

  • 1. 68% of consumers don’t comparison shop before buying a card. 1
  • 2. “It was a lot of information.” The most common reason given for not reading disclosures before purchase.
  • 3. How do we balance things that impact protect consumers, like transparency and full disclosure, with facts we know about cognition, emotion, and shopping behavior? 3
  • 4. Thinking beyond the fine print Thinking about fee disclosures beyond printed information. The entire purchase experience as a set of actions, behaviors and decisions.
  • 5. Consumer wants to buy a prepaid card At a bank In-store Online Consumer compares two simple tables side-by-side on packaging. B B A B Consumer purchases best prepaid card for them Consumer compares two simple tables on two different websites. Consumer compares two simple tables side-by-side on brochures. Visits websites on phone for full disclosure table. Clicks prominent link to full disclosure table. Refers to handouts with full disclosure table. DECISION MADE DECISION MADE DECISION MADE DECISION MADE DECISION MADE DECISION MADE NEEDS MORE INFO NEEDS MORE INFO NEEDS MORE INFO A A A A B B A B
  • 6. Design goals 1. Trigger comparison shopping 2. Full disclosure of fees 3. Easy to understand 6
  • 8.
  • 9. Visual hierarchy (salience, visual cues) Visual hierarchy guides the viewer through content in an ordered way. It is created through visual contrast, which is made up of size, alignment, negative space, or proximity of text.
  • 10. We use visual hierarchy to emphasize four fees by increasing the font size and weight of the fee, leading the viewer’s eye to these fees first. These first four fees deserve the viewer’s attention first because users cited these fees as the dealmakers or breakers in choosing a card, either based on what they see at the store, or more often than not, their previous experience with other cards.
  • 11. An example of the alert/call-to-action proposed for prepaid cards used for payroll purposes.
  • 12. Plain language The fees should be clear. They should feel in control. Full disclosure, but not in the way.
  • 13. Plain language also means less fine print, less jargon.
  • 14. Delegating information elsewhere Whatever is not on the outside of the card packaging is on the “long form,” a full disclosure inside the package, or online.
  • 16. Testing Last testing took place in Kansas City, Missouri in April. Hour-long in-depth interviews with consumers to understand their comprehension of the disclosures, and get background info on their experiences with prepaids. We tried to set up realistic shopping scenarios with card package prototypes, each with different fees. Consumers were asked to select what they thought was the best product for them.
  • 17. Prototype Uses the most-common industry paper package. Main disclosure is on the back, full disclosure is inside.
  • 18. The form’s design allowed participants to easily find and understand fees. In shopping scenarios, most participants made decisions based on the four top-line fees on the label, which have the least cognitive overload.
  • 19. “The fees were just lower” was the most common reasoning for their choice, yet it meant something different for each person.
  • 20. Testing insights Consumers may not always compare those fees with other products, but they are comparing them to their own previous experiences, bad or good. The final shopping choice is usually based on “gut.” If this is how consumers are behaving, it’s important for us to make those main fees appear as clear as possible. To best help consumers, it may be better to focus on a handful of elements and connect with them, rather than “full disclosure.”
  • 21. Now vs. later Top line fees are usually fees with immediate impact on the consumer. The incidence-based fees are long-term fees or services that may never be used.. The now is more important at purchase time than the later.
  • 22. Supporting Research 22 Less is more
  • 23. Less fees enable more comparison Research suggesting limits on our capacity for processing information. George A. Miller, “The Magical Number Seven, Plus or Minus Two: Some Limits on Our Capacity for Processing Information” Psychological Review, 1956, vol. 63, pp. 81-97.
  • 24. Less choice reduces shopping stress Research suggesting that less consumer choice greatly reduces anxiety and stress for shoppers. Increases confidence. We want consumers to feel like they have agency. Barry Schwartz. "The Paradox of Choice: Why More is Less.” Sheena Iyengar, Mark Lepper. "When Choice is Demotivating: Can One Desire Too Much of a Good Thing?" Journal of Personality and Social Psychology, 2000.
  • 25. There is no “best” card for consumers Some groups advocate for more information so that people can make the best choice for themselves. Research suggests though, that people make decisions based on information we’ll never know: their past experiences and gut feelings at time of purchase. Norbert Schwarz. "Meacognitive Experiences in Consumer Judgment and Decision Making." Journal of Consumer Psychology, 2004.
  • 26. Insights from the Fogg Model The likelihood of someone looking at the redesigned simple label and eliciting the desired outcome (comparison shopping) depends on their motivation, ability, and triggers. We identified some constraints based on what we knew about shopping behavior, our focus groups, testing, and interviews with prepaid card consumers. Shoppers show low motivation to comparison shop because of cognitive overload due to disparaging information (e.g., fees don’t match up between products) Triggers are created by information that shoppers are familiar with (e.g., they’ve been burned by it before). Shoppers show low motivation to go through a full disclosure because of cognitive overload due to sheer amount of information. Low Ability – consumers need to do all of this while waiting in the checkout line, they’ll give up. Applying basic principles from the Fogg model supported our approach of emphasizing a handful of elements using visual hierarchy and plain language. Some of these were triggers to look up more information or remember past experiences. By lowering the amount of things to read or consider pre-purchase, we increase motivation to consult disclosure, and increase shopping decision ability.