Product information

Beyond the now well-known arguments and evidence of the vast inefficiency of guidance documentation, which is particularly applicable to digital financial advice due to the characteristics
outlined, but appears solvable through continuous storage, simple, clear, understandable and comparable information on financial products is standardized Format becomes even more important in
the digitization of customer relationships. For example, the first scientific evaluation on the design of so- called PIBs (Product Information Sheets, or short-form disclosure documents, key investor information) for Germany shows that regulation based on clear sample texts is based on minimum labeling requirements for all major financial products for consumers and consumers would have a high utility value for them.

100 The use of standardized product information is thus closely linked to the benefits of investment advice.

The mere timely and systematic publication of PIBs outside of concrete advisory services alone constitutes a serious shortcoming of existing regulation. In addition, there is the extremely fragmented
and urgently needed regulation of product information for financial services, which from the customer’s point of view should serve to solve related problems. A concrete solution would be tangible: 104

• All providers, regardless of their registered office, who wish to sell a financial service in Germany, are obliged to provide standardized product information publicly available for all their financial services,
regardless of the time of purchase. This applies uniformly to all financial services provided by banks, savings banks, investment funds, insurance companies and all similar providers, regardless of the access channel and the type of consultant.

• On the part of the competent financial supervisor, concrete standardized PIB models are specified, of which in principle no derogation is allowed. Such patterns should be based on “best practice” examples, as they have been included in the quoted study 105. The developed benchmark can be understood as a minimum requirement for the distribution of financial services.
The PIBs used by the providers are reviewed regularly, at least on a calendar year basis, by the responsible financial regulator. In the event of a substantial deviation, the competent financial regulator
must request the respective provider with a short notice period for rectification. If a provider does not comply with such a request, then the corresponding product may not be distributed further.

• The financing of such a system of standardized PIBs as minimum requirements for the distribution of all financial services can be carried out by means of pay-as-you-go systems, analogous to, for example, DPR or PIB-specific license fees. There would be good opportunities for clear, simple, understandable and comparable product information for all financial services that citizens need for most needs and occasions. The on-going transparency would then allow consumers to actually operate on a “market” and participate in
“competition”. The idea of a social market economy would not remain closed to the financial sector.

The digitization of many spheres of life in the last twenty years poses many new challenges for many consumers, and especially in view of the ever-accelerating development of technology on the one hand and the inclusion of more and more areas of citizens’ lives on the other. Participation and access must be ensured in terms of technology and content as well as protection and transparency. The digital world
requires consumers who do not see themselves as victims of change, but who take advantage of opportunities and help shape the changing world, while at the same time assessing the change in risk- return distribution with appropriate risk understanding.

Essential foundations remain consumer confidence and consumer competence. The ability of consumers to become active market players in the digital world goes far beyond the traditional idea of protection and prevention. Consumer questions about the digital world do not replace those of the analog world. The analogue world remains parallel and partially interlaced with the digital world. The interaction between the analog and the digital world is of particular importance when, for example, heuristics of the analogue world are used unchecked in the digital world and vice versa. An analogue “anchor” will always remain, citizens will act as (analogous)

There are grave differences between the digital world on the one hand and the traditional or analog world on the other with regard to time / speed, reach / quantity, irreversibility / storability and the
associated transaction costs. This applies both to the private sphere of life, as well as to the world of work and civil society. The advantage of very cheap digital production and communication is the need
for technical equipment. Consumers are exposed to a wealth of information that would in principle force them to focus on the essential information, the advantage of the gigantic diversity of information can turn into a serious disadvantage very quickly if, for example, the amount of information is growing steadily and can hardly be processed and the imperatively following information and processing heuristics lead to misinformation (information overload, choice overload). Do the patterns of behavior, competences and heuristics of the analogue world also function in the digital age?

Which particular opportunities and risks arise for trusting, vulnerable and responsible consumers? In what form and to
what extent does the risk-return split change as a result of changed supplier-buyer relationships in the new business models?

Finally, the “data traces” that are neglected in the use and processing of the information also play an important role, directly affecting privacy, including the protection of personal data, especially when data is being read out and / or processed unnoticed, an obvious example is the personalized one (individualized) advertising that uses targeted information about a person on the net, but more profound are e-targeting and e-profiling of different types, both in relation to technical or geographic price differentiation, and as a consequence of conscious non-information and e-profiling The chances of using the digital data (traces) are unequally distributed, although the transaction costs for both sides of the market are falling, but the supply side is gaining in importance through data mining and data a
Tracking (Big Data) a significant information advantage, which can lead to a gain in information power.

Therefore, in this context we can also speak of “digital shadow”, which should be taken into account in consumer policy.