Report No: 78783-BG PUBLIC SECTOR–OPERATED PRICE- COMPARISON WEBSITES: CASE STUDIES AND GOOD PRACTICES JUNE 2013 . The World Bank Private and Financial Sectors Development Department Central Europe and the Baltic Countries Europe and Central Asia Region Washington,D.C. TABLE OF CONTENTS Acknowledgments ...................................................................................................................... 3 Abbreviations and Acronyms ..................................................................................................... 4 Executive Summary .................................................................................................................. 5 Methodology ............................................................................................................................. 8 Background on Disclosure and the Potential Role of Price-Comparison Websites .................. 8 Institutional and Structural Arrangements ..................................................................... …….10 Private versus public sector–operated websites ....................................................... 10 Objectives of public sector–operated websites ........................................................ 10 Structural approaches to public sector–operated websites....................................... 11 Legal and Regulatory Framework ........................................................................................... 13 Regulatory power to compel reporting of data ........................................................ 13 Content of reporting requirements ........................................................................... 14 Creation and Maintenance ....................................................................................................... 14 Initial creation .......................................................................................................... 14 Ongoing operations .................................................................................................. 15 Marketing, consumer testing, and tracking usage .................................................... 16 Products and Providers ............................................................................................................ 17 Product coverage ...................................................................................................... 17 Provider coverage .................................................................................................... 19 Front-end Functionality of Price-Comparison Websites ......................................................... 19 User-specified filters ................................................................................................ 20 Comparative data ..................................................................................................... 23 Design and functionality .......................................................................................... 27 Complementary tools ............................................................................................... 29 Back-End Data Processing of Price-Comparison Websites .................................................... 29 Data collection ......................................................................................................... 29 Data updating ........................................................................................................... 30 Data manipulation .................................................................................................... 30 Annex: Comparative Table of Price-Comparison Websites in Case Study Countries ............ 32 2 ACKNOWLEDGMENTS This report was prepared by Ms. Jennifer Chien (independent consultant in financial inclusion policy). Technical guidance was provided by Ms. Johanna Jaeger (financial sector specialist, and technical leader) as well as by Mr. Samuel Maimbo (lead financial sector specialist, and task team leader), with oversight provided by Mr. Douglas Pearce (acting service line manager) and Ms. Aurora Ferrari (sector manager), all from the World Bank. Evgeni Evgeniev (private sector development specialist, World Bank) contributed to the edit of the translated version of the document. 3 ABBREVIATIONS AND ACRONYMS AER annual equivalent rate 1 APR annual percentage rate2 ATM automated teller machine BNM Bank Negara Malaysia CAT total annual cost CMS content management system CONDUSEF National Commission for the Protection and Defense of Users of Financial Services (Mexico) EIR effective interest rate3 FCAC Financial Consumer Agency of Canada HFSA Hungarian Financial Supervisory Authority ISA individual savings account IT information technology MAS Money Advice Service (United Kingdom) NCA National Consumer Agency (Ireland) 1 Annual equivalent rate (AER) is the notional interest rate if interest is compounded and paid annually instead of monthly or quarterly. 2 Annual percentage rate (APR) or effective interest rate (EIR). APR/EIR is the annualized rate that represents the total cost of a loan, including interest rates and fees. EIR differs from APR (i.e. nominal APR) in that it takes into account compounding interest when converting nominal rates into an annualized rate. 3 See above. 4 EXECUTIVE SUMMARY This technical note is intended to provide regulators with concrete, practical information on operating price-comparison websites and the strategic considerations necessary to take into account when designing such sites. The technical note examines price-comparison websites operated by public sector entities in Canada, Hungary, Ireland, Malaysia, Mexico, Norway, and the United Kingdom. The technical note describes the price-comparison tools in these case study countries, comparing differing approaches and highlighting good practices found across countries.4 Institutional and structural arrangements were found to vary across case study countries. Price-comparison websites are operated by either a financial regulator (Hungary, Malaysia) or more commonly by a financial consumer agency set up by the government but operating as an independent agency (Canada, Ireland, Mexico, Norway, United Kingdom). Typically, less sophisticated price-comparison websites provide basic price-comparison tools, while more sophisticated sites provide interactive product-selection tools and complementary educational materials in an intuitive, easy-to-use format. The initial cost of creating price-comparison websites ranged from US$260,000 to US$1.7 million. Site operators often took an incremental approach, beginning with basic price- comparison tools and expanding to more sophisticated product-selection tools covering a broader range of products. Price-comparison websites in most case study countries are operated by minimal staff. Public authorities seeking to build such websites should consider setting out a reasonable scope, using automated data processing and outsourcing operational responsibilities as appropriate to build sites that can be cost effectively maintained over the long term. Price-comparison websites in most case study countries cover loans, current accounts, savings accounts, credit cards, and mortgages. While a few sites cover a wider range of products in addition to these basics, it is advisable to focus on standardized products that can be effectively compared by means of price-comparison tools and that are used by a majority of the population. “Less is more” should be the guiding philosophy in providing comparative data to consumers, as too much detail can overwhelm users. Basic features and functions should be provided to allow users to easily filter, sort, and compare products based on their specific interests and needs. 4 See annex for a comparative table summarizing observations across all case study countries. 5 Table 1: Key Findings and Policy Recommendations Key Finding Policy Recommendation Institutional and Structural Arrangements Objectives of public sector–operated price- Articulate the specific objectives of price-comparison comparison websites range from comparing product websites based on country context, and structure sites offerings to increasing competitive pricing to to meet these objectives. encouraging switching. Comparative advantages of public sector–operated Focus on comparative advantages over private sector– sites include objectivity, breadth of products and operated sites to provide value to consumers. providers covered, and complementary consumer protection tools. Sites may be operated by the main financial Consider the best institutional arrangement for regulator, but more sophisticated sites are typically identifying an appropriate operator that can dedicate operated by the financial consumer protection long-term resources and attention to price-comparison agency. sites and provide complementary tools. Legal and Regulatory Framework Price-comparison websites typically benefit from Consider introducing regulation to compel providers to regulation that requires providers to report report data directly or indirectly to site operators. comparative data to financial regulators or consumer agencies. Reporting requirements that include comparable Assess the need for revising reporting requirements to metrics on key prices, terms, and conditions are a include comparable metrics (such as APR and total prerequisite to building price-comparison websites. cost of credit), including standardized formulas for calculation. Creation and Maintenance Initial creation costs range from US$260,000 to Assess internal staff resources available for US$1.7 million, but the ongoing staff resources maintenance as well as different funding structures, required are typically minimal. Funding structures and outsource operational responsibilities where for ongoing operations vary based on country necessary and desirable. circumstances. Some mechanisms include direct funding through host institutions, levies imposed on financial providers, and grants from other government bodies. Sites often begin with basic price-comparison tools, Take an incremental approach, focusing on addressing expanding gradually over time to product-selection priority objectives using available resources. tools with embedded advice and increased user specifications. Consumer testing and focus groups revealed the Perform ongoing consumer testing to refine and importance of clear and intuitive site design and tools improve the effectiveness of price-comparison tools. that are not overly detailed or time consuming to use. Products and Providers Most sites include loans, current accounts, savings For greater impact, prioritize product coverage based accounts, credit cards, and mortgages. on country context, focusing on standard products used by a majority of the population. Sites typically include data from all institutions that Aim for broad coverage of providers in the market, a fall under the financial regulatory framework. comparative advantage of public sector–operated price- comparison websites. Front-end Functionality Highly sophisticated sites are designed to be Provide user-specified filters, but, to be intuitive, limit interactive, easy to navigate, and visually appealing. to key criteria and design filters. “Less is more” when determining what data to compare across product offerings; detailed data should be left to secondary web pages. 6 Include design features such as sorting by column headings and side-by-side comparisons of user-selected products. Embed guidance, definitions, and advice within comparison tools. Back-end Data Operations Providers often input data directly to sites through Consider automated data entry by providers, with spot- individual logins to back-end content management checking by site staff, to avoid inputting errors and systems. conserve resources. Updates can occur on either a regular schedule or Be transparent about the frequency of updating and the continuously; most sites do not manipulate data aside basis for calculating interest rates and estimated costs. from projections of total costs or interest. 7 METHODOLOGY Information for this technical note was obtained through desk research, online review of price-comparison websites from case study countries, and interviews with staff operating those websites.5 The seven case study countries were chosen as examples of interactive, public–sector operated websites that provide consumers with up-to-date data on a range of financial products from a broad number of providers in their respective financial markets. BACKGROUND ON DISCLOSURE AND THE POTENTIAL ROLE OF PRICE-COMPARISON WEBSITES Simple and easy-to-understand consumer disclosure lies at the heart of robust consumer protection.6 To be effective, material information should be disclosed in a standardized format conducive to consumer comprehension and during all stages of a relationship with a customer, including both the shopping phase and the transaction phase. Such a task is easier said than done. The specific prices and terms that should be disclosed for informed decision making by consumers will differ by product. Behavioral biases by consumers can also affect how disclosed information is processed. Regulators have multiple tools for increasing disclosure and transparency. Regulation and guidelines for financial providers can specify disclosure requirements, such as the statement of APR/EIR7 and the total cost of credit8 and summary and disclosure sheets that present key pricing and terms in a standardized format. Regulators can use enhanced supervision and enforcement efforts during implementation of disclosure rules.9 5 Performed during February-March, 2013. 6 See Organisation for Economic Co-operation and Development, “G-20 High-Level Principles on Financial Consumer Protection” (Paris: OECD, 2011). The G-20 “High-Level Principles on Financial Consumer Protection” list disclosure and transparency as a key principle (principle 4). Information on all material aspects of a financial product or service should be disclosed so that consumers understand what they are purchasing and will choose products well suited to their specific needs. Transparency can also increase market competition and lower costs. 7 Annual percentage rate (APR) or effective interest rate (EIR). APR/EIR is the annualized rate that represents the total cost of a loan, including interest rates and fees. EIR differs from APR (i.e. nominal APR) in that it takes into account compounding interest when converting nominal rates into an annualized rate. 8 The total cost of credit is the total cumulative amount a borrower must pay for a loan product. 9 For further details on designing disclosure regimes, see Jennifer Chien, “Designing Disclosure Regimes for Responsible Financial Inclusion” (Focus Note 78, CGAP, Washington, DC, March 2012). 8 Regulators can also play a more direct role in increasing disclosure and transparency through the operation of price-comparison websites. Such websites allow all consumers (with Internet access) to easily search for and compare product offerings in the market, helping to broaden disclosure and transparency during the shopping phase. These websites can increase market competition by creating competitive pressure among providers to lower prices and improve product offerings.10 However, there are inherent limitations to price-comparison websites. Price comparisons are most useful for comparing standardized, commoditized products and are less appropriate for sophisticated products. Certain preconditions must be met for price-comparison tools to operate effectively, such as the availability of standardized metrics for conveying pricing and terms of financial products, as well as having the regulatory power to compel providers to report these metrics. Data on comparison websites also need to be reliable and relatively up to date, requiring the long-term commitment of often the limited staff and resources of regulatory bodies. Ultimately, price-comparison websites should be viewed as one tool among many available to regulators and one means of increasing transparency and enhanced financial consumer protection.11 All the foregoing factors should be taken into account when considering whether to build price-comparison websites, and the costs weighed in relation to potential benefits. 10 For example in Peru, the financial regulator found that online publication of consumer loan rates offered by banks and finance companies, joined by a consumer awareness campaign, reduced the average consumer lending rate by 1000 basis points (or ten percentage points) at the time of stable interest rates. 11 For a wide range of regulatory tools and good practices for financial consumer protection, see Good Practices for Financial Consumer Protection (Washington, DC: World Bank, 2012). 9 INSTITUTIONAL AND STRUCTURAL ARRANGEMENTS Private versus public sector–operated websites Private sector–operated price-comparison websites exist in many countries for a wide range of products. These sites often have quite technologically advanced search functionality and user interface. They are also profit motivated, typically generating profit through providers and retailers whose products are listed on the sites. Regulators seeking to offer price-comparison tools should carefully consider their own objectives and comparative advantages. Price-comparison tools may be most helpful in addressing specific issues such as high margins, significant price variability, or vulnerable populations with respect to certain financial products or services. Comparative advantages of public sector–operated price-comparison websites include the objectivity and transparency of the public sector site operator, the greater number of products and providers that may be compared in one website, and the combination of comparative pricing data with complementary financial guidance and educational tools. Objectives of public sector–operated websites The price-comparison websites examined in case study countries had similar objectives but displayed a wide range of approaches in structure and level of sophistication. CONDUSEF, the financial consumer protection agency in Mexico, describes its personal credit and payroll simulator as a tool to help consumers find credit options that suit them, compare credit alternatives in the market, and receive guidance on choosing the credit option that best suits their needs. The National Consumer Agency (NCA) website in Ireland notes that pricing surveys across diverse areas of spending are intended to raise awareness of price differences and encourage businesses to offer good value and transparent pricing. The objectives of price-comparison websites should be clearly articulated, and websites need to be structured to meet those objectives if they are to be effective. The graphic in figure 1 displays the goals of the Finansportalen website in Norway, operated by the Consumer Council. It illustrates the causal relationships behind the website’s intended impact and includes a more explicit focus on encouraging bargaining and switching between providers. The tools and features offered on Finansportalen correspond well with these particular goals, such as a “switch” button that facilitates receiving offers from other banks. 10 Figure 1: Goals of the Finansportalen Website in Norway Structural approaches to public sector–operated websites Price-comparison websites may be hosted by either a financial regulator (Hungary, Malaysia) or, more commonly, by a financial consumer agency set up by the government but operating as an independent agency (Canada, Ireland, Mexico, Norway, United Kingdom). The financial consumer agency typically works in coordination with financial sector regulators and other relevant government agencies. The benefits of a financial consumer agency operator include expertise in consumer protection issues, the ability to dedicate long-term resources and attention to the operation of the price-comparison site, and the ability to provide complementary financial consumer protection materials. Price-comparison websites examined for this technical note displayed a range of sophistication (see table 2). The most basic sites provide simple and straightforward price- comparison tools with limited features and functionality. For example, the Bankinginfo site operated by Bank Negara Malaysia (BNM) includes tables that list product offerings by provider and allow comparisons across metrics and a few user-selected filters. Comparison tools on the site are structured by product. By contrast, sophisticated sites rely more on product-selection tools as opposed to price- comparison tools. These sites are designed to be highly interactive, intuitive, and visually appealing for consumers. Comparison tools may be structured around products or life events, contain user-friendly features for customizing results, and embed advice and 11 information to guide consumers toward appropriate products. Complementary features such as budget calculators and financial guidance and educational tools are offered alongside comparison tools. The Money Advice Service in the United Kingdom offers comparison tools that can tailor results for highly specific user needs, provide key comparative data points so as not to overwhelm the user (with more detailed data available on a separate web page), and integrate advice throughout the tools. The site also offers budgeting tools, action plans, and cost calculators that complement the comparison tools. The price-comparison websites in Hungary and Mexico fall between basic and sophisticated. Price-comparison tools include some features aimed at aiding in product selection, and complementary tools are offered. However, advice is not as well integrated into comparison tools, and the overall design and structure of such sites are less intuitive to navigate in comparison with more sophistication sites. Table 2: Degree of Sophistication of Price-Comparison Websites Basic Medium High Main  Focus on price  Combination of price  Focus on product selection characteristics comparison comparison and product  Highly interactive with  Comparative tables selection tailored results with basic user-  Advice and  Intuitive navigation and specified filters and complementary tools clean design limited functionality not well integrated  Embedded advice  Advanced complementary tools Case study Malaysia Hungary, Mexico Canada, Ireland, Norway, countries United Kingdom The varied degree of sophistication of price-comparison websites across case study countries suggests that regulators can take a staged approach when building such sites. As further described in the “Initial creation” section below, price-comparison websites in Canada, Ireland, and the United Kingdom all began with basic comparative tables and evolved over the years, expanding and refining comparison tools based on usage data, user feedback, and consumer testing. Any approach should be aimed at addressing the highest- priority disclosure and transparency needs in a particular country. The ability to include more sophisticated design elements will likely depend on available resources. 12 LEGAL AND REGULATORY FRAMEWORK Regulatory power to compel reporting of data Price-comparison websites typically benefit from regulation that directly or indirectly requires financial providers to report data. Price-comparison websites operated by the primary financial regulator in a country, such as in Hungary and Malaysia, are obviously in the best position to directly exert regulatory powers. As the Hungarian Financial Supervisory Authority (HFSA) in Hungary is entitled to issue data-reporting decrees, it first determines the relevant products and related terms and conditions to include in price-comparison tools. The president of the HFSA then orders financial providers to report these specific items of information, such as fees for current accounts, annual equivalent rate (AER), and APR (further detailed in the “Comparative data” section below).12 Websites operated by consumer agencies in Ireland, Mexico, and Norway either have the direct power to require financial providers to supply data (Ireland, Mexico13) or benefit from regulations that require such reporting (Norway). Based on regulations issued under the Marketing Practices Act, financial providers operating in Norway have been required to deliver data to Finansportalen since January 2013. Providers are not technically required to report data directly to the consumer agencies operating price-comparison websites in Canada and the United Kingdom but are required to publicly disclose information to consumers. Regardless of regulatory backing, price-comparison websites should seek to build relationships with providers as a matter of good practice to facilitate obtaining timely, accurate data. The Financial Consumer Agency of Canada (FCAC) noted that data can be very hard to collect on a voluntary basis, as providers are quite reluctant to share information. Obtaining data from financial providers became more routine for the FCAC after relationships were developed with providers, and now some financial institutions have requested that they be added to the FCAC website to compete for consumer attention. Before January 2013, Finansportalen in Norway lacked the mandate to compel financial providers to include their product offerings on the site. However, through working with the trade organization for banks, insurance companies, and other financial institutions in Norway to emphasize the 12 See http://www.pszaf.hu/intezmenyeknek/bal_menu/adatszolgaltatas/adatszolgaltatas_hitelintezetek/2012/szamlater mekek_adatszolg.html and http://www.pszaf.hu/intezmenyeknek/bal_menu/adatszolgaltatas/adatszolgaltatas_hitelintezetek/2012/4- 2012_PSZAF_rendelet.html for such decrees (in Hungarian) on bank accounts and deposit and credit, respectively. 13 Depending on the financial product or service in question. 13 importance of participation, Finansportalen was able to obtain the voluntary commitment of financial providers to maintain and update product information in price-comparison tools. In addition, the main body undertaking the creation of a price-comparison website should officially coordinate with other financial sector regulatory bodies both to garner support and to assess what data required by regulation to be reported may need to be obtained from other regulatory bodies for price-comparison tools. Content of reporting requirements Regulators building price-comparison websites will also need to consider the extent to which current regulatory reporting requirements include the key prices, terms, and conditions that the price-comparison websites are intended to compare. Requiring financial providers to calculate and report to financial regulators or publicly disclose APR/EIR and total cost of credit (or equivalent metrics) should be considered a prerequisite to building price- comparison websites. In addition, standardized formulas for calculating and presenting these metrics should be developed and provided. For example, noting that banks all displayed APR in slightly different ways, the NCA in Ireland asked financial providers to calculate APR and AER in accordance with existing regulation and present them in a standardized format specifically for purposes of the NCA’s price-comparison tools. When the HFSA was initially developing its bank account selection tool, no annual or monthly cost indicators existed to compare current accounts in Hungary. Therefore, the HFSA decreed that financial institutions report the typical current account costs or fees (for example, monthly operating fees, charges for cash withdrawal by automated teller machines, fees for credit transfers, and fees for direct debit) as a formula. The site then calculates a monthly cost indicator based on both the cost formulas provided by financial institutions and the typical number of transactions input by site users. CREATION AND MAINTENANCE Initial creation The initial design and construction of price-comparison websites are most commonly outsourced, as was the case in Ireland, Malaysia, Norway, and the United Kingdom. By contrast, the FCAC designed and developed its price-comparison tools in-house, as did CONDUSEF. The process in Canada took 18 months and cost approximately US$300,000. The design of the front-end, consumer-facing portion of the NCA’s price-comparison tools and the construction of the back-end content management system (CMS) were outsourced to 14 two separate providers and took two years and approximately US$260,000 to build. Staff at Finansportalen in Norway indicated that the portion of its site containing price-comparison tools cost approximately US$1.7 million to construct. Several sites started modestly with static comparison tables and built up from there. Canada, Ireland, and the United Kingdom are all examples of this evolution. In Canada, the starting point was putting all bank offerings in a single comparison document. However, the limitations of this approach quickly became apparent, as there were too many offerings for consumers to digest. Therefore, in-house programmers were used to transition from a descriptive, static comparison to a more dynamic tool that allowed users to input preferences, with the system returning a short list of appropriate product options. Feedback from a wide range of consumers was incorporated during this development phase. At the same time, an FCAC consumer education officer worked to develop relationships with financial institutions to secure their participation in the site. The Money Advice Service in the United Kingdom originally began as part of the Financial Services Authority but was split off two years ago. It provided early comparison tables that covered more sophisticated products such as mortgages and pensions. Creating and maintaining these tables were found to be labor intensive, and it was ultimately determined that the cost of keeping the tables up to date was not worth the benefit, given the number of customers using them. When the website was redesigned, the Money Advice Service decided to use a new solution and engaged an outside organization that specialized in creating comparison tables for the private sector in the United Kingdom. This organization designed and now operates the Money Advice Service’s price-comparison tools. Using a specialized service provider enabled the Money Advice Service to provide a wider suite of comparison tools and include the entire market of providers, a specific objective of the redesigned site, without a commensurate increase in staff. Ongoing operations Funding structures will obviously vary based on country circumstances. Examples of such mechanisms include direct funding through host institutions, levies imposed on financial providers, and grants from other government bodies. Price-comparison tools on the HFSA’s website are funded directly by the HFSA. The Money Advice Service and the NCA’s site are both funded through general levies imposed on financial providers to support the provision of information and education on financial products and services to consumers. A portion of these levies is used for price-comparison tools. Levies for the Money Advice Service are raised by the Financial Services Authority in the United Kingdom which also approves the Money Advice Service’s annual business plan. Levies for the NCA are collected through the Central 15 Bank of Ireland on behalf of the NCA. Finansportalen is funded by grants from the Ministry of Finance and the Ministry of Children, Equality and Social Inclusion. Most price-comparison websites in the case study countries operate with minimal staff. The Money Advice Service has one staff member overseeing price-comparison tools, as its day-to-day operation is outsourced to a third-party provider. The Bankinginfo site in Malaysia similarly requires minimal staff as the webmaster role is outsourced and financial providers input data directly. The FCAC’s site in Canada requires part of the time of two staff members, as well as information technology resources, given that data entry for comparison tools is increasingly automated. The NCA in Ireland requires two full-time staff members. Regulators considering operating price-comparison websites should keep in mind the available staff resources when determining which functions to outsource or automate. Marketing, consumer testing, and tracking usage Marketing of price-comparison tools is necessary to ensure that consumers are aware of the availability of such tools. In Norway, marketing the Finansportalen “brand” consists of public relations and editorial work, including statements, consumer advice, and advertising in newspapers and on radio and Facebook and links to Finansportalen’s tools on larger websites. The HFSA in Hungary uses brochures placed in financial institutions and TV advertisements to actively communicate to consumers the tools available on its site. The HFSA also recommends that financial institutions place links to HFSA’s site on their own websites and call consumers’ attention to these tools. Consumer testing and focus groups are highly recommended for refining price- comparison tools, resources permitting. In Ireland, the NCA’s site was redeveloped in 2011 based on user testing. Since the launch of the new site, focus groups have assessed its effectiveness, and the results have been used to further adjust the site’s features and overall look and feel. In Mexico, CONDUSEF used market research in the initial development of its price-comparison tools to inform design elements. In Canada, the FCAC undertook public opinion research to test whether the site met consumer needs and was easy to use. An outside service provider was commissioned to conduct this research, using an online survey and in-depth phone interviews. Results revealed that consumers had positive impressions of the tools offered on the site. However, consumers had difficulties in navigating the site and considered the site poorly organized, with the location of resources not intuitive. Consumers also noted that certain tools, such as the budget calculator, were useful but requested too much detail and therefore took too long to complete. 16 These consumer testing results reinforce the need for price-comparison websites to be user friendly and to provide consumers with a positive experience that allows them to easily find the tools they are seeking. Tools should provide the optimal level of detail and allow users to get to relevant results without undue delays. Consumer testing does not have to prohibitively expensive; at a minimum, websites can incorporate short surveys into price-comparison tools to garner immediate feedback and impressions from users. Tracking the use of price-comparison tools should also be considered good practice.14 Site operators in Norway and the United Kingdom both report that price-comparison tools for mortgages are the most frequently visited, followed by savings accounts. These statistics point to consumer demand for comparisons of these products, in spite or perhaps because of the challenges in easily comparing such products. Different tools are also used by different groups. FCAC staff noted that static comparison tables are used by researchers as well as by the private sector for comparison between competitors and are helpful for meeting the objective of increased market competition. PRODUCTS AND PROVIDERS Product coverage Nearly all price-comparison websites in the case study countries include comparison tools for loans, current accounts, savings accounts, credit cards, and mortgages. Beyond these core products, sites differ in approach. Some sites include comparison tools for additional products like investments and stocks, insurance, and remittances, while other sites break down core products into more specialized products such as small loans or student banking products. 14 Finansportalen reported an average of 10,603 unique visitors per week in 2012 for the entire website. CONDUSEF reports 414,708 “transactions” for its personal credit and payroll tool in 2012. 17 Table 3: Financial Products Covered by Price-Comparison Websites in Case Study Countries United Canada Hungary Ireland Malaysia Mexico Norway Kingdom  Banking  Consumer  Loans  Base lending  Personal  Small loans  Loans package loans  Current rates credit and  Credit  Current selector tool  Bank accounts  Current payroll  Current accounts  Savings selection  Regular accounts simulator accounts  Savings account program savings  Savings  Credit card  Bank deposits accounts selector tool  Deposit and  Lump-sum accounts catalog  Mortgages  Cash  Credit card savings deposits  Basic savings  Mortgage  Exchange individual selector tool search  Credit cards account rates simulator banks savings  Credit cards  Mortgages  Credit cards  Investments accounts  Mortgages  Student  Hire purchase (bonds, funds) (ISAs)  Real estate banking  Housing loans  Insurance  Savings leasing products  Negotiable  Remittances bonds  Vehicle instrument of  Total cash  Credit cards leasing deposit rates costs  Investment,  Fixed deposit stocks and accounts share  Fees and accounts. charges and ISAs  Islamic and  Mortgages microfinance  Annuities products and pensions A number of factors should be taken into consideration when determining which financial products and services to include in price-comparison websites. Products that are more standardized and commoditized, such as basic loans and current accounts, are arguably most appropriate for price-comparison tools as there are a limited set of key metrics based on which consumers choose a product from one provider over another. In addition, given that basic products such as loans and current accounts are typically used by a large percentage of the population, focusing on these products benefits the widest audience. More complex products such as insurance and mortgages could be included as a second step as multiple variables and user-specificities pose additional challenges to be captured effectively by a price-comparison tool. From an operational perspective, site operators should also consider which products are offered by regulated entities, as it will be more difficult to regularly obtain data from entities that do not fall under the formal regulatory framework. Operators of price-comparison websites in Norway and the United Kingdom reported focusing on the most important banking and financial services in the market, while actively seeking to cover a range of products. Finansportalen in Norway began with basic products and expanded product coverage over time, at the specific request of other regulators and government bodies and with the goal of providing a portal that “has it all” and would therefore be used more regularly and repeatedly by consumers. The Money Advice Service in 18 the United Kingdom also noted that one of the comparative advantages of its site was that it covered multiple products, unlike private sector–operated sites. In contract, the FCAC in Canada chose to focus on well-constructed, user-friendly comparison tools for a limited set of basic standardized products, while providing tools, calculators, and educational materials for a variety of other financial products and services. In Mexico, CONDUSEF created comparison tools for financial products that were in mass use and represented the greatest number of inquiries and complaints received by CONDUSEF. In addition to comparison tools for the products noted in table 3, sites in Canada, Hungary, and Mexico provide static comparative tables, typically in Excel format. These tables are often quite detailed and cover a broader range of more specialized products than comparison tools. While not interactive, static comparative tables can serve as a useful accompaniment to comparison tools. The FCAC noted that static comparative tables serve a different audience, namely, financial journalists and financial providers themselves, and may be helpful for increasing market competition. Provider coverage The standard goal of price-comparison websites should be to make available data from as many providers in the market as possible. Price-comparison website operators in Canada, Ireland, Mexico, and Norway report covering the major players currently active in the market (in addition to other providers) and therefore including data representing the majority of market share. For example, the banking package and savings tool on FCAC’s site includes the five major banks in Canada, which represent 75–80 percent of retail deposits in the country, as well as other banks, credit unions, and other financial institutions. Price- comparison websites should seek to cover all institutions that fall under the formal financial regulatory framework, but will likely find it more difficult to cover semiformal or informal financial providers that do not fall under the regulatory framework. FRONT-END FUNCTIONALITY OF PRICE-COMPARISON WEBSITES This section describes the front-end functionality of price-comparison websites in case study countries, examining four elements: (1) what filters users are allowed to preselect to tailor product results; (2) what types of data are compared across product offerings; (3) what types of features and functions are provided by comparison tools; and (4) what other complementary tools are offered by price-comparison websites. To explore these topics in greater depth, the technical note focuses on how price-comparison websites approach three specific products: personal loans, current accounts, and savings accounts. 19 User-specified filters The majority of price-comparison websites examined in this technical note allow users to preselect certain criteria before providing comparative results. Filters range from simple to complex and from intuitive to less user friendly. Personal loans All sites allow users to specify the size and term of the loan, arguably the two key criteria for personal loans. The HFSA site also provides filters for currency, period of repayment, and maximum APR. Users can select from 14 ranges of APR (which may be excessive). Filters from other sites include monthly income (Mexico), age (Norway), and whether payment holidays or new customers are allowed (United Kingdom). More sophisticated price-comparison websites, including those in Ireland and the United Kingdom, allow users to easily adjust the size and term of the loan after receiving comparative results. Both the Money Advice Service and the NCA’s site provide visually appealing and easy-to-use sliding scales to input and revise filters. Figure 2: User-Specified Filters for Loan Comparison on NCA Website in Ireland 20 Current accounts The approach toward user-specified filters varied more for current accounts than for loans, as there are a greater number of variables on which consumers may base their comparison shopping decisions. Price-comparison websites in Canada and Norway use detailed user- created profiles to customize results. The FCAC’s site guides users through a six -step process to individualize product-selection results. Each step has a clear visual presentation and basic instructions for users. Users select a specific province or territory for which they want information on banking costs, whether they can benefit from a special account (for example, youth, senior citizen, or student), and the minimum balance users are always able to maintain. Users then create a personal profile for how many transactions they typically make per month, inputting a specific number for the following types of transactions:  In-branch withdrawals  In-branch bill payments  In-branch transfers  Self-serve withdrawals at an ATM  Self-serve bill payments by ATM, phone, or Internet  Self-serve transfers by ATM, phone, or Internet  Checks  Direct payment by debit card  Pre-authorized payments The site summarizes the user-created profile and then lists financial institutions with current accounts that meet users’ particular needs. Finansportalen follows a similar approach of using a detailed “usage pattern” as a variable in filtering results. However, Finansportalen prepopulates the usage pattern with average usage statistics from Gallup data and then allows users to adjust these numbers if desired. This approach may be less potentially overwhelming to average consumers and requires less time to complete. 21 Figure 3: User-Specified Filters for a Current Account Comparison on the Finansportalen Website in Norway By comparison, the Money Advice Service in the United Kingdom uses the same basic format for user-specified filters for current accounts as with its other products. Users choose what they want to do—“earn interest on balance,” “have low cost overdraft option,” “get an account despite poor credit rating,” “open a student account,” or “pay for a premium service account”—and then select filters for their credit rating (good, poor, don’t know) and whether they want accounts with phone banking, Internet banking, or both phone and Internet banking. All three examples from Canada, Norway, and the United Kingdom reveal the greater complexity of addressing disclosure and transparency issues for current accounts. As opposed to paying a specific “price” for a product (such as a loan), there are more account features that consumers may care about when choosing a current account appropriate for their needs. Regulators building comparison tools for current accounts will need to consider which of these features to highlight in user-specified filters, what format to use to capture user profiles in a user-friendly and intuitive way, and how to incorporate these user selections into the back-end process of filtering to provide a targeted selection of products. Savings accounts The approach toward user-specified filters for savings accounts had more commonality across case study countries than did current accounts. Price-comparison sites in Canada, Hungary, and Malaysia ask users to choose a minimum balance to maintain or a minimum balance requirement. Users can select how much they expect to have as their balance in the account throughout the year (Norway) or how much they expect to save per month (Ireland). Users 22 can select the frequency of interest payments in the price-comparison websites in Hungary and Malaysia, although it is unclear if this account feature would be a high priority for most consumers. Comparative data When determining what data to compare across product offerings, a “less is more” philosophy is essential. Regulators should focus on providing the key data points that are most important to the consumers who are comparing and choosing a financial product or service and that commonly apply across all providers. An excessive amount of comparative data can overwhelm users and decrease the utility of comparison tools, while using less common metrics will result in comparative tables with many blanks. A separate but important consideration for price-comparison websites is what rates to report. Not all rates will be available to all consumers at all times, and attempting to report all rates available would be a daunting (if not impossible) task for which the operational costs would likely exceed the benefits to consumers. Given that rates often vary between new and existing customers, Finansportalen staff noted the challenge of designing a comparison site with consistently defined prices that allows the highest degree of comparison for consumers. Consequently, price-comparison websites in Ireland and Norway specifically focus on providing data only for product offerings available to new customers. This approach aligns well with one of the overarching objectives of price-comparison sites: to foster comparison shopping among different providers for better deals. Regulators will need to determine a reasonable scope for presenting the range of available rates for the same product. Personal loans Sophisticated price-comparison websites include the following three metrics for comparing personal loans: (1) APR/EIR; (2) monthly repayment; and (3) total repayment or total cost of credit. Site operators will need to determine standardized methods for calculating and portraying each of these metrics, as calculation methods can vary by provider (even when general definitions are provided by law). The Finansportalen site in Norway explains to users that EIR represents the actual cost of a loan and is the rate that should be used when comparing loans. The site also notes that EIR is calculated in line with formulas provided by regulation. For ease of comparison, nominal interest rates and other credit costs are held constant in relation to their initial level even if they vary in practice during the term of the loan. 23 The Money Advice Service in the United Kingdom calculates the total amount repayable and monthly repayment based on a representative loan amount and term but allows users to adjust either of these two variables. The total amount repayable is described as “every penny you’re expected to repay, including all monthly repayments, fees and charges.” Figure 4: Loan Comparison on Money Advice Service Website in the United Kingdom Other metrics provided less frequently by price-comparison sites at a top level (that is, in the initial comparative table of results after user-specified filters have been entered) include nominal interest rate, type of interest (fixed or variable), and market area. Most price-comparison websites include a secondary level of data that users can access by selecting a particular product offering. Such data are therefore less useful for comparison purposes and more useful for understanding the detailed terms and conditions of a particular product. Case study countries employed a wide variety of metrics, including minimum loan amount, interest calculation, entry fee, management fee, capitalization period, credit insurance, repayment terms, missed payment fees, default interest rate, early repayment charge details, handling fees, and repayment examples. 24 Current accounts As noted previously, numerous variables can be considered in a comparison of different current account offerings. Even more than with loans, the initial comparative data presented to users should be limited to the most important metrics. Market data and consumer testing can be used to help determine the key metrics for a particular market. Case study countries focused on a variety of metrics, including:  Minimum balance to open account  Monthly or quarterly fees for account maintenance  Fees for stop-payment requests  Fees for bill payment handling  Fees for account opening  Fees for debit and ATM transactions  Maximum monthly transactions (in-branch and self-serve)  Interest rates on account balances  Interest rates charged on overdrafts  Minimum balance for fee waiver Price-comparison sites typically keep initial comparative data limited to three or four key metrics. Different methods are used to achieve this. The FCAC’s site in Canada includes all information on “features” (for example, free checks, free money orders, overdraft protection, check returns, and so forth) in a separate tab from comparative data on fees. The HFSA’s site in Hungary embeds tables on interest rates and credit cards within the initial comparative table of product results. While it is helpful to keep the visual presentation from becoming overcrowded, this approach may not be optimal if consumers consider interest rates as a key metric for decision making. As noted with loans, most sites include more detailed data on each product offering on a separate, secondary web page. 25 Figure 5: Current Account Comparison on FCAC Website in Canada Another variation between sites is the extent to which comparative data are based on patterns of consumer usage. Data on the Bankinginfo site in Malaysia are not based on a usage pattern, nor are data on the Money Advice Service (other than preset amounts used to determine applicable interest rates). The HFSA’s site notes that costs are calculated on the “average estimated cost of a monthly usage invoice.” Finansportalen and FCAC’s site go the furthest in presenting costs and expenses based on a client’s estimated use. Applying the user-specified filters noted previously, Finansportalen calculates how much a client can expect to pay in fees per year. Presenting concrete as opposed to generic numbers may be more relevant to consumers. Regardless of the approach chosen by regulators, it is advisable to be transparent about the basis of all interest rates and estimated cost calculations. Savings accounts Price-comparison websites in all case study countries consistently use interest rates to compare savings account products. Sites in Hungary, Ireland, and the United Kingdom report AER.15 Sites in Canada, Hungary, and Malaysia provide data on tiers of interest rates based on a range of account balances, whereas sites in Ireland and Norway provide the interest rate applicable for an estimated amount of savings input by the user, as well as the gross interest earned in one year. 15 Annual equivalent rate is the notional interest rate if interest is compounded and paid annually instead of monthly or quarterly. 26 Price-comparison websites less frequently provide data on the following metrics in initial comparison tables: minimum amount at opening, currency, introductory offers, eligible age, ATM charges, number of free withdrawals per year, and notice requirements for withdrawals. As with price-comparison tools for other financial products, such information may be included in more detailed, secondary web pages for specific product offerings instead of in the initial comparative tables. More detailed web pages on specific product options include data on an extensive number of account features, charges, penalties, and usage restrictions. Figure 6: Savings Account Comparison on HFSA Website in Hungary Design and functionality Price-comparison websites should be designed with the consumer experience in mind. Websites should be clean and colorful, user friendly, and easy to navigate. Although design will obviously vary by site, certain features and functions commonly observed across well- designed price-comparison websites can be considered good practices applicable to all price- comparison sites. Price-comparison tools should allow users to sort by column headings from high to low and low to high. Sites in Canada, Hungary, Ireland, Mexico, and Norway all provide this useful and intuitive feature. It is also helpful to have definitions for all headings embedded in comparative tables, using simple and clear language to describe what each metric means. Price-comparison websites in Ireland, Norway, and the United Kingdom provide short definitions that pop up when a user scrolls over or clicks on column headings. 27 The organization of data is also important. The design of sites should seek to present comparative data in a way that is not overwhelming and can be easily processed, while still allowing users to find more detailed information if desired. As noted, most case study countries provide further details on product offerings on secondary web pages. In addition, sites in Canada, Hungary, Ireland, and Malaysia provide a comparison function whereby users can select specific product offerings (typically three to five products) that are then compared side by side in detail. Sites can also provide the functionality to email, print, or save a PDF of comparison results. Figure 7: User-Selected Side-by-Side Loan Comparison on NCA Website in Ireland A number of price-comparison websites provide hyperlinks to the websites of financial providers in comparative data tables, either in the top or in the secondary levels of information. This feature is useful for multiple reasons. Regardless of the resources dedicated to data collection and updating, data in price-comparison websites cannot guarantee 100 percent accuracy at all times. Data may be outdated and will in some cases be only illustrative as they are based on standard scenarios. Therefore, consumers should be encouraged to visit provider websites directly to confirm current prices, terms, and conditions. Furthermore, assuming that regulators want to encourage consumers to switch providers, providing links to provider websites facilitates this process. The Finansportalen site in Norway chose to include an actual “switch” action button to motivate and enable consumers to change from their existing providers. This function helps consumers initiate switching 28 providers by asking new financial providers for an offer, based on the product the user has selected from the comparative table. The function also helps consumers ask for an offer for better terms from their current financial provider. Chosen financial institutions receive and act on these requests from consumers. Complementary tools Though not the focus of this technical note, many other tools were found on regulator websites that complement price-comparison tools. The HFSA’s site in Hungary provides calculators for credit ratings and household budgets and informational materials on a number of financial products and services. Similarly, the FCAC’s site in Canada provides calculators, tip sheets, quizzes, budgeting tools, and educational materials on a range of products, often presented alongside price-comparison tools. For example, the site’s section on personal accounts includes an overview explaining the different types of bank accounts and customers’ rights and responsibilities with respect to such accounts and has links to selector tools on banking packages and savings accounts that are integrated into educational overviews, along with further links to budget calculators. Regulators should consider what package of tools will be most helpful to consumers in achieving stated regulatory objectives and work to integrate these tools into a seamless user experience. Note that calculators and simulators may be more helpful in aiding consumers for products such as mortgages and insurance than price-comparison tools comparing actual product offerings. BACK-END DATA PROCESSING OF PRICE-COMPARISON WEBSITES Data collection The two main approaches used for data collection are automatic updating directly by financial institutions and the manual input of data collected by site operators of price-comparison websites. Each approach has its pros and cons, although the automated approach may be preferable. The manual approach is used by the NCA in Ireland. The NCA collects data from financial institutions through Excel questionnaires, and staff then manually input data into the website. In Mexico, CONDUSEF collects data from the Bank of Mexico, other financial sector regulators, the websites of financial institutions, and from financial institutions themselves. Data is then manually input into CONDUSEF’s online price-comparison tools. Such an 29 approach may provide greater quality control but conversely may be more prone to manual error and is highly labor intensive, diminishing the ability to undertake frequent updates. Price-comparison websites in other case study countries use an automated approach. Financial institutions are given individual logins to the back-end content management system of price- comparison websites and update data on their product offerings directly. For example, a specific contact person in each financial institution is responsible for updating prices for Finansportalen in Norway. While less labor intensive for the regulator or site operator, this approach still requires that staff spot-check the accuracy of provider-input data against information on provider websites and other publicly available data. Regulators can take a staged approach to data collection. The manual approach may be a good starting point, as it does not require the construction of an advanced back-end CMS. For example, the FCAC in Canada began with a manual process for its price-comparison tools. When redesigning the comparison tool for credit cards, the data collection was automated. Data collection for the banking package and savings-comparison tool remains a manual process, although it is currently being transitioned to an automated process as well. Data updating The two main approaches with respect to data updating are updates on a regular schedule (for example, quarterly, bi-annually, or annually) and continuous updates when product terms change. The FCAC updates data annually for the banking packages and savings selector tool and quarterly for the credit card selector tool. For both tools, reminder emails are sent to financial providers. Data for CONDUSEF’s personal credit and payroll comparison tool is updated monthly. All other price-comparison websites in case study countries require that financial institutions update data continuously. In Hungary and Norway, it is the responsibility of financial institutions to update product data for modifications of conditions or fees. In Ireland, financial institutions must submit updated data to the NCA five days before changes go live. When crafting an appropriate approach, regulators should weigh the desire for timely data against the likelihood that all financial providers will comply with updating requirements. Data manipulation The majority of price-comparison websites do not directly manipulate the data displayed in comparative tables, aside from metrics that are projections of total costs or interest. Rates and terms are presented exactly as reported by providers. Where projections such as total costs of credit, monthly repayments, and total costs for current accounts are presented, calculation functions are built into the back-end system of the site to automatically 30 generate these results (based on rates input by providers and usage patterns input by users). Avoiding direct manipulation of data is recommended as it limits the likelihood of errors on the part of site operators and is more cost effective. However, note that this approach is predicated on financial institutions providing key metrics that are comparable across providers, as discussed in the “Legal and Regulatory Framework” section above. Finally, regardless of a site’s chosen approach to data processing, it is good practice to be clear and transparent on data processing choices. Price-comparison sites should indicate on their sites how often data are updated, how data are obtained, and how certain metrics are calculated. Price-comparison tools on the HFSA’s site in Hungary include a pop-up window noting that costs are calculated based on averages and simplified for certain conditions. Therefore, values presented are indicative. Other sites include detailed descriptions of the approach to presenting and calculating interest rates and note that rates may differ from actual rates on provider websites. In addition, regulators should consider what secondary benefits can be derived from collected data. Although not directly related to the operation of price-comparison websites, this consideration is important, given the resources that will be spent collecting price-comparison data. Such data should be leveraged for other beneficial purposes, such as monitoring provider behavior and tracking market trends. In Hungary, the HFSA uses data collected in the course of its consumer protection monitoring activities as well as during examinations. 31 ANNEX: COMPARATIVE TABLE OF PRICE-COMPARISON WEBSITES IN CASE STUDY COUNTRIES Canada Hungary Ireland Malaysia Mexico Norway United Kingdom Degree of High. Advanced Medium. High. Advanced Basic. Simple Medium. High. Advanced High. Advanced sophistication product-selection tools product-selection comparative tables product-selection product-selection with high degree of tools with high with limited tools with high tools with high interactivity and user degree of interactivity. degree of degree of guidance. interactivity and user interactivity and user interactivity and user guidance. guidance. guidance. Operator Financial Consumer Hungarian National Consumer Bank Negara National Consumer Council in Money Advice Agency of Canada Financial Agency (NCA) Malaysia (BNM) Commission for cooperation with Service (MAS) (FCAC) Supervisory the Protection and consumer (operated by third- Authority (HFSA) Defense of Users ombudsman and party provider) of Financial financial supervisory Services authority (CONDUSEF) Regulatory Not technically Decrees by NCA has power to All collected data Depending on the As of January 2013, Not technically framework required to report data president of HFSA require financial requested under product, new regulation required to report to FCAC, but for institutions to institutions to provide BNM guidelines. CONDUSEF may mandates that data to MAS, but institutions are report data. data. request information financial institutions institutions are required to publicly from providers by report data to required to publicly disclose information law. Finansportalen. disclose information to consumers. to consumers. Initial Designed and N/A16 Design of front-end Initial design and Designed and Initial design and Initial design creation developed in-house. and construction of construction developed in- construction outsourced, then Took 18 months, back-end outsourced outsourced. house. outsourced. Cost moved in-house. ~US$300,000. to two separate ~US$1.7 million. providers. Took two years, cost ~US$260,000. Ongoing Funded by FCAC. Funded by HFSA. Funded by levy on Funded by BNM. 6 staff members Funded through Funded by levy on operations 15% of two staff 10 staff members financial providers. Webmaster role spend part of their grants from Ministry financial providers. members. spend part of their Two full-time staff. outsourced, minimal time on of Finance and Operated by third- 16 “N/A” indicates that no information was available. 32 Canada Hungary Ireland Malaysia Mexico Norway United Kingdom time maintaining staff required. maintenance of Ministry of Children, party provider. One comparison tools, tools (3 financial Equality and Social staff member at MAS including IT, experts, 3 IT Inclusion. Annual oversees comparison communications, experts). operational costs of tools. consumer ~US$1.5 million for protection, and data entire Finansportalen reporting staff. site (comparison tools and all other content). Products  Banking package  Consumer loans  Loans  Base lending rates  Personal credit  Small loans  Loans covered selector tool  Bank selection  Current accounts  Current accounts and payroll  Credit  Current accounts  Savings account program  Regular savings  Savings accounts simulator  Current accounts  Savings accounts selector tool  Deposit and  Lump-sum  Basic savings  Credit card  Bank deposits  Cash ISAs  Credit card selector savings search deposits account rates catalog  Mortgages  Savings bonds tool  Credit cards  Credit cards  Credit cards  Mortgage  Exchange banks  Credit cards  Mortgages  Mortgages  Hire purchase simulator  Investments  Investment, stocks  Real estate  Student banking  Housing loans (bonds, funds) and share leasing products  Negotiable  Insurance accounts, and  Vehicle leasing instrument of  Remittances ISAs deposit rates  Total cash costs  Mortgages  Fixed deposit  Annuities and accounts pensions  Fees and charges  Islamic and microfinance products Providers Majority of market All regulated Majority of market All licensed banks Banks, Financial Majority of market Appears to cover covered institutions Companies with majority of market Multiple Corporate Purposes (SOFOMES), Popular Financial Societies (SOFIPOS) 33 Canada Hungary Ireland Malaysia Mexico Norway United Kingdom User-specified Personal loans Personal loans Personal loans Base lending rates Personal loans Personal loans Personal loans filters (by  Not covered  Loan amount  Loan amount  None  Loan amount  Loan amount  Loan amount product)  Term  Term  Term  Term  Term Current accounts  Repayment Current accounts  Repayment  Purpose  Source of loan  Province or period Current accounts  Interest or non- period  Age  Payment holiday territory  Currency  None interest bearing  Monthly income or new customer  Special status  Maximum APR  Introducer Current accounts allowed  Minimum balance Savings accounts required Current accounts  Income  Detailed usage Current accounts  Monthly savings  Minimum amount  Not covered  Mortgage Current accounts profile  Age amount to open  Annual savings  Objective  Average Savings accounts balance  Credit rating Savings accounts monthly income Savings accounts  Not covered  Age  Phone or Internet  Province or  Use of credit  Age  Special status banking territory cards  Minimum amount  Detailed usage  Minimum balance  Internet banking to open pattern Savings accounts  Predefined  Frequency of  Objective profiles interest payment Savings accounts  Annual savings Savings accounts balance  Foreign  Age currency  Special status  Minimum amount  Expected frequency of savings  Frequency of interest payment  AER Comparative  Not covered  Minimum and  APR  Base lending rate  Annual interest  EIR  APR data on maximum APR  Total cost of credit (% p.a.) rate  Nominal rate  Total repayment personal loans  Minimum  Monthly  Effective date  Total payment  Total repayment  Monthly annual rate of repayment  Amortization  Monthly repayment interest  Total annual repayment  Type of interest  Type of interest cost (CAT)  Market area 34 Canada Hungary Ireland Malaysia Mexico Norway United Kingdom  Minimum and  Payment  Product package maximum loan  Life insurance amount cost  Currency  Unemployment insurance cost Comparative  Monthly fee  Interest  Quarterly fee  Rates (range and  Not covered  Total cost per year  Balance rate AER data on  Minimum balance conditions and  Debit/ATM corresponding %  Cost cards per  Overdraft AER current for fee waiver credit cards transaction fees p.a.) year accounts  Maximum monthly (annual interest  Overdraft interest  Initial deposit  Expense payments transactions (in- rate, AER, credit required per year branch and self- card fees,  Service charge  Market area serve) withdrawal and  Fees for stop  Product package  Bill payment purchase limits) payment requests and annual price handling fee (in-  Minimum branch and self- amount to open serve)  Account  Features opening fee o Free certified or  Internet banking personalized checks o Free money orders and bank drafts o Free stop payments o Traveler’s checks o Overdraft protection o Check returns o Free access to other ATMs o Email money transfers 35 Canada Hungary Ireland Malaysia Mexico Norway United Kingdom Comparative  Interest (rates and  Interest rate  AER  Rates (size of  Not covered  Effective yield  AER data on calculations) conditions  Introductory offers deposit and deposit rate  Minimum/ savings  Fees for in-branch, (ranges, annual  Gross interest corresponding  Number of free maximum accounts ATM, phone or interest rates, earned in one year rates) withdrawals per investment Internet usage for AER)  Initial deposit year  Interest periods each of following:  Minimum and  ATM charges  Market area  Notice o Free transactions maximum AER  Eligible age  Product package requirement for o Bill payments  Minimum withdrawals o Withdrawals amount o Transfers  Expected o Balance inquiries frequency of  Account savings accessibility (ATM,  Currency Internet, phone, in- branch)  Features o Debit card o Direct payment o Pre-authorized debit o Checks Design Sort by column Sort by column Sort by column Side-by-side Sort by column Sort by column Sort by column features heading. Side-by-side heading. Side-by- heading. Side-by-side comparison of up to heading. heading. Pop-up heading. Clean comparison of up to side comparison of comparison of three products. definitions of column visuals and colorful five products, high selected products. selected products. headings. Button to graphics. Links to interactivity. User friendly and “switch” providers. provider websites. clean design. Links to provider websites. Data Manual for banking Automated. Collected from Automated. Licensed Data manually Automated for Scraping of websites collection package and savings Financial financial institutions banks provide data collected from banking products. and direct calls to selector tools. Excel institutions load through Excel directly through Bank of Mexico, Financial institutions financial institutions surveys sent to data directly to site. questionnaires and logins to website other regulators, insert data directly. by third-party financial institutions manually input by content management websites of provider. and resulting data NCA staff. system. financial input by FCAC staff. institutions, and Automated process for financial 36 Canada Hungary Ireland Malaysia Mexico Norway United Kingdom credit card selector institutions. tool, financial institutions update directly. Data updating Data updated annually Responsibility of Institutions must Banks required to Data updated Banks update price Updated continually for banking package institutions to submit data to NCA update rates when monthly for information on first when products and savings selector continuously five days before rates change. personal credit and day changes apply to change. Updates tools. Quarterly for update data for changes go live. payroll tool. consumers. Reported released every two credit card selector modifications of rates are for new weeks. tool. Reminder email conditions or fees. customers only. sent to providers. Link www.fcac- http://www.pszaf.h http://www.nca.ie/co www.bankinginfo.co http://www.condus www.finansportalen. https://www.moneya acfc.gc.ca/eng/resourc u/fogyasztoknak mpare m.my/04_help_and_a ef.gob.mx/ no/Forsiden dviceservice.org.uk/e es/toolCalculator/inde dvice/0401_useful_to n/categories/comparis x-eng.asp ols/comparative_tabl on-tables es/comparative_table. php?intPrefLangID= 1& 37