Consumer Appetite for Crossborder Shopping in Financial Services A Report Prepared for the FSA Final Report – 17/04/2010 Steve Nuttall, Anthony Chaimowitz and John Cogswell This document does not represent the point of view of the Financial Services Authority. The interpretations and opinions contained in it are solely those of the authors. Table of Contents _____________________________________3 Executive Summary _______________________________5 Introduction and Background _________________________________9 Scope and Methodology 1.1 Stage 1 Qualitative Research __________________________________________10 1.2 Stage 2: A quantitative survey__________________________________________10 1.3 Stage 3: A supplementary quantitative survey__________________________11 1.4 Stage 4: Intermediaries qualitative research____________________________11 1.5 Interpretation and timing ______________________________________________11 1.6 Crossborder: benefits, barriers and disadvantages _____________________13 1.7 Connections__________________________________________________________19 1.8 The benefits of crossborder shopping __________________________________20 1.9 Switching points and product pricing___________________________________21 _________________25 Barriers in Financial Services crossborder Shopping 1.10 Hard barriers ________________________________________________________25 1.11 Soft barriers _________________________________________________________27 1.12 Country Hierarchy___________________________________________________31 1.13 Overcoming barriers_________________________________________________32 1.14 Impact of Financial Intermediaries on Decision Making________________33 __________________________31 Conclusions and Policy Implications ___40 Annex 1 Methodological Note about FSA Crossborder Transactions Study 2.1 Understanding Trade Offs ____________________________________________42 2.2 The Trade Offs_______________________________________________________42 2.3 Mortgages __________________________________________________________44 2.4 Savings Accounts ___________________________________________________40 2.5 Investment Accounts ________________________________________________41 2.6 Travel Insurance_____________________________________________________50 Page 3 of 50 Executive Summary • The aim of European Union policy in the area of retail financial services is to enable consumers to shop around all over Europe for the best savings plans, mortgages, insurance and pensions with clear information available to compare products • Key interventions in EU policy to date have largely focused on addressing supply side constraints that restrict trade in financial services. • While increasing numbers of consumers in the UK are looking outside their domestic market for low cost, low risk products there is a very limited and undeveloped market for financial services. • Current levels of cross border transactions for financial services remain modest with less than 1% of consumers having bought a financial product at a distance from a company situated in another member state 1. • General consumer motivations for cross border transactions centre on the search for greater value and enhanced consumer choice while not sacrificing consumer protection should something go wrong. In financial services consumers will be looking for reduced transaction costs, superior returns and tax efficiency and in certain circumstances convenience and local specialist knowledge • Consumers are currently motivated to consider and engage in cross border purchase when there is an underlying need. Connections with other EU countries are a key driver in influencing the decision to purchase cross border, suggesting that many purchases are made out of necessity rather than because of any perceived inherent benefits. • The EU area is not perceived as being homogenous, and cultural perceptions of member states vary. The domicile of the product or firm plays a key role in consumer consideration of cross border product offers. • There exists a very high level of loyalty to UK providers, and where switching might occur it is at a price/return differential that is unlikely to be commercially attainable. • Removing perceived hard barriers to cross border shopping, for example by working towards common regulatory frameworks and dispute resolution procedures, is seen as a necessary precondition that consumers expect 1 YouGov survey 2008 Page 4 of 50 policy makers to address. However, such actions are by no means sufficient to change consumer attitudes. • Cross border purchase of financial products is seen to carry a degree of risk over and above that involved in buying products from UKbased providers and these risks outweigh any potential benefit to be gained from buying cross border. • In addition there exist powerful underlying attitudinal barriers which play a critical role in shaping the mindset of consumers. These cannot be overcome through regulatory policy intervention. • Financial advisors (including Independent Financial Advisors or IFAs) play a key role in influencing the decisions and choices consumers make, and are an important distribution channel in the UK. Consumers are willing to follow the advice of a trusted advisor and would purchase from a non UK provider if they were advised to do so. However, few IFAs would offer such advice. • The evidence shows that there exists a complex set of interlocking factors which mean that there is unlikely to be a single policy measure that would by itself significantly contribute to the growth in a single market for financial services. Policy intervention to address supply side contraints and establish a level playing field for regulation and protection is likely to have only a very limited impact on consumer behaviour • There is a strong argument that policy intervention should work with the grain of existing consumer behaviour where this delivers the broader aims of increasing competition and consumer choice. • Given the lack of consumer appetite toward buying in a true cross border situation and the much stronger acceptance of financial product purchase from a provider not based in the UK but with local distribution, policy should be directed to supporting this form of product purchase. • The evidence suggests that the vast majority of UK consumers are in practice currently unlikely to take up the ‘benefits’ of a more open market in financial services even if that market can be created. Page 5 of 50 Introduction and Background The European Commission’s White Paper on Financial Services2 published in 2005 set out an ambitious strategy to achieve a single European market for financial services, with a particular focus on barriers which inhibit the smooth functioning of a single market for retail financial services: “...while the FSAP focused mainly on the wholesale market, retail integration will become more important over the next period. Barriers associated with the use of bank accounts will be examined, with a view to enabling consumers to shop around all over Europe for the best savings plans, mortgages, insurance and pensions, with clear information so that products can be compared.” 3 Building on this White Paper, the Commission published a Green Paper in 2007 specifically addressing retail financial services4 . This Green Paper noted a number of indicators which demonstrated that integration in retail financial services had not reached its potential. These included: • modest crossborder activity (in research carried out for the Commission, 85% of respondents spontaneously indicated that they had never purchased financial services from firms situated in another Member State and 75% said they would not seek to obtain financial services put to them from a firm located in another EU member state) 5 . Moreover, less than 1% claim to have bought a financial services product at distance from a company situated in another member state; 2 WHITE PAPER Financial Services Policy 20052010, European Commission, 2005. http://ec.europa.eu/internal_market/finances/docs/white_paper/white_paper_en.pdf 3 EU financial services policy for the next five years EC Press Release 05/12/2005 http://europa.eu/rapid/pressReleasesAction.do?reference=IP/05/1529&format=HTML&aged=0&language=EN&guiLangu age=en 4 GREEN PAPER on Retail Financial Services in the Single Market European Commission 30 April 2007 5 Public Opinion in Europe on Financial Services. EuroBarometer special report. August 2005 http://ec.europa.eu/consumers/cons_int/fina_serv/cons_experiences/report_eurobarometer632_en.pdf Page 6 of 50 • wide variations in prices; • restricted product diversity and choice; • large variations in market performance. Although the Green Paper recognises that consumer behaviour and preferences may be a factor in limiting market integration, the Commission considers that further reforms may be necessary to make markets work better for consumers. Industry responses tend to favour approaches where the benefits of integration for consumers are best achieved by promoting marketled initiatives that free up competition between retail financial product providers, rather than pursuing opportunities for consumers to actively purchase retail financial products cross border6 . While some work has been undertaken to help stimulate greater demand from consumers, the key interventions to date have largely focused on addressing supply side constraints that restrict crossborder trade in financial services. There seems to be an implicit assumption that once these barriers are removed, the volume of real crossborder transactions (i.e. where consumers buy products and services at a distance from a provider or intermediary based in another EU member state) will rise as consumers become aware of a greater range of product offerings from providers operating outside national boundaries and exercise choice in their search to obtain quality at the best possible price. This assumption may underestimate the strength of consumer resistance to a cross border offering for financial services purchases, and overestimate the level of trust and confidence that consumers have in offerings from firms based outside of domestic borders. Research undertaken by the European Commission has shown that the main barriers appear to be lack of information and language problems. However, this research does not dig deep enough to understand the real motivations and drivers affecting resistance and acceptance of crossborder financial services shopping, comparisons between financial services and other goods and services, and the magnitude of price differences required to persuade consumers to switch to a product available from a provider or intermediary based in another EU member state. In order to address this information gap, the FSA appointed YouGov Financial Services Consulting to establish a benchmark report which measures the extent to 6 See for example response from Council of Mortgage Lenders. www.cml.org.uk/cml/filegrab/EC retailfinancialservicesgreenpaperresponseJuly07.pdf Page 7 of 50 which UK consumers would consider shopping crossborder with regards to different financial services products. This study additionally investigates what factors tend to drive consumer appetite for crossborder shopping (e.g. cultural familiarity vs. value for money vs. product choice). At the outset, we agreed a working definition of a crossborder financial transaction with the FSA which satisfied one of the following scenarios. A consumer living or working in country A buys a financial product/service: • From a firm in neighbouring country B; • At a distance (phone or internet etc) from a firm in country B; • From a firm owned and operating in country A via an intermediary owned and operating in country B • From a firm owned and operating in country B via an intermediary owned and operating in country A • Consumer buys product/service from firm owned and operating in country B via an intermediary owned and operating in country B These definitions were used primarily to ensure there was an agreed working understanding of the types of transactions that could be reasonably classified as crossborder. However, it was important that we did not position these definitions in the minds of survey respondents as we felt it was important to establish how consumers themselves perceive, define and experience a crossborder transaction and assess how well these perceptions and experiences matched up against our definitions. This research sought to address the following key questions: 1. How open are UK consumers to the prospect of buying financial services products crossborder and from different EU member states? 2. What types of crossborder transactions would UK consumers be most likely to consider? 3. What types of experiences have consumers had of crossborder shopping (both financial services and other markets)? 4. How do consumers think crossborder transactions in financial services markets compare with other markets? 5. What are the main factors driving positive and negative views towards cross border shopping (both financial services and other markets)? 6. To what extent are familiarity and personal connections factors driving underlying attitudes and behaviours? 7. What are the perceived benefits from crossborder shopping in financial services? Page 8 of 50 8. What preconditions need to be in place before consumers would consider shopping crossborder? 9. To what extent are consumers familiar with leading European financial services brands that are based outside of the UK and to what extent do they trust these brands? 10.To what extent does brand familiarity and attitudes towards different countries of origin shape consideration of crossborder offerings and underlying levels of trust? 11.What factors would be likely to lead to a change in consideration of shopping crossborder and what kind of tradeoffs would consumers need to make in order to make crossborder shopping a more likely consideration? Page 9 of 50 Scope and Methodology The study focuses on the following groups of consumers: • Those who have recently purchased or are in the market for the range of products in scope • Those who currently hold the range of products in scope and would either definitely consider or definitely not consider a crossborder purchase. • Those who have a “significant relationship” with another EU country. The following products were considered: • Long Term Savings (incl. Pensions) • Investment Products • First Charge Mortgages on Main Residence (and any second homes owned abroad) • Insurance Products (Complex and Simple) • Personal Loans (incl. Secured Loans and Credit Cards) • Retail Deposit Savings Accounts We consciously decided to limit the research with consumers to those regarded as “being in the market”7 for the target range of products, rather than a survey design based around a nationally representative crosssection of the population as a whole. A survey that focused on the views of the population as a whole would include many people who have no experience or understanding of the products in question, potentially have no underlying needs for which they would seek advice, and consequently would not be able to offer an informed opinion about choices they might make or providers they might choose. Conversely, a sample based around actual or probable consumers should provide more robust evidence about likely adoption of a crossborder product offering and a richer understanding of the barriers that need to be overcome. A frequent limitation of many research designs which seek to focus on market participants is the difficulty involved in identifying and recruiting target groups due to low incidence in the population as a whole. The recruitment process can add 7 By this we mean consumers who have taken out a qualifying product within the last two years or are planning to take a product out in the next six months. Page 10 of 50 significant costs and extend project timescales which is exacerbated when looking to recruit across a range of product types. We overcame this problem by running two large scale screener surveys gathering information about a range of financial product holdings and attitudes to crossborder transactions that were sent to all 220,000 active YouGov panellists in January and May 2008, each yielding around 70,000 respondents. We designed a three stage methodology that sought initially to understand consumer views, concerns and experiences of crossborder transactions through qualitative research, provide more quantitative assessments of consumer opinion and finally incorporate the views of retail intermediaries who play a key role in product distribution and delivery of advice to consumers 1.1 Stage 1 Qualitative Research An initial qualitative exploration of the key issues was conducted amongst four different groups to understand the main concerns among consumers and provide insight into their crossborder experiences. These groups were made up of the following type of respondents: • Group 1 held selected financial product(s) or were in the market for one in the next 12 months. They would consider crossborder purchasing for all the financial products they hold. • Group 2 held selected financial product(s) or were in the market for one in the next 12 months. They would NOT consider crossborder for any financial products they hold. • Group 3 held selected financial product(s) or were in the market for one in the next 12 months. They would consider crossborder for SOME of the products they hold but would NOT consider for others. • Group 4 consisted of consumers who have a SIGNIFICANT RELATIONSHIP with another EU country and who have either bought, or tried to buy, a financial product crossborder. 1.2 Stage 2: A quantitative survey Our main programme of quantitative research was based on interviews with 3,507 people who were “in the market” for a range of financial services products. This covered a cross section of consumers who are either recent or prospective purchasers of the financial products within the scope of the study. A minimum of 500 interviews for each of the six main product categories were conducted. In order to measure the extent to which a hierarchy of countries exists within the EU in relation to the provision of financial services and to quantify the extent to which UK consumers
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