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A Behavioral-Pattern Driven Framework for Research on Financial Consumer Protection Cover

A Behavioral-Pattern Driven Framework for Research on Financial Consumer Protection

By: Man Cho  
Open Access
|Jun 2025

Figures & Tables

Behavioral patterns to be tamed on the supply-side

BehaviorExamplesPolicy Remedies
(1). Profit-making over the fiduciary duty
  • • Putting intermediaries' interests (i.e., profit-making) over those of financial consumers

  • • Business ethics training programs targeting different levels of employees in the financial service sector

  • • A mandatory oath like the Hippocratic Oath by medical doctors

(2). Moral hazard in product design and sale
  • • Developing and selling predatory or fraudulent financial products

  • • Regulatory requirements to prevent ‘incomplete sale’ (by providing appropriate information in an appropriate format, by offering a cooling-off period, by establishing an efficient and affordable conflict resolution mechanism, among others)

  • • Regulatory oversight of intermediaries

(3). Inefficient risk management practices
  • • Volume maximization strategy, to increase current profit at the cost of long-term financial loss

  • • Cyclical risk measurement and management practices

  • • Prudential regulations to institute a long-term view in the intermediaries' operation and help prevent pro-cyclical risk management practices

  • • Require sound risk measurement and management practices following accepted finance theories and empirical models in assessing the systematic and idiosyncratic risk factors; A BD·ML-based analytics to be considered

  • • Risk-rating of financial products to be conveyed to consumers(done by intermediary, validated by regulator, and released to consumers in a plain language; the BaFin case as an example)

(4). Suboptimal technology choice & utilization
  • • Under-utilization and under-investment in DPA technologies for front-office functions

  • • Under-utilization of DPA technologies for middle- or back-office functions

  • • Level the playing field in terms of data, market infrastructure, and other dimensions of competition among the intermediary types

  • • Regulatory sandbox to promote innovations among financial intermediaries

  • • Equip intermediaries with the BDAC in all three dimensions of personnel, infrastructure, and governance

(5). Inadequate responses to financial frauds & crimes (demand-side, supply-side, and regulators)
  • • Organized financial crimes seriously affecting consumers' welfare (e.g., voice or messenger phishing, pharming, smishing, and hacking)

  • • Mechanism to coordinate the combat against crime organizations that are behind the financial frauds

  • • The SAR (Suspected Activity Report) requirement by CFPB

  • • Information dissemination on cases of financial frauds occurring in different countries, and on policy remedies employed

Behavioral patterns to be tamed on the demand-side

BehaviorExamplesPolicy Remedies
(1). Over-consumption & under-saving
  • • Present time bias (i.e., too much consumption now but under-saving for the future)

  • • Under-prepared for retirement

  • • Well-targeted financial education (FE) programs with a clear objective, tailored to remedy this behavioral pattern for different consumer groups (differentiated by lifecycle stages, endowment levels, and other factors)

(2). Over-leverage & unsound product choice
  • • Easy borrowing under platform-based lending, leading to over-borrowing

  • • Over-leverage caused by predatory lending products (e.g., subprime mortgage contracts)

  • • Well-targeted FE programs as above

  • • In-time, independent, and interactive counseling or advice programs (a GenAI-based interactive system to be considered)

  • • Sound and incremental expansion of financial inclusion for marginal borrowers

(3). Excessive risk-taking & unsound product choice
  • • Herd behavior caused by a strong and sustained asset price upturn

  • • Well-targeted FE programs as above, elaborating why “it is very hard to make money!”

  • • A GenAI-based investment consultation system (e.g., a robo-advisor operated by an independent entity)

  • • Information sharing (i.e., collecting and disseminating real-world cases on outcomes of the herd investment behavior and the fraudulent intermediaries)

DOI: https://doi.org/10.2478/irfc-2025-0002 | Journal eISSN: 2508-464X | Journal ISSN: 2508-3155
Language: English
Page range: 19 - 36
Submitted on: Nov 26, 2024
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Accepted on: Apr 23, 2025
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Published on: Jun 30, 2025
In partnership with: Paradigm Publishing Services

© 2025 Man Cho, published by International Academy of Financial Consumers
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.