The Fairness Playbook: How Fintech Can Earn Consumers’ Trust

Welcome to Money Isn’t Everything. I’m Mary Wisniewski, Cornerstone Advisors editor-at-large and host of the show that explores early-stage ideas that could, if not already, shake up financial services.

On today’s show, I talked with Consumer Reports’ Delicia Hand about the organization’s newer playbook.

It’s a really interesting playbook called the Fairness by Design Playbook, and it offers recommendations for financial product design and much more.

So we talk about that.

We also talk about how GenAI is changing scams, why financial health metrics ought to be included in product KPIs, and why building with users, not just for them, is essential.

We also explore the implications of a much leaner CFPB for consumer protections.

Here’s our conversation.

Delicia, welcome to Money Isn’t Everything.

It’s wonderful to have you on the show today.

Nice to be here.

Thank you for having me.

Yeah.

It’s been multiple weeks ago at this point, but Consumer Reports put out this wonderful playbook that speaks to everything that I really care about, which is fairness in design.

I want to get into the specifics there, but I wanted to sort of frame up the backdrop.

What was or is happening in the consumer finance landscape that inspired Consumer Reports to put out this playbook?

Sure.

So there are a couple of things.

One is that when we started doing testing of digital finance products and services a few years ago, we were still in a pandemic, kind of just coming out of the pandemic.

Like a lot of people, we saw the uptick in use of digital finance products by consumers.

Prior to being at Consumer Reports, I actually spent 10 years as a consumer finance regulator.

So I was at the Consumer Financial Protection Bureau and was there during the start of the pandemic.

I was really able to observe a lot of things happening to consumers, how the financial world was responding, but then how, through necessity, loads of consumers started managing their finances through more digital means.

We were really curious about what’s happening there.

Who’s measuring if there’s a difference between engaging in a fintech app or using regular banks?

So we started to evaluate different digital finance products.

We’ve learned a lot of things.

We decided to reflect back on that and not just lift up the data from those findings, but actual product and design recommendations in this playbook.

Yeah.

That I found really interesting because you don’t often see that necessarily in a playbook or white paper.

I had some follow-ups on the specifics in it.

But before that, you mentioned the CFPB.

I did have a question about that because they’re getting so many cuts.

I’m wondering, do you see Consumer Reports helping to fill a void with what’s going on at the CFPB right now, or did it just happen to occur around a similar time frame?

I think it’s probably both.

One of the reasons why it was important, even before this moment, almost four years ago, for us to start testing digital finance products is because even with the CFPB, there wasn’t anyone out there who was regularly and systematically evaluating these products from a consumer perspective.

You may be following the law as a provider of these services, but how does that translate from a consumer perspective?

The law often is a baseline requirement, especially at the federal level.

But consumer needs go beyond just your basic floor.

We’re really looking at the ceiling.

So there was a need for someone asking the questions, do these products deliver what they say they’re going to deliver?

You hear a lot of language, or we were seeing a lot of language being used, things like financial health, financial security, financial freedom.

Who is out there evaluating whether these products have the ability to deliver on those things?

Or what are the metrics by which you even assess those things?

So that wasn’t something that the CFPB was doing at the time.

And then now, yes, there’s absolutely a gap.

The CFPB was birthed in a moment where fintech was new.

It was not as established.

We’re now at another moment of newness.

AI is everywhere.

It’s in everything, or increasingly in everything.

So this is not the right time to shutter a consumer protection regulator.

If anything, this is the exact moment where you need somebody who’s in the marketplace looking very closely at how new technologies are showing up in all sorts of consumer products, especially consumer finance.

So it’s unfortunate.

We do feel like there is an opportunity to at least try to continue to look closely and evaluate products from this perspective around how technology is helping or potentially creating challenges for consumers.

Yeah.

For the AI, I was just reading a study that came out by Alloy recently, and it was the State of Fraud 2025.

AI was definitely mentioned in this as helping fraudsters be more convincing.

I’m wondering, are you already hearing from consumers like, oh, I fell for this AI scam?

Or is this more like, get in front of it?

What’s sort of the sentiment that’s coming in firsthand that you’re hearing?

Yeah.

I mean, it’s a little bit of both.

We actually published a report earlier this year that focused, for example, on voice-cloning tools that are out there for all sorts of good reasons.

I think one of the things with AI, as with any technology, you’ve got good uses of these things, and then you’ve got bad uses or harmful uses.

We put out a report where we were evaluating AI tools that you can use to replicate someone’s voice.

There are a number of good reasons why you may need those capabilities, but we also saw that it enables people, for example, to replicate with a good deal of accuracy your voice, my voice, your voiceprint.

Someone can capture through a recording your voice, and then maybe they can make phone calls on your behalf.

They could reach out to family members or create videos using your voiceprint.

So if you can think it, at this point someone will be able to leverage the much more accessible tools that are out there.

They are exacerbating some of the scam and fraud pathways that are out there.

There have always been fraud and scams and tricks and traps for consumers, but it certainly is exacerbating things for sure.

Voice cloning is just one example of that.

Yeah.

I recently spoke with a founder of a neobank called Charlie, and its focus is older adults.

He’s been making it his personal mission to really spread fraud and scam tips and tricks.

But he’s finding success.

He’s finding an audience on TikTok.

So I think that’s cool.

There’s one segment of the show, and I think it frames up where we can get into more of the specifics with the playbook, and it’s “That’s What You Said.”

You said this, I believe, on another podcast.

It was getting into exploring responsible innovation, which is at the heart of this playbook.

You made the comment, “You are not just pushing to be fastest and get out to market and then acquire as many consumers as possible, but you are really focused on your constituents and trying to match the product experience and delivery to the particular needs of those communities.”

I just wanted to unpack that thought a little bit more.

What are some ways or examples of reflecting that idea through an app, either in existence or what it could be?

Yeah.

So I often say responsible innovation is trying to innovate with consumers, not just for them.

In digital finance, I think oftentimes traditionally consumer needs are viewed as potentially in competition with, or maybe not necessarily driving toward, a company’s bottom line.

I think we, and there are many in this space, have evolved beyond that.

We now realize that there are business-reinforcing advantages to innovating responsibly.

So I think what I mean by, if we move beyond this mentality of, if we build it, they will come, and move more to, let’s build with consumers.

This is even moving beyond focus groups.

There’s a lot of user experience testing and focus groups with consumers that happens now.

That’s really good, but there’s still a mentality sometimes of building for consumers.

So that’s one thing that comes to mind.

I think the other thing is also building into the design of a product not just the things that are required or reactive or anticipating compliance responsibilities, but the things that are really responsive to the consumer’s needs.

So when we test a product, for example, we go into it as a consumer would.

We download the app and we record every little step that we take.

We make observations against certain benchmarks and standards.

When you go into the app, are they pushing you a certain type of content immediately?

Each one of those things is a product design decision.

I think about the opportunity in that.

Oftentimes, the first thing you see when you go to use an app, you see the required privacy notice.

Or you open up a website and you’re required to engage with some kind of privacy content.

Those are required things.

What if companies were designing products to also ensure that other consumer protections were built in and easy to use?

So maybe instead of having you go through the fine print of a privacy policy, which most people click through to get to what they want, what if that was integrated into your everyday experience?

Or when something happens, you’re pushed notices proactively, for example.

So I think that’s a concrete example of, when you’re innovating with consumers, you’re really thinking about the journey that consumers go on when they’re using a product.

What are those moments to design for their experience, not necessarily for them to use your product?

Yeah.

That is so important, especially when you think about how a lot of these, and I’m speaking more to fintech than the banking app, but ultimately kind of all of them, the mission statement is usually like, this is to improve a financial outcome.

So if there are flaws, intentionally or not intentionally, in the app, that is the opposite of that mission.

Delicia, I’m kind of curious.

I used to work for Bankrate, so they’d evaluate bank accounts based on fees, how much it pays, how many branches, how many ATMs, but not so much on the mobile app.

I feel like this has been a large gap ever since mobile banking has become a thing.

How hard is it, or was it, to decide these are the things that matter right now when evaluating these products?

Sure.

So we evaluate on a principle basis.

There are six principles that we use: transparency, privacy, safety.

Those are kind of basic regulatory principles.

Then we have more outcomes-based principles, such as inclusivity, user-centricity.

Is this user-friendly?

Are things easy to find?

What’s your customer service experience like?

And financial well-being.

For your specific goals and financial health and well-being objectives, are there product attributes that can help you manage through difficult moments in life, that can help you set goals?

How are these things integrated into the user experience beyond just education and literature that you can find in the product?

So we evaluate based on these principles, but we didn’t just put together this evaluation approach.

We engaged with a number of stakeholders.

So we’re Consumer Reports.

We engage with consumers.

We ask about what are the products that you care most about?

What products are you using the most in terms of digital finance?

That lifted up product areas that we saw that consumers were using the most.

We also reinforced that with market data.

So we asked consumers themselves, but we also looked at market data.

Then we engaged the ecosystem, academics, think tanks, financial institutions themselves.

We looked at standards in the U.S. marketplace, but we also looked at other countries who were leading in terms of similar issues and standards that they’ve developed for outcomes-based measures when looking specifically at digital finance.

So we designed our approach based on this iterative process where we interviewed all sorts of different stakeholders and got feedback on it.

Then started to test in limited ways by evaluating in kind of narrow ways.

Once we were satisfied that this was something that was credible and meaningful, then we launched and started to do more comprehensive evaluations.

Yeah.

I mean, I was interested in the whole thing, but there were three areas that I was like, oh, this is especially interesting.

This one was the safety recommendations.

The point was to show customers exactly what money is protected and what isn’t, using the official signs and language required by law.

The reason why I flagged this is just because there was the huge lockout of people trying to use apps, I think it was Yotta, with the whole debacle that happened.

Gosh, I think it was this year even.

There was a deep confusion of whether this was protected by FDIC or not.

It seems like the brands are confusing consumers about, when they partner with the bank, what’s covered, what isn’t covered, what’s the tiny little minutia that could screw this up for you.

I can’t imagine the FDIC stamp of approval is always top of mind for the consumer, but it feels like in the last year or so it certainly was for people who got locked out of their money.

I’m wondering, do you think there’s the opposite of indifference for knowing their money is protected?

Are we still in this heightened moment, or was it always more of a slice of the population who has been hit?

I think of it as almost continual slices.

These are not just individual moments.

There’s a series of moments that happen.

So if it’s Yotta one day, it’s Synapse the next day, FTX, or, you know.

The challenge is that when it comes to money, consumers make a lot of basic assumptions.

So they may not necessarily even notice the FDIC-insured language, but it doesn’t necessarily mean they’re not making the assumption that their money is protected in whatever vehicle it’s stored in.

If financial institutions are offering deposit-insured-like products or offering to consumers, “Hey, deposit your paycheck here,” and it looks like a bank account, you can deposit and you can debit, you can make purchases and you can store continuous amounts of value.

Whether there’s explicit FDIC branding or not, this can be confusing to the consumer and misleading.

What we found, especially in our consumer surveys, is that many consumers don’t understand that funds in different kinds of, whether it be some P2P apps or maybe a digital wallet or an exchange, may not be FDIC-insured.

But because you can deposit funds, transfer funds and you can withdraw those funds, they make the same assumptions.

They think, well, this is an institution and I’m able to do all these regular transactions the same as I would my bank.

So they make the same set of assumptions.

We found this issue continually.

I sort of make this analogy to your car manual.

You get a car, you walk off the lot, you probably never look at the manual.

You see it in your glove box.

You never have a need to look at it until something goes wrong.

A light on your dashboard or you get a flat tire.

I would say FDIC insurance and other kinds of disclosures and assurances like that are similar to that auto manual.

You want it to be there.

You want it to be in your car.

You want it to be accessible so that if you get a flat tire or you’ve got some light that goes off, you can figure out what to do.

So consumers want that same kind of surety about what happens with their funds in these moments.

It can be big moments or it can be small moments as well.

It shouldn’t take a financial institution collapsing for a consumer to realize that they’re locked out of their account or they have no right to redeem their funds because it wasn’t an FDIC-insured product.

So that’s one of the reasons why it was important for us to be looking at these apps.

Does banking digitally or holding your funds digitally make a difference?

Yeah.

I’m so glad that you are because it’s the highest stakes, really.

Another really interesting area, one suggestion was to make financial well-being a core success metric by embedding it into your KPIs.

I really love this idea.

I’m just kind of curious, I have no sense of this.

Are banks, credit unions or fintech companies already doing this?

Or are you ahead of the curve, setting a very interesting path to your product development?

What we’ve seen is that, on the plus side, there are a number of different kinds of financial institutions that are using the language of financial well-being.

We’ve seen a few different kinds of practices.

So I would say at kind of a good-enough level, we’ve seen a lot of institutions provide financial literacy and educational materials.

So there are modules that are available that consumers can take, and then there are different kinds of literature that are provided.

Then I would say at the game-changing level, this is kind of a basic level that we’ve seen.

But then you move from just providing materials, which we are evolving, unfortunately, into a society where people aren’t reading a lot.

So how much value is it that you’ve got a module that someone can read where we have data showing that people are consuming content very differently these days?

People are listening on podcasts, they’re watching videos, they’re watching Reels and things like that.

Whether that’s good or bad, that’s a different question.

But that’s data in terms of how people are consuming information.

So it’s one of the reasons why we focused on this as a core metric and moving from just providing content to embedding it into your KPIs.

Because you need to be tracking, okay, to the extent that you have basic information, which is sort of basic, it’s not the best that institutions can do, how can you grow and focus on the number of users that are engaging with that content?

Moving beyond, when are users using this content?

Then different kinds of KPIs should also connect to financial well-being to the extent that you move beyond the basic educational materials.

What other kinds of metrics should you be tracking?

Are people able to use the tools that you’re providing?

To the extent that you are providing in-app tools to help people manage their finances, accomplish certain goals like saving for an emergency and things like that, are you actually tracking consumer demand of that?

How are they using those things?

How are consumers using these tools to build long-term financial wellness?

So those are some of the metrics that we want companies to be looking at.

There’s a business case to be made for that.

There’s research that shows that a focus on financial well-being is a driver of brand reputation.

It’s why we started doing this research in the first place, because companies were actively using language of financial health and financial well-being.

Consumers assume that if you put out a product and say, “We’ll help you through this hard moment in life,” we want to see that maybe it’s a product that can actually help them to achieve that.

So when you develop these KPIs and metrics, it enables you to build that pathway.

But from a consumer perspective, it also demonstrates that you’re an institution that’s committed to their well-being and not just the transaction or product.

Yeah.

I really hope that the industry embraces that because I always just hear, oh, this is how many active users we have using this app.

It would be much more interesting, this is how many saved, if the intent was to help them save more.

The third thing I wanted to highlight, because I just feel like this could be where the ball gets dropped easily, is around the point of being inclusive.

There was a mention of, is this product compatible with all the technology, including the older devices?

In your research, are you finding a disconnect here?

I just imagine it could happen easily.

Yeah.

So this is, we have many interesting stories to tell here around inclusivity.

I think oftentimes people hear about it and they think about more racial or gender demographics.

But the aperture is wider and includes a lot of different issues.

It can include, for example, your basic education level.

Are you providing information to consumers at a level that they can understand and comprehend?

Are you using a basic eighth-grade reading level when you describe certain concepts?

That’s a basic thing that we have found and flagged for companies, for example.

Things like literacy levels.

Accessibility has also been an issue from transitioning from the website to the app.

Things are hard to see and those adjustments aren’t often made.

It was really illuminating evaluating these different products and just seeing how, I think we went in assuming that this would be a no-brainer kind of thing and we would see a lot of good and best practices here.

But I would say across a number of different kinds of financial products and companies offering these products, basic things like, for people who might be visually impaired, not being able to adjust within the app, for example, to see something clearly or having language accessibility options.

So those are things that we noticed that are also encompassed under inclusivity.

Well, I am excited to see it, and I’ll be excited to follow whatever comes next, which I do want to ask you about.

But just a couple last questions.

One is, if you were to give just one piece of advice for fintech developers or bank and credit union developers of their own mobile apps, what should be their next move in working toward this fairness model?

That’s a really good question.

I would probably go back to making sure that you’re building with consumers and not just for them.

I think that’s the single most transformative shift that developers can make.

One of the things we’ve seen is there’s testing, but then testing can happen and there’s testing and research that goes into product development, but then sometimes it seems to stop.

You’re off developing the product based on a set of assumptions and information that you’ve gotten from that initial research.

So that testing should continually be happening.

The other thing sometimes that we’ve seen is testing happens at the end.

So you’re not even thinking about specific consumer needs.

You’ve got this product idea, you’ve designed it, developed it, and then you give it to a number of consumers who are test subjects.

I think the fairness-by-design approach is consumers are equal partners and potentially even co-creators through the entire product lifecycle.

They have a voice in design decisions.

To the extent that you are developing solutions to a specific consumer problem, are you actually validating some of those solutions with actual consumers?

Then using explainable and accessible plain language in that engagement with them.

That is great advice.

Delicia, my last, well, last two questions are, one, how should someone reach you?

And what should one expect from Consumer Reports next as it relates to fintech and banking?

Sure.

You can reach us by going to ConsumerReports.org.

That’s our website.

You can see our product ratings of all kinds, but also our digital finance product evaluations there.

What’s next?

We are doing a couple of things.

We’re continuing to rate different kinds of digital finance products.

What’s next is crypto wallets.

That’s a good one.

Yes.

And investment apps.

So your Robinhoods or Stash apps, but also your more traditional investment institutions that also have app-based engagements and things like that.

So we’ll be looking specifically at those products next.

The other thing that we’re doing is we’re holding ourselves to our own advice.

In the spring, we’re going to be doing a tech sprint where we’re going to bring consumers to the table to work with different members of the consumer finance industry to do some co-creation.

We’re going to set some consumer challenges and create a scenario where consumers will have the opportunity to work with product designers to solve some of the secure problems.

Oh, well, I’ll have to stay tuned to that.

Final question is, what’s the image on your phone’s lock screen?

It’s the ocean.

Well, I love the ocean, so it must be your thing.

Yep.

I was born in the Caribbean, and any beach is my favorite place to be.

Well, wonderful.

Delicia, thanks so much for walking me through the work that Consumer Reports is doing.

I’m really, really fascinated by it.

So thank you so much for your time today.

You’re welcome.

Really appreciate the opportunity to talk with you.

Okay.

So one thing that really popped for me was making the point of rethinking KPIs a bit more for the financial product.

If it’s supposed to help someone save, you’ve got to track if they’re saving more.

As she says, it’s not enough to count active users.

We should be counting how many people are actually saving or meeting their goals.

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Up next will be the final episode for 2025, and it’s with a CEO of a bank that is making friction, well, a selling point.

Catch you then.