In June 2010, the UK’sFinancial Services Authority(FSA) issued guidance intendedfor regulated financial servicesbusinesses...
In June 2010, the UK’sFinancial Services Authority(FSA) issued guidance intendedfor regulated financial servicesbusinesses...
Prevailing financial promotionsregulation applies to platformslike Twitter and Facebook, andforums, blogs and iPhoneapplic...
It also said stuff that’s difficultto disagree with like…
It also said stuff that’s difficultto disagree with like…Use of social media shouldensure clear, fair and notmisleading co...
The trouble is, I ended upthinking…
Whose financial servicesindustry is it anyway?
Is it your advice or your clients?
Is it your advice or your clients?Is it your product or yourcustomers?
Is it your advice or your clients?Is it your product or yourcustomers?Is is about consumerengagement or an industry thatca...
Because the way in whichpeople like to communicate ischanging.
And so I thought I’d share mythoughts on…
And – like any good story – itstarts like this…
…our species just couldn’t helpgathering together (and still can’t)
We couldn’t help swapping stories,enjoying each other’s company andenjoying safety in numbers
We’ve always liked to congregatetogether in order to exchangegoods and services
Or congregate aroundshared values and beliefs
And, generally, havea good time
Language
Language
LanguageTechnology
LanguageTechnology
LanguageTechnologyMeans of distribution
LanguageTechnologyMeans of distribution
LanguageTechnologyMeans of distributionCash
Technology
TechnologyMeans of distribution
TechnologyMeans of distributionCash
Technology
TechnologyMeans of distribution
TechnologyMeans of distributionCash
Now…because it relies on thetransmission of a message via amedium…
…mass media content needs to bemanufactured
EncoderSo, at one end of the model, there’s an individual ororganisation that wants to transmit something…
Encoder MessageWhich means they have to decideon the content of a message…
Encoder Message MediumAnd select the media by which theyintend to transmit that message…
Encoder Message Medium DecoderIn order to reach an individualat the other end of the process…
Encoder Message Medium Decoder…with access to the means to receiveand understand the message
Encoder Message Medium DecoderSo the rules of engagement aredetermined by those with the ability togain access to the medi...
Encoder Message Medium Decoder…whileconsumersof content aresubject tothose rules
Encoder Message Medium DecoderWeb 1.0 continued this pattern
Encoder Message Medium DecoderBut Web 2.0has entirelychanged thepotential of thisroleWeb 1.0 continued this pattern
FreeThat’s because Web 2.0 has madethe ability to publish contentfreely available
FreeTechnologyMeans of distributionCashSo cash is no longer abig barrier. The mainInvestment is time.
FreeTechnologyMeans of distributionThe network forpublishing and distributionis readily accessible
FreeTechnologyWhich just leaves youwith the means requiredto publish content…
And, these days, amobile device is allthat you need…
Encoder Message MediumSo the rules of engagement aredetermined by those with abilityto gain access to the medium…
Encoder Message Medium EncoderMessageSo the rules of engagement aredetermined by those with abilityto gain access to the m...
Provider Content Platform ProviderContentYou end up with a model where – so long asthey’re prepared to invest the time –in...
(As in socialist – everyone who’s able to can participateequally in a common means of sharing and publication)
Which means the social weboffers the equivalent of this…
And this…
And this…
Because we’re able to real-ise offlineinteraction online via social platforms
Opting to participate in as few…
Or as many…
As we like
Which brings me neatlyback around to theguidance for the use ofsocial web platforms bythe UK’s FinancialServices Authority...
By choosing to treat social webplatforms and tools as a mediumthat’s just like traditional massmedia…
The FSA is focusing its attention onthe use of the social web as a meansof pushing promotional messages…
Rather than encouraging the useof the medium for a vastly moreuseful ambition:
Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financi...
Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financi...
Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financi...
The FSA is seeking to regulate forthe worst that can happen andnot the best. Otherwise knownas…
The FSA is seeking to regulate forthe worst that can happen andnot the best. Otherwise knownas…The Dr Pepper moment
But the FSA needs to payattention to its own statutoryobjectives, which are…
Market confidence: Maintainingconfidence in the financialsystem
Market confidence: Maintainingconfidence in the financialsystemPublic awareness: Promotingpublic understanding of thefinan...
Market confidence: Maintainingconfidence in the financialsystemPublic awareness: Promotingpublic understanding of thefinan...
And the FSA needs toheed its own principles ofgood regulation too…
Proportionality: The restrictionswe impose on the industry mustbe proportionate to the benefitsthat are expected to result...
Proportionality: The restrictionswe impose on the industry mustbe proportionate to the benefitsthat are expected to result...
Because by paying adisproportionate amount ofattention to prevention of the DrPepper moment…
Because by paying adisproportionate amount ofattention to prevention of the DrPepper moment…The FSA may prevent consumersf...
Like the way Starbuckscustomers help the coffee-shopbrand enhance and design newproducts and services
Or Lego enables its customers todesign the kind of products thatthey’d like to buy themselves
Or the way in which 37Signalsenables greater transparency andservice experience for clientsthanks to tools like Basecamp
Or the way Trip Advisor enablestravellers to share their opinionof destinations so people havericher sources of informatio...
And even effect improvements infacilities by encouraging ownersof businesses to address issuesabout the quality of their s...
Consumer participation makesfor better regulation
And besides…
The use of social web platforms isonly going in one direction
In 2000 27% of the UK populationwere online. In 2008 it was 76%.86% of UK 18-24 year olds goonline each day.And by 2013, 4...
So consumer habits are changing…
So consumer habits are changing…Consumption of content is changing…
So consumer habits are changing…Consumption of content is changing…And consumer expectations of businesses are changing
Which means the FSA cannot ignore its ownprinciple of good regulation for innovation:
Which means the FSA cannot ignore its ownprinciple of good regulation for innovation:Allowing scope, where appropriate, fo...
…when the most significantparticipant in the marketplacealways has been – and alwayswill be – consumers
If the FSA continues to insiston regarding the social webprimarily as a means ofpushing promotionalmessages
Decoder Medium EncoderMessageThe rules of engagement will bedetermined by consumers with theability to gain access to the ...
Decoder Medium EncoderMessage…while regulated businesseswill feel powerless toconfidently engage with themThe rules of eng...
Decoder Medium EncoderMessageAnd consumers will just findsome other way of obtaining whatthey want instead
Now that’s what I call a Dr Pepper moment
6: Financial promotions industry update No 05 (June 2010), Financial Services Authority22, 23 and 66: Campfire image by Ka...
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
The unsociable FSA's Dr Pepper moment
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The unsociable FSA's Dr Pepper moment

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I originally produced this presentation for a webcast I hosted for BrightTalk in the UK. It offers a critical analysis of guidance issued by the UK financial services regulator - the FSA - about the application of social web tools for consumer communication within financial services. In essence, it claims the FSA has got the wrong end of the stick and that that's detrimental to consumer interests.

This slidedeck is also posted at MRM's slideshare page at www.slideshare.net/MRMLondon.

Published in: Business, Economy & Finance

The unsociable FSA's Dr Pepper moment

  1. 1. In June 2010, the UK’sFinancial Services Authority(FSA) issued guidance intendedfor regulated financial servicesbusinesses in the UK
  2. 2. In June 2010, the UK’sFinancial Services Authority(FSA) issued guidance intendedfor regulated financial servicesbusinesses in the UKHere’s what the guidancesuggests…
  3. 3. Prevailing financial promotionsregulation applies to platformslike Twitter and Facebook, andforums, blogs and iPhoneapplications.
  4. 4. It also said stuff that’s difficultto disagree with like…
  5. 5. It also said stuff that’s difficultto disagree with like…Use of social media shouldensure clear, fair and notmisleading communicationwith clients.
  6. 6. The trouble is, I ended upthinking…
  7. 7. Whose financial servicesindustry is it anyway?
  8. 8. Is it your advice or your clients?
  9. 9. Is it your advice or your clients?Is it your product or yourcustomers?
  10. 10. Is it your advice or your clients?Is it your product or yourcustomers?Is is about consumerengagement or an industry thatcan be regulated?
  11. 11. Because the way in whichpeople like to communicate ischanging.
  12. 12. And so I thought I’d share mythoughts on…
  13. 13. And – like any good story – itstarts like this…
  14. 14. …our species just couldn’t helpgathering together (and still can’t)
  15. 15. We couldn’t help swapping stories,enjoying each other’s company andenjoying safety in numbers
  16. 16. We’ve always liked to congregatetogether in order to exchangegoods and services
  17. 17. Or congregate aroundshared values and beliefs
  18. 18. And, generally, havea good time
  19. 19. Language
  20. 20. Language
  21. 21. LanguageTechnology
  22. 22. LanguageTechnology
  23. 23. LanguageTechnologyMeans of distribution
  24. 24. LanguageTechnologyMeans of distribution
  25. 25. LanguageTechnologyMeans of distributionCash
  26. 26. Technology
  27. 27. TechnologyMeans of distribution
  28. 28. TechnologyMeans of distributionCash
  29. 29. Technology
  30. 30. TechnologyMeans of distribution
  31. 31. TechnologyMeans of distributionCash
  32. 32. Now…because it relies on thetransmission of a message via amedium…
  33. 33. …mass media content needs to bemanufactured
  34. 34. EncoderSo, at one end of the model, there’s an individual ororganisation that wants to transmit something…
  35. 35. Encoder MessageWhich means they have to decideon the content of a message…
  36. 36. Encoder Message MediumAnd select the media by which theyintend to transmit that message…
  37. 37. Encoder Message Medium DecoderIn order to reach an individualat the other end of the process…
  38. 38. Encoder Message Medium Decoder…with access to the means to receiveand understand the message
  39. 39. Encoder Message Medium DecoderSo the rules of engagement aredetermined by those with the ability togain access to the medium…
  40. 40. Encoder Message Medium Decoder…whileconsumersof content aresubject tothose rules
  41. 41. Encoder Message Medium DecoderWeb 1.0 continued this pattern
  42. 42. Encoder Message Medium DecoderBut Web 2.0has entirelychanged thepotential of thisroleWeb 1.0 continued this pattern
  43. 43. FreeThat’s because Web 2.0 has madethe ability to publish contentfreely available
  44. 44. FreeTechnologyMeans of distributionCashSo cash is no longer abig barrier. The mainInvestment is time.
  45. 45. FreeTechnologyMeans of distributionThe network forpublishing and distributionis readily accessible
  46. 46. FreeTechnologyWhich just leaves youwith the means requiredto publish content…
  47. 47. And, these days, amobile device is allthat you need…
  48. 48. Encoder Message MediumSo the rules of engagement aredetermined by those with abilityto gain access to the medium…
  49. 49. Encoder Message Medium EncoderMessageSo the rules of engagement aredetermined by those with abilityto gain access to the medium…And the rules of engagement aredetermined by those with abilityto gain access to the medium…
  50. 50. Provider Content Platform ProviderContentYou end up with a model where – so long asthey’re prepared to invest the time –individuals possess the same potential asorganisations to publish content via platforms
  51. 51. (As in socialist – everyone who’s able to can participateequally in a common means of sharing and publication)
  52. 52. Which means the social weboffers the equivalent of this…
  53. 53. And this…
  54. 54. And this…
  55. 55. Because we’re able to real-ise offlineinteraction online via social platforms
  56. 56. Opting to participate in as few…
  57. 57. Or as many…
  58. 58. As we like
  59. 59. Which brings me neatlyback around to theguidance for the use ofsocial web platforms bythe UK’s FinancialServices Authority (FSA)
  60. 60. By choosing to treat social webplatforms and tools as a mediumthat’s just like traditional massmedia…
  61. 61. The FSA is focusing its attention onthe use of the social web as a meansof pushing promotional messages…
  62. 62. Rather than encouraging the useof the medium for a vastly moreuseful ambition:
  63. 63. Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financialservices businesses and so takecare of their personal financialwellbeing
  64. 64. Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financialservices businesses and so takecare of their personal financialwellbeingHowever people want to
  65. 65. Rather than encouraging the useof the medium for a vastly moreuseful ambition:To encourage consumerengagement with financialservices businesses and so takecare of their personal financialwellbeingHowever people want to and notjust how the FSA would preferthem to
  66. 66. The FSA is seeking to regulate forthe worst that can happen andnot the best. Otherwise knownas…
  67. 67. The FSA is seeking to regulate forthe worst that can happen andnot the best. Otherwise knownas…The Dr Pepper moment
  68. 68. But the FSA needs to payattention to its own statutoryobjectives, which are…
  69. 69. Market confidence: Maintainingconfidence in the financialsystem
  70. 70. Market confidence: Maintainingconfidence in the financialsystemPublic awareness: Promotingpublic understanding of thefinancial system
  71. 71. Market confidence: Maintainingconfidence in the financialsystemPublic awareness: Promotingpublic understanding of thefinancial systemConsumer protection: Securingthe appropriate degree ofprotection for consumers
  72. 72. And the FSA needs toheed its own principles ofgood regulation too…
  73. 73. Proportionality: The restrictionswe impose on the industry mustbe proportionate to the benefitsthat are expected to result fromthose restrictions
  74. 74. Proportionality: The restrictionswe impose on the industry mustbe proportionate to the benefitsthat are expected to result fromthose restrictionsInnovation: For exampleallowing scope, whereappropriate, for different meansof compliance so as not to undulyrestrict market participants fromlaunching new financial productsand services
  75. 75. Because by paying adisproportionate amount ofattention to prevention of the DrPepper moment…
  76. 76. Because by paying adisproportionate amount ofattention to prevention of the DrPepper moment…The FSA may prevent consumersfrom helping build a better UKfinancial services industry
  77. 77. Like the way Starbuckscustomers help the coffee-shopbrand enhance and design newproducts and services
  78. 78. Or Lego enables its customers todesign the kind of products thatthey’d like to buy themselves
  79. 79. Or the way in which 37Signalsenables greater transparency andservice experience for clientsthanks to tools like Basecamp
  80. 80. Or the way Trip Advisor enablestravellers to share their opinionof destinations so people havericher sources of information onwhich to base choices…
  81. 81. And even effect improvements infacilities by encouraging ownersof businesses to address issuesabout the quality of their service
  82. 82. Consumer participation makesfor better regulation
  83. 83. And besides…
  84. 84. The use of social web platforms isonly going in one direction
  85. 85. In 2000 27% of the UK populationwere online. In 2008 it was 76%.86% of UK 18-24 year olds goonline each day.And by 2013, 43.7 million UKconsumers will be online.
  86. 86. So consumer habits are changing…
  87. 87. So consumer habits are changing…Consumption of content is changing…
  88. 88. So consumer habits are changing…Consumption of content is changing…And consumer expectations of businesses are changing
  89. 89. Which means the FSA cannot ignore its ownprinciple of good regulation for innovation:
  90. 90. Which means the FSA cannot ignore its ownprinciple of good regulation for innovation:Allowing scope, where appropriate, fordifferent means of compliance so as notto unduly restrict market participantsfrom launching new financial productsand services
  91. 91. …when the most significantparticipant in the marketplacealways has been – and alwayswill be – consumers
  92. 92. If the FSA continues to insiston regarding the social webprimarily as a means ofpushing promotionalmessages
  93. 93. Decoder Medium EncoderMessageThe rules of engagement will bedetermined by consumers with theability to gain access to the medium…
  94. 94. Decoder Medium EncoderMessage…while regulated businesseswill feel powerless toconfidently engage with themThe rules of engagement will bedetermined by consumers with theability to gain access to the medium…
  95. 95. Decoder Medium EncoderMessageAnd consumers will just findsome other way of obtaining whatthey want instead
  96. 96. Now that’s what I call a Dr Pepper moment
  97. 97. 6: Financial promotions industry update No 05 (June 2010), Financial Services Authority22, 23 and 66: Campfire image by Kara Brugman24, 67 and 105: ‘Al mercatodi campo de fior’ by Pyno Moscato25: Vaulted roof interior by Tim Caynes26 and 68: ‘Lamb & Flag’ by Julia Manzerova29-36: ‘Manuscript’ by Liz Muffet37-40: Hoe’s one cylinder printing press image, Wikipedia41-44: TV aerial image by Víctor Nuño60: iPhone image by William Hook110:Dr Pepper can, Coca Cola Great Britain press centrePhotography credits and sources
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