Presentation by Pete Lunn, ESRI, at the Behavioural Economics Workshop, OECD, Paris - 31 March 2014. More information at www.oecd.org/gov/behavioural-economics.htm
2. Initial example 1
•
Scientific studies show that decision-makers are drawn to default options
•
Companies can default consumers into additional products
•
New EU Consumer Rights Directive now prohibits this
•
Companies must offer an “active” choice
3. Initial example 2: fuel efficiency labelling
•
The “MPG” illusion (Larrick and Soll, 2008)
•
May distort product comparison
•
New US EPA label aims to “correct” the illusion
•
Possible to test empirically for effectiveness prior to adoption
0
10
20
30
40
50
60
70
80
90
100
10
15
20
25
30
35
40
45
50
55
60
Fuel Requirement (Gallons Per 1,000 Miles)
Miles Per Gallon (MPG)
4. What is behavioural economics?
Dictionary definition:
BE is the application of psychological insights to economic analysis.
For the purposes of this review:
BE is the application of the inductive scientific method to the study of economic behaviour.
5. Behavioural economics ≠ “nudges”
•
Thaler and Sunstein (2008)
–
Do not deny people choices
–
Manipulate the context to promote better choices, through “choice architecture”
–
Two initial examples are nudges
–
Note: they do involve some prohibition and restrictions on choice
•
This is only one way to use BE
–
Nudges may not be enough
–
BE findings can be used to support some bans or other limits on choice
–
Evidence may show that a more paternalistic policy is better
–
E.g. OECD recommends compulsory second tier pension
6. US example: CARD Act 2009
•
Credit Card Accountability Responsibility and Disclosure Act signed in May 2009
•
Behavioural evidence suggests consumers:
–
Discount or fail to attend to potential costs
–
Too optimistic about avoiding fees
•
New “behaviourally informed” regulations
–
Ban certain types of fee
–
Default to not honour limit-busting purchase
–
Calculations on bills to nudge repayments
•
Early evidence suggests large consumer gains from the act
–
More from the bans than the nudges
•
For other US examples of “empirically informed regulation” read Sunstein
•
Aim is often to avoid more regulation
7. UK Behavioural Insights Team
•
Internal unit of behavioural researchers based in the UK Cabinet Office... now “spun out”
•
Designs behaviourally informed policies and conducts experiments and trials
Fine collection
Subsidised loft clearance
•
Empirical approach integrates policymaking and evidence gathering
•
Some general principles emerge
8. Other examples
DG SANCO
Joint Research Centre
Productivity Commission
Competition and Consumer Agency iNudgeyou
Swedish Consumer Agency
•
Over 60 behaviourally informed policies cited in review as a whole
•
Many events designed to raise awareness of behavioural principles among policymakers
•
Influence of BE is often implicit rather than explicit
GreeNudge
Centre d’analyse stratégique
Office of Fair Trading Financial Conduct Authority
Consumer Financial Protection Bureau
9. Regulatory design: simplification
•
Two common forms of mandated simplification:
−
Simplified information (product descriptions)
In US, CFPB on mortgages, student loans, cards
−
Simplified choices (product ranges)
In UK, OFGEM’s plans to limit energy tariffs
•
Backed by evidence on “choice overload”
−
Complexity can reduce engagement
−
Complexity can result in poorer choices
•
Mixed evidence of positive effects
In UK, MCOB increased prices without reducing dispersion
In US, experiments found SEC “Summary Prospectus” had little impact on mutual fund choice
But in Massachusetts, standardisation of health insurance products appears to have been effective
10. Regulatory design: convenience
•
Decision-makers drawn to default options
−
Auto-enrolment into pensions
In NZ, led to greatly increased coverage
In Australia, aim to get workers onto good default policies
−
Organ donation
In UK, active choice required for driving licence
•
Decision-makers drawn to convenient options
−
Make as option easy and more people take it
−
Small frictions can have large effects
11. Regulatory design: salience
•
Need to get attention has long been understood
Consumer warnings on cigarettes etc.
In Sweden, “orange envelope” pension information
•
Salience can alter impact of taxes
In US, decisions affected by alcohol tax on tag or at till
•
Bigger issue may be “shrouding”
−
Hidden charges in financial products
−
Drip pricing
−
Mandated total cost pricing
−
Banning “hidden fees”, e.g. Card Act
12. Regulatory design: debiasing
•
Regulations can be designed to correct mistakes
−
Mandated worked examples of compound interest
−
Mandated disclosure of loan default probability
−
Disclosure of usage information in telecoms and energy markets
•
Big issue: how to identify mistakes?
−
“Biases” can counterbalance
−
One person’s unhealthy overeating is another’s personal choice
−
How do we know whether decisions after a debiasing intervention are better than before it?
13. Three (related) observations on regulatory design
1.
It is much easier to show a behavioural effect exists than to measure its overall impact on a market
2.
With decisions over risk detriment is likely but hard to show
−
Gambling
−
Insurance markets
−
Financial investment risk
3.
Regulators are becoming more empirical
14. Regulatory delivery: BE principles
•
Simplification, convenience and salience relevant to good regulatory delivery too
•
Conversely, complexity, inconvenience and inattention may frequently underlie breaches of regulations
•
Compliance depends on perceptions of fairness
–
People will act against their own interests when they perceive unfairness
–
Compliance may depend on whether others are seen to comply
E.g. Tax compliance experiments
•
Conduct of market studies requires behavioural skills
•
Empirical testing of regulations
15. Conclusions
•
BE is increasingly employed in regulatory policymaking in many countries
−
Including in exploring alternatives to rules
−
Especially in consumer and competition policy
•
BE suggests benefits to a more empirical approach
−
Context specific research
−
More integration of evidence gathering and policymaking
Thank You