CG-3 Clear language and presentation principles and guidelines for the industry
Notice
The new Financial Consumer Protection Framework (FCPF) in the Bank Act and the Financial Consumer Protection Framework Regulations (collectively: “FCPF Requirements”) come into force on June 30, 2022. The FCPF Requirements apply to banks, authorized foreign banks and federal credit unions. This guideline will be reviewed, including for purposes of reflecting the FCPF Requirements, and will be reissued in due course as is appropriate. Starting June 30, 2022, this guideline is to be read by banks, authorized foreign banks and federal credit unions in conjunction with, and subject to, the FCPF Requirements. If there is any inconsistency between the FCPF Requirements and this guideline relating to banks, authorized foreign banks and federal credit unions and their conduct post June 30, 2022, the FCPF Requirements prevail.
Clear language project: background and objective
Although the Financial Consumer Agency of Canada (FCAC) provided plain language information to consumers in the past, we recently established more formal clear language and presentation principles that can be used in our consumer education and financial literacy initiatives. FCAC is currently reviewing and adapting its consumer material to better serve the needs of Canadians in understanding their personal finances and the banking system in general by using these principles as guidelines.
These principles and guidelines are based on research of current and past initiatives in the area of plain language at the provincial, federal and international levels.
Following the announcement of the proposed amendments to the plain language provision of the Cost of Borrowing Regulations, the Commissioner requested that the Supervision and Promotion Branch of FCAC provides guidelines to the industry in using these principles. The guidelines will ensure that there is no confusion about the intent and scope of the Clear Language policy.
The following guideline is based on the Supervision and Promotion Branch’s perspective on how a federally regulated financial institution (FRFI) might ensure clear language and presentation in its communications with their consumers. Can they provide FCAC with policies and procedures that describe their efforts in making product applications, forms and agreements easier to understand and use?
FCAC’s Supervision and Promotion Branch established the following guidelines to assist the industry in developing communications for consumers. Guidelines are not rules; they require judgment and they suggest rather than prescribe.
Clear language and presentation
What is it?
Clear and simple writing starts by focusing on the needs of the reader and presents information in a logical order using familiar, everyday words and expressions. It avoids jargon and uses a minimum of technical language in a manner that is not misleading, but that an audience can understand quickly and easily.
Why clear?
Consumers | FRFIs |
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will understand the message easily | will save time and money |
will make sound and informed financial decisions | will improve communication between employees and customers |
will be satisfied | will reduce employee errors |
will save time | will be able to train employees in clear communications correctly and quickly |
Old vs. new
The proposed amendments to the Regulations were published May 23, 2009 in the Canada Gazette.
The current wording states:
“6(4) A disclosure statement, or a consent in relation to a disclosure statement, must be in plain language that is clear and concise. It must be presented in a manner that is logical and likely to bring to the borrower’s attention the information required by these Regulations to be disclosed.”
The proposed wording states:
“6(4) Any disclosure that is required to be made by a bank under these regulations must be made in language, and presented in a manner, that is clear, simple and not misleading.”
FCAC expectations
A FRFI must effectively demonstrate that it has applied the five principles of clear language outlined below.
Its policies and procedures must incorporate the operational guidelines in order to measure and ensure that the principles are met and respected.
FCAC principles
- Know your audience.
- Make your material understandable by planning your text.
- Write clearly.
- Use the visual presentation to enhance your text.
- Test your material.
The proposed amendments to the Regulations were published May 23, 2009 in the Canada Gazette.
Principle | Guidance | Operational guidelines |
---|---|---|
Know your audience |
In all communications directed at consumers, the FRFI needs to:
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Make your material understandable by planning your text |
Let consumers know what they’re looking at and provide them the information they need. Avoid ambiguities: be direct, concise and to the point. Use a logical pattern and make the links between your ideas obvious. Remove any information that is not essential to your purpose. Will the consumers understand the document the first time they read it? |
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Write clearly |
Organize your ideas and structure your writing. |
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Use the visual presentation to enhance your text |
Create a reader-friendly format. The way the information is presented on the page is almost as important as the words used to describe it. Your document needs to be visually inviting. |
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Test your material |
A FRFI needs to test its documents in order to determine whether they are user-friendly. It is especially important to test application forms and agreements that will be used by the average reader. If the average consumer can read the entire document without feeling confused and without having to go back and read it again, you’ve passed the test. |
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Other considerations
Writing in clear and simple language does not mean deleting complex information to make the document easier to understand.
Do not oversimplify. If details are important, write them clearly. Readers must have a clear understanding of your product, and they don’t want surprises.
Get help with clear language and presentation by seeking services from an expert or consultant who combines skills in writing and information design.
Offer clear language and presentation training to your employees.
These guidelines are not standards, but they will help in evaluating the degree to which you have applied the principles of clear language.
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