CFPB | Microcopy by Amit

Accept money and account disclosures

See how a lawsuit win led to a high-profile project where I had to lead the efforts with a content-first design.

Prologue:

New Year’s brought some good news. And a lot of commotion. PayPal had just won a lawsuit against the Consumer Financial Protection Bureau (CFPB) that was going on for ages.

The Consumer Financial Protection Bureau is a U.S. government agency that makes sure banks, lenders, and other financial companies treat their customers fairly.

It was a major reason why PayPal had 3 consumer accounts.

Role I played: Lead content designer

Duration: 1 month

Stakeholders: Product owner, Senior designer, UX researcher, V.P Legal, Director (content), VP (Branded Experiences), and VP (Design)

Implications:

Disclose all the fees to the users before they “upgrade” their account or get a wallet account that lets them hold a balance. We were doing it using 2 types of fee disclosures on the page:
1. Short-form fee disclosures
2. Long-form fee disclosures
A long unwinding disclosure page that had one of the biggest drop-offs.
It was the reason why PayPal had 3 account types for consumers:
1. PayPal account (basic account without wallet)
2. PayPal Cash account
3. PayPal Cash Plus account
Each of these accounts was technically a different account. We couldn’t simply tell the users that they were upgrading their PayPal account to a wallet account.

Business objective:

Update the disclosure page by removing the short form fee disclosure while being legally compliant. We had to make changes in warp speed. That meant designing the page, localizing the copy, building, testing, and releasing it within 20 days.

Improve the customer lifetime value (CLTV) of a PayPal user by offering an efficient and simplified fee disclosure and CIP journey.

Audience:

All PayPal consumer accounts in US who're eligible for a Cash or Cash Plus accounts

Challenges:

It was a high-profile project because of the stakes and implications for the company
The page had to be watertight and legally compliant because of the high-profile win against a government agency.
Every letter on the page was stringently scrutinised by legal
We had to ship the new page within 20 days

My content strategy:

Get users to confidently choose a PayPal Cash or PayPal Cash Plus account and make it appealing to them by addressing any potential concerns that they may have around fees, new accounts, among others.

Leading the way with content-first design

I found this project to be an exciting opportunity to lead with content-first design, because:

It was a content-heavy page
The accept money choice screen was one of the most frequently visited pages
It was a page with substantial drop-offs for Cash and Cash Plus accounts
There was a lot of room to remove user confusion
It was a high-profile and challenging project
It would have a direct monetary impact on the company's bottom line

Here's how the flows looked previously:

Competitor analysis and explorations

Identifying opportunities for improvement

Identifying the current pain points
By removing the short form disclosures, I didn’t want users to focus on the long form of fee disclosures and take away that we were charging them different types of fee.
Combine 2 pages (disclosures + Customer Identification) to reduce drop-offs.
Add a sticky button on the page that could let users confirm without scrolling all the way down.

Getting the buy-ins:

Multi-phased approach:
- Product wanted to ship this page ASAP
- We gave them 2 versions of the page that would mean incremental or phased approach while ensuring that we met the deadline
- Presented to senior leadership of product, design, and content to get their buy-ins on my approach

My hypotheses:

When users see the CFPB screen, they are confused about a new account and why do they need it? So, by rephrasing the headline to be more clear and imply that this is a mandatory step and not an optional one, my hypothesis was that we’ll reduce the confusion, get users’ attention and improve conversions.
So, we now have a short, clear, and direct headline. Followed by value props. By shortening the value props and tweaking them to be a little more relevant, the users would relate better with the page.
People don’t usually like paying fees. Add to it, getting a new account with extra fees is always going to be scary. Seeing zeroes on the summary of fees will help improve the conversion rate. Showing that there are $0 fees involved for most features will reduce user anxiety.
People want benefits at no extra cost. Also, they don’t trust corporations when it comes to fees and is usually worried about hidden fees. Letting them know that setting up an account is free and that we’ll show the fees upfront will reduce the drop-offs.

Research:

I dug up the extensive research done by my predecessors and content leadership for creating the page
Users had responded well to the short form disclosures. I didn’t want to take away the short-form only for users to be overwhelmed by the long-form disclosures.

First draft:

My approach:

For phase 0:

While we were removing the short-form disclosures, I also saw it as an opportunity to remove a few user pain points using content.

Since we would also be removing the summary of fees section - something that worked for us well, all of the long-form copy would require a tap from the users to expand and go read about the fees.
I was worried that our users may not read through all the legalese or take the effort in expanding and reading through all the fees, and they may just end up assuming that PayPal charges them fees for using this account.
I wanted to reassure them that only certain transactions require fees and most of the usual stuff - things they were doing till now - is free, just like before. (THe catch being Legal refrained us from using the word ‘free’.)

So, I borrowed cues from what worked for us earlier in the summary section.

What we know is that people liked seeing zeroes and it helped improve conversions. Showing that there's a $0 fee involved for most features will help reduce user anxiety and boldening it will draw their attention.
By letting our users know that setting up an account is free and that we’ll show the fees upfront when we do charge them, will reassure them and reduce the drop-offs too.

Creating a template

This screen would show up for 12 different use cases
I wanted to create a template for this screen so that it worked for all use cases

Working closely with Legal

Using regular cadences with the legal representatives, I ensured that the team was aware of the legal nuances.
We also used this opportunity to refresh some of the legal content that was not conversational or on-brand.

We added the Crypto and FDIC legal disclosures in the long-form to make it more compliant.

Changing the entry point:

I also used the opportunity to make some timely changes to the entry point of one of the most visited screens on PayPal.
This screen is shown to all users in the US when they receive money in their accounts. We give them the choice to either keep the money in PayPal or transfer it to their bank.

My rationale:

Hypothesis: By offering different value props or benefits, we will improve the conversion on the page.
Align with business objective: We checked the company objective to understand what we want the users to do. Keeping money in PayPal with PayPal Cash or PayPal Cash Plus account also unlocks a lot of new features for them.

For Phase 1: Combining 2 pages

Why combine 2 pages?

A/B test: We wanted to A/B test if combining the pages performed any better than the current experience of 2 different pages in the flow
- Our hypothesis was that by shortening the perceived time for completing the flow and by combining 2 pages of significant friction for users, we would improve the conversions.
Competition benchmarking: Most of the competitors were either flouting legal regulations or were combining these pages.
Making it easier for users to continue:
- By combining the disclosures and CIP into one coherent experience and by removing the short form fee disclosures, we intend to reduce friction for users.
- We would add a sticky button that would let users continue without scrolling all the way to the end of the page.
Measure the impact of disclosures:
- By randomly exposing users to Cash Plus disclosures instead of Cash disclosures as part of the experiment, we intend to measure the impact of our eventual goal of converging Cash and Cash Plus account constructs into a single balance holding account construct

Benefits:

With combined disclosures and CIP, there is a potential to reduce customer confusion, friction and improve the conversion funnel
If the experiment is successful, it will lay a foundation for us to simplify our offerings to the users

Challenge:

Legal mandate:
- We had to adhere to a few more legal restrictions:
  - Be explicit about communicating that It is a different account.
  - Do not use the words “free” or “upgrade”
  - Users needed to read the T&C before they proceeded to the next page.
    - This jeopardised our idea of using a sticky button.
User comprehension:
- How do we explain to the users why they needed a new account?
Limited space:
- The CFPB page with disclaimer was by itself a very long page. Merging another page with it meant a lot of information being crammed on a single page.
Building a template for all teams
- There were many versions of the 2 pages floating around the company. I wanted to standardise its implementation.
- How do we ensure that the page worked for all use cases and different teams?
- How could I let the teams explain the context on the page without meddling with the rest of the page.

My approach:

We tried to solve for user pain points by:

Giving context: Instead of an abrupt mention of a new account, I transitioned the copy to speak about the feature (PayPal balance) in the headline and then educate the users about why the feature required them to get a new account.
Adding a customisable section: This section would tell the users why they needed a new account. It would be customisable for any team that would use this page in their flow.
Remove user objection around data by giving them information around why we are collecting their info and what would we do with the data
Content workarounds to ensure that we are legally compliant:
- Sticky T&C + button: Since we couldn’t use the sticky button without ensuring that the users read the T&C, we made the T&C to be sticky with the button too.
- Descriptor: Using a descriptor copy that told users that the page also had fee-related info, we ensured that we were doing right by the users.

Results:

+ 3.4% users accepted the disclosures for Cash account
+ 1.9% users accepted the disclosures for Cash Plus account
+4% lift in the number of users who submit CIP