Argent - the journal of the Financial Services Forum
One of the most baffling moments in our two decades of campaigning was when we read a quote from a marketing expert suggesting that plain English was now outdated as a sales gimmick.
If you don't see anything wrong with that marketer's comments, this may not be the article for you. Plain English isn't just another marketing trick. It's not the sort of thing you learn about at a flashy conference full of PowerPoint presentations and enticing slogans ("LEARN THE 23 RULES GUARANTEED TO BOOST YOUR PROFITS BY 43%!!!"). Plain English is, at heart. about doing something morally right. However, you may be more interested in a pleasant side effect - it saves your company time, effort and (you'll like this bit) money.
We'll start with a scare story. In March 2003, the Financial Services Authority (FSA) issued its first fine for misleading financial advertising. DBS Financial Management forked out £100,000 for its sins.
It had sent out 4.5 million brochures inside national newspapers in June 2001. The FSA's objections to the brochure included:
- the phrase "100% capital security over five years" - this only applied on the fifth anniversary of the investment, rather than at all points during the five years;
- the front cover stating "all at no initial charge" - there was an initial charge of 6%; and
- using growth rates of 14.4% and 22.2% for projections - these were arguably extremely optimistic, and far higher than the FSA allowed.
DBS also failed to follow FSA orders to improve its processes for checking adverts before publication. FSA managing director Carol Sergeant said:
'This is the FSA's first fine for misleading advertising. We require financial advertisements to be "clear, fair and not misleading". The direct offer advertisement for "Protected ISAS" that was approved by DBS did not come close to meeting this standard
After the FSA began its investigation, DBS contacted all 455 people who had taken up the product in response to the advert and offered them a full refund.
Of course, most financial marketing material isn't anywhere near as misleading as this. But the precedent has been set. And it may not be long before more subtly misleading, or merely unclear, material attracts the attention of the regulators. Just look, for example, at how quickly "spin" has been devalued in the political context.
When Plain English Campaign began its work in 1979, the more brutally honest financial marketers told us their job was simply to sell products, and never mind if they weren't suitable for the buyer. But since pensions mis-selling, endowment scandals and split-caps mishaps, the industry has changed. Yes, the principle of "buyer beware" still applies, but making sure customers understand what they are buying is no longer a moral nicety. To put it frankly, if your customers know what they are getting into, they are less likely to tie up your legal department if their product performs badly.
It's not just legal fees you'll save with clearer documents. Think about the situation where a customer misunderstands the instructions on one of your forms. They tick two boxes when they should have ticked one. Or they write the date in the wrong format. Take the 28p you spend posting the form back for a second attempt, multiply it by thousands of forms a year and add on the staff time taken up in resending the forms. Add on again the hundreds of hours your call centres spend talking to customers baffled by your literature, and it doesn't matter if you think the customer is too dim to understand your brilliant prose - it's your firm's money down the drain.
And plain English can also save money in the strangest of ways. Peter Hammonds, then company secretary at NatWest, told the following story at one of our awards ceremonies:
"We were getting on great, we were beginning to be recognized as working well with plain English. We turned to our employee share schemes, which had an unsatisfactorily low participation rate. It was a good scheme but all too many of the staff were not choosing to take advantage. I realized that a lot of this was to do with the poor communications. It wasn't just the words, it was the design and the accessibility and the channels that we were using.
"But more importantly than that, we needed to deliver our message in a way that would genuinely appeal to employees and would in reality increase those participation rates. What we were doing was not only describing shares and share ownership, but also describing the operation of the scheme. When we came to explain the complicated process of how to join the scheme, we asked ourselves 'Why on earth do they have to do all that in the first place?'
"Our wanting to concentrate on clarity led to us ultimately changing the operation of the scheme - and plain English saved us a lot of money! It was truly astonishing. We were able to take out costs just on the back of trying to create a clear message."
So, how do you write in plain English? I'm afraid I can't offer "23 AMAZING INSIDER RULES!!!" because there are no unbreakable rules for clear communication. Writing clearly is an art, not a science. But there are some guidelines that usually help.
Keep your sentences short. We once saw a single sentence in a New Zealand mortgage agreement document that ran to more than 500 words. I doubt even a standard 25-year term is long enough for the borrower to make sense of that. We find an average of between fifteen and twenty-five words is enough to make a point without the reader losing the thread. But try to vary the length - this makes your writing come across as more human.
Prefer active verbs. The basic principle is to use "we will post the form to you" instead of "the form will be posted to you". Sentences written with active verbs are usually shorter and crisper. They also tend to make it clearer who is doing what'.
Use you and we. Terms such as "the recipient" and "the provider" make the process you are describing seem more distant and impersonal. Remember that, while the product you are selling may just be another policy number to you, it is an important part of your customer's life, affecting his wealth and security.
Choose words appropriate for the reader. This isn't a cue to be condescending. Simply make sure that you express your point in everyday terms that your intended audience will understand. If you must use financial jargon because there is no suitable alternative, be sure to explain the terms you use.
A senior figure in the financial industry once told me that if people didn't have a vocabulary and education at A-level standard, he wasn't worried about their inability to comprehend financial documents. Leaving aside the moral arguments this raises, it seems like a foolish business attitude to me. All recent trends point towards the "humble working folk" being forced into a far more active role in private financial activity in the future. Intellectual arrogance seems a pretty worthless reason to be losing business.
And the most important guideline for clarity in financial marketing? Don't be afraid to challenge "standard practice".
- If your copywriters tell you they have to use stock phrases, find out if this is just an excuse for preferring lazy repetitiveness to professional creativity.
- If your legal team tells you documents have to be full of archaic terms simply to make them legally sound, ask them to identify the genuine "terms of art". These are expressions that have a defined legal meaning established by previous court cases.' One study found such terms make up less than three per cent of a typical legal document.
- And if your compliance department says the stodgy small print has to be there because the regulators say so, then make the regulators justify this ugly intrusion on your shining example of clarity. The FSA's Practitioners Panel is just one place to raise your concerns.
We would like to think every financial marketing professional reading this will use plain English because it is the morally right thing to do when communicating with a customers More realistically, we expect many readers will find their hands are forced by tighter regulations on misleading or ambiguous promotional material.
But above all, we hope every reader will realize that plain English can create a situation where they can sell the right product to the right customer with far fewer wasted resources, both before and after the sale.
Surely that's better than any gimmick?