Before the COVID-19 pandemic, Malaysia was already faced with multiple complex challenges – from the impacts of climate change, and ageing populations, to rising inequalities. The pandemic has only accelerated these challenges and to a large extent, also exacerbated vulnerabilities affecting households and individuals’ levels of financial resilience.
Given these challenges facing investors today, the burden of financial well-being is too heavy to rest solely on individuals themselves. To move forward beyond the present crisis, responsible finance will require that all stakeholders – government, policymakers, the financial industry, and more – treat individuals’ financial well-being as a shared responsibility.
Building Financial Resilience
Firstly, there is a need to build financial resilience across the population. As we explored previously in our series, a lack of financial resilience cuts across all drivers of vulnerability – predominantly linked to poor investment and saving behaviours, as well as an equally important factor when dealing with issues which are out of one’s control, such as unexpected life situations and industry-related issues.
It is crucial to acknowledge that some individual barriers faced by certain segments of the population to be able to save or invest, involve embedded structural challenges that cannot be solved purely by market-based solutions. These include sluggish wage growth, unemployment especially for youths, mismatches between labour demand and supply, the rise of the gig economy and lack of social safety nets.
Thus, a whole-of-nation approach which goes beyond the jurisdiction of any single regulator or an agency may be needed for holistic reforms that address both structural and individual barriers. Policymakers and regulators will need to focus their efforts on assisting vulnerable populations to become more financially resilient, such that they are better able to use market opportunities to save and invest.
Since investor vulnerability is multifaceted, driven by various factors such as personal and financial circumstances, age, geographical location, and investment experience – policy actions need to take a tiered and nuanced approach. This includes a review of incentive structures complemented with behavioural nudges that can help shape and sustain the necessary savings and investment behaviours.
Nudges are part of a wider toolbox in the behavioural sciences consisting of education and training, subsidies and taxes enable or restriction, and environmental restructuring (physical or social context) which specifically focuses on leveraging behavioural levers to guide people towards making decisions that benefit them the most in the long term, without significantly changing their present incentives.
Examples of ‘nudge’ initiatives include behavioural interventions like “save more tomorrow” and “sidecar savings”, which encourage saving for retirement in easy, convenient, and painless ways, as well as micro-investing applications that help build an investment habit by investing in smaller amounts of money like the spare change from daily purchases.
Raiz Malaysia for example is an automated investment service that rounds up each transaction from a user’s Debit Card to the nearest Ringgit and invests the change into a unit trust portfolio based on their financial situation and goals
(Source: Raiz Malaysia)
Dealing with vulnerable investors
Secondly, the building of financial resilience must then be complemented with a targeted approach to improve the protection of vulnerable investors. ICMR’s study identified key trigger points that indicate vulnerability such as discretionary income and perceived financial status, health status, level of retirement savings, level of financial literacy, investment experience and encounters with scams.
To identify if a possible investor could be vulnerable, the current Know-Your-Client (KYC) process could be further enhanced with the introduction of these trigger points into the process. Also, this assessment should be done on a more regular basis, preferably every 6 to 12 months, as one’s situation is not static and needs to be recalibrated accordingly.
Emphasis needs to be placed on market intermediaries and agencies to better identify and manage vulnerable investors. Regulators then need to focus on the “duty of care” by providing guidance and overseeing the conduct of capital market intermediaries, including fair treatment of vulnerable customers coupled with investor protection measures.
Most regulators have general guidelines for financial services that already require service providers to consider factors such as knowledge, experience, financial situation, and risk profile of the individual investor during service provision. At the same time, targeted programmes are being implemented in many jurisdictions to specifically protect certain vulnerable groups, like senior investors.
In Malaysia, financial regulators have certainly been vocal on issues affecting investors such as unlicensed activities and scams, retirement inadequacy, as well as the inclusiveness of capital markets for retail investors. Given the prevalence of challenges facing today’s investors, considering how investor vulnerability may affect these outcomes would be beneficial for future policy and research.
In line with this, the Securities Commission Malaysia (SC) launched the third Capital Market Masterplan (CMP3) in 2021, which identified “enhancing focus on protecting investors against vulnerabilities” as a strategic consideration, with the “identification and assessment of vulnerable investors” being one of the priorities over the next five years, as illustrated in the diagram below.
Source: Securities Commission Malaysia (SC)
Collaborative and behavioural insights for effective implementation
Creating policies and initiatives alone may not be enough to address the rising issues of vulnerability. To ensure the effective implementation of these initiatives, financial vulnerability must be viewed across the value chain. Our report highlights that vulnerability drivers are a combination of behavioural and structural issues that fall and cut across the purview and jurisdictions of multiple agencies.
Behavioural insights should be incorporated into every stage of a policy cycle, from development to all the way to post-implementation. While this may require embedding more rigorous evidence-based approaches to design and evaluation such as Randomised Control Trials (RCTs) into the policy cycle, it could eventually reduce the need for corrective measures once a policy is at the implementation stage.
RCT is a trial in which subjects are randomly assigned to either a treatment group or a control group. The treatment group receives the intervention being studied, while the control group receives either no intervention or a placebo. The effects of an intervention or treatment are measured by comparing outcomes between the groups.
Policymakers can also leverage this understanding to evaluate the effectiveness of policy implementation and make necessary adjustments. Behavioural insights can also help uncover unintended consequences or knock-on effects of certain policies, which regulators may not have been measuring or looking out for in the first place.
Given the delicate environment and crossroads of change, there is a dire need for policymakers to take proactive steps now while we still have the policy space to make reforms and improvements for the long term. With more collaboration with industry stakeholders, policymakers can create a resilient financial ecosystem that safeguards the interests of the most vulnerable investors.
This article is part of a content series by the Institute for Capital Market Research (ICMR). Follow ICMR’s Facebook page to stay updated on behavioural tips and insights for better investing habits. To learn more about ICMR’s research on new-age vulnerabilities, visit www.icmr.my or download the full report.