금융상품의 가격차별과 금융소비자보호를 위한 공정성 이슈 검토

When selling financial products, various forms of price discrimination can occur, just as when selling general products or services. Certain forms of price discrimination may be considered acceptable, while other forms of price discrimination may be considered unfair. In this study, we examine the differences in price discrimination between financial products and general products and the difficulties in securing fairness through financial supervisory policies. To evaluate the fairness of price discrimination in financial products, we must consider not only issues related to general products, but also the unique characteristics of the financial industry and products, consumer protection issues, public interest, and competition policy. In particular, certain characteristics inherent to the financial sector, such as risk pooling and economies of scale, the dilemma of protecting superiorly informed institutions against inferiorly informed consumers, and the potential for primary price discrimination due to the service nature of the industry should be taken into consideration. Additionally, in order to resolve unfair price discrimination, a competition policy approach is needed that takes into account normal profits and the competitive structure between financial institutions. With regard to guidelines for fairness in price discrimination within financial products, adopting Hovenkamp’s regulatory framework(1999), considering the needs of low-income groups as outlined in the UK Financial Conduct Authority report (FCA, 2018), ensuring transparency in procedures and information disclosure, and employing indirect intervention methods are recommended. Lastly, this study explores challenges within the domestic financial industry, including issues surrounding low-cost fee incentives, the balance between consumer protection and choice, and the pursuit of practical fairness through industrial policies rather than direct intervention in price discrimination.