FINANCEOngoing practice88% confidence

Complexity as Extraction Tool

Financial product complexity is often deliberate — opacity is the product

Problem it solves

Inability to identify when complexity is a feature designed to obscure rather than serve

Best for

Consumers evaluating financial products; policy advocates pushing for standardisation

Not ideal for

Comparing identical transparent products from competing providers

Overview

Why this framework exists

Financial firms respond to consumer demand as it is, not as it should be — and because cognitive complexity is a barrier to comparison shopping, complexity is often profitable. Ramadorai documents multiple mechanisms: fee–rate trade-offs on mortgages that require a PhD-level calculation to evaluate; Indian bank MCLR pricing where each lender uses a different base and quotes 'MCLR + X'; post-regulation product proliferation in UK insurance that creates so many distinct products that the legal meaning of 'equivalent' ceases to apply.

The insight is structural: whenever a regulator tries to simplify, suppliers respond by proliferating products until complexity returns. This is not conspiracy but rational competitive response to incentives. Suppliers compete on who can exploit consumer confusion most efficiently, not on who can best serve consumer welfare.

The practical response at the individual level is to understand which comparisons are already standardised (index fund OCF charges in percentage terms) and which require re-engineering (mortgage total cost = rate × term + capitalised fee). For advocates, the policy lesson is that vague simplification mandates are insufficient — standardisation must be prescriptive and product-specific to be durable.

Core principles

5 total
  1. Complexity that benefits the seller at the buyer's expense is a product feature, not an accident.
  2. Regulatory attempts to simplify without prescribing exact formats will be outrun by supplier product proliferation.
  3. A comparison that requires expert knowledge to make correctly is a comparison the average consumer cannot make — and suppliers know it.
  4. The fee–rate trade-off collapses to a simple calculation only if both quantities are expressed in comparable units over the same time horizon.
  5. When every provider uses a different base rate for pricing, headline comparisons are meaningless.

Steps

4 steps
  1. Identify the comparison unit
    Before evaluating any financial product, determine what the correct unit of comparison is. For mortgages: total cost over the fix period (payments + capitalised fees). For index funds: OCF as a percentage. For insurance: premium × years at a given excess level. Resist any comparison the provider presents in a different unit.
    Pro tipProviders frame the unit that favours their product. Reframe to the unit that favours the consumer: total cash out over a fixed time horizon.
  2. Normalise the base before comparing rates
    When providers use different base rates (as with the Indian MCLR system), headline additive spreads are not comparable. Require or calculate the all-in rate in absolute percentage terms before comparison. In the UK, this means verifying that two 'LIBOR + X' quotes use the same LIBOR.
    WarningSwitching to a tracker that references a different rate than your existing deal means you are taking on basis risk — the spread between the two rates is not guaranteed to stay constant.
  3. Watch for product proliferation after regulation
    When a regulatory simplification has recently taken effect, check whether suppliers have responded by creating new product variants. If the number of SKUs has risen, the regulation may have been circumvented. This is the key lesson from the UK insurance price-walking ban.
    Pro tipAsk providers: 'How many distinct products do you offer in this category?' A very large number is a red flag.
  4. Demand the plain-vanilla equivalent
    In any financial product category, ask whether a simpler version exists with no bells, whistles, or embedded options. Compare the headline economics of both. If the plain version is almost as good, it is often better once hidden costs are accounted for.
    Pro tipThe existence of a plain version usually implies the complex version earns the provider more margin — which tells you where the extraction is happening.

Checklist

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Examples

3 cases
Indian MCLR mortgage quoting

Indian banks quoted mortgage rates as 'MCLR + X', but each bank had a different MCLR. A consumer seeing 'MCLR + 1' vs 'MCLR + 2' would rationally choose the first — without realising the first bank's MCLR was 3 points higher.

OutcomeA government reform requiring banks to reference a common external benchmark eliminated the problem. Ramadorai advised on this reform as part of his Indian government household finance work.
UK insurance price-walking aftermath

After the FCA banned price walking — charging loyal customers more than new customers for equivalent policies — insurers responded by proliferating product variants. With fewer customers in any one 'equivalent' bucket, the ban's scope shrank and pricing power returned.

OutcomeThe regulation reduced the most egregious walking but created a more fragmented market where the benefits of search increased even as the worst abuses declined — a classic regulatory whack-a-mole outcome.
UK mortgage fee–rate trade-off

The host described being offered a 3% mortgage with a £5,000 fee and a 6% mortgage with no fee, finding it impossible to determine which was cheaper. This is a textbook dominated-choice trap.

OutcomeRamadorai confirmed this is a documented academic finding — fee–rate complexity causes a material proportion of UK borrowers to make the inferior choice.

Common mistakes

5 traps
Trusting the provider's chosen unit of comparison
Providers present the metric that favours their product: monthly payment rather than total cost, rate rather than rate-plus-fee. Accepting their frame makes accurate comparison impossible.
Assuming post-regulation markets are simpler
Ramadorai's insurance research shows that price-walking regulation caused a surge in product proliferation, restoring supplier pricing power by eliminating the legal meaning of 'equivalent'. Reform does not automatically mean simplification.
Accepting headline rate comparisons across different base rates
The Indian MCLR example shows how identical-looking spreads over different bases produce very different all-in rates. The same logic applies anywhere providers use proprietary reference rates.
Treating complexity as a signal of sophistication
Complex products generate higher margins for sellers. A complicated-looking product is more likely to contain extraction mechanisms than a simple one, not less.
Assuming mandatory disclosure solves the problem
Disclosing fees in small print does not make them comparable. The UK mortgage market has required fee disclosure for years — the fee–rate comparison problem persists because the format is not standardised.

Origin story

How this framework came to be

Ramadorai developed this lens while doing policy work across multiple jurisdictions: India (MCLR mortgage quoting), Israel (opaque bundled mortgage products), and the UK (fee–rate trade-offs and post-price-walking-ban insurance proliferation). The pattern was identical in each case — regulatory simplification prompts supplier re-complexification at the margins.

Source

Traced to primary
Source · PODCAST
The Mortgage Trap Hitting Millions of Homeowners
Tarun Ramadorai · 2024
Open source →

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