How should financial institutions approach consumer protection differently when they offer services through smartphones rather than humans? This was the question we posed when the Smart Campaign team first started revising the standards to be applied to digital financial services, especially digital credit. We are very pleased to have launched the new Standards, their accompanying Guidance Document, and the companion Handbook for Regulators. What we didn’t expect, however, was quite how profound the differences would turn out to be. We made significant changes to the standards for all seven Client Protection Principles (the principles themselves remain the same). I want to focus here on the most fundamental: Appropriate Product and Delivery Design.