Comments Draft "National Strategy for Financial Literacy
Our motto is "WRITE IT SO THEY CAN READ IT"

We would like to begin by applauding you on your efforts to create a unified and structured approach for financial stability of the American people.  We concur with your proposed national vision, mission statement, goals and objectives stated within your document.
But we also believe there is an important missing key component in the practical application of your competency and financial education goals and objectives. Based upon our review, we would like to make four specific recommendations:

1. Include an overreaching goal and strategy, which not only determines and integrates financial competencies based upon life stages and events but also at particular “learning levels” (to include development at high school and college levels of financial competencies and educational needs). Develop this core content to meet the diverse needs of its learners to include the basics. Given the many different knowledge levels out there, there needs to be just as many different levels of explanation. In many cases this need is not met. We suggest a similar approach as one currently used by the Department of Energy (DOE) Office of Scientific and Technical Information (OSTI) – as mentioned later in this document.
2. Include an overreaching goal and strategy for strengthening provision of financial education based on the learning levels as determined in recommendation 1.
3. Once educational material at specific learning levels is developed, develop a comprehensive portal to collect and supply financial educational tools and training material with this material being findable by level of difficulty.
4. Comprehensive delivery to all participants within the financial community and to consumers through use of an information portal that sorts and delivers information according to user need and knowledge.

It has been our experience as a private company working with government agencies, that simply providing a variety of tools and information does not always lead to a particular desired result.   As you are well aware, not all Americans start out making their financial decisions based upon the same core knowledge and concepts. They come from varying backgrounds and education levels. Fortunately, the development of detailed standards of learning by the States has made it feasible to identify these different learning levels. As a result, educational materials can now be designed and provided on a much more targeted basis.

There is a progression of ever increasing knowledge with every individual, which can be precisely described in the terms of the core concepts at each level.  In fact, there is also a natural progression of core concept levels for each generic financial product, just as there is for each branch of the sciences. Different people are in different places on these product progressions, so educational material has to be tailored to them. 
Certainly a particular life stage or event, as you have stated in your objectives, is a factor in the financial education and awareness process. But more importantly the capabilities of those individuals understanding certain concepts are also a major component. It is our belief that words and the understanding of those words embody core knowledge. The underlying assumption being that terminology and subject matter always corresponds.

That is, in order to learn about X one has to talk about X. More technically, we define a concept as what one has to know in order to use a term correctly. A concept is therefore a body of knowledge. In any given subject the concepts are part of the core knowledge and therefore to learn a subject is to learn its terminology. This is just as true in the world of financial products as it is in the sciences, from Kindergarten through Graduate School.

Our STEM Education Center (http://www.stemed.info/) has worked extensively with the DOE’s Office of Science to develop a system of grade level stratification for science education. A similar approach can be applied to financial products and financial education.

DOE’s Office of Scientific and Technical Information (OSTI) aggregates and publishes on the Web all of DOE’s research results. OSTI has led in the development of www.ScienceEducation.gov, a new portal for federal educational materials related to science, technology, engineering and mathematics (STEM). Central to the development of SE.gov has been the creation of a new kind of ranking algorithm, one which estimates the grade or difficulty level of educational materials. In the process of developing this algorithm the STEM Education Center has specifically cataloged all of the science and technology concepts normally taught in grades K-12, as required by state standards of learning.

We have also extensively sampled and compiled the science related concepts taught in (a) basic college and (b) advanced undergraduate education. These grade level catalogs provide a new and potentially powerful approach to the design of science educational materials and in providing useable search tools on the Web.  We propose that the same approach can be used for our Recommendations 1 and 2 shown above for the development of educational tools for the public. 

Additional tools that might be helpful in determination of the issues within a particular financial process or document might be through the use of issue tree analysis. Issue tree analysis is an atomized approach to a particular issue and begins with the premise that every document has an underlying structure, one that can be “mapped out” on paper like an engineering drawing, which can then be used to improve communication, understanding and the resolution of competing interests.  We have had considerable success in using issue trees to design plain language financial products, by identifying all the core concepts. (Please see our attachment of a sample issue tree).

Regarding recommendation 4, we also suggest that the US Department of the Treasury consider a delivery mechanism similar to the one currently being considered by the DOE in their National Library of Energy (NLE). The NLE concept appears on pages 42-43 of the latest version 1.2 of the DOE Open Government Plan:
http://www.energy.gov/open/documents/FINAL_DOE_OGPVer1-2b_07July2010.pdf

The NLE will engage the public through web-based participation and collaboration mechanisms.  The NLE will be the government’s primary resource for supporting and promoting energy-related education and competency in our nation’s K-12 and university classrooms and laboratories.  And, most importantly, the NLE will be the nation’s pre-eminent source for accelerating energy-focused scientific discovery and technology implementation. Similarly we believe the US Department of Treasury can design an information sharing mechanism with the financial community and within all government agencies with financial missions. 

Thank you for the opportunity to respond to your draft proposal.  If you have any questions or would like to discuss this further, you may call Dr. David Wojick at 540-858-3136 or feel free to email us at mailto:dwojick@craigellachie.us.

Respectfully submitted,
David E. Wojick
Georgia Perry-Ray
The STEM Education Center
www.stemed.info
Our motto is “Write it so they can read it”

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