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Financial Awareness for Customers in a Vulnerable Position

Background and Context

What we heard

Improving financial awareness for customers who are in a vulnerable position is an area of focus for the IBCB. Financial vulnerability can occur at any time, it can be transient or permanent and many bank customers can find themselves in a vulnerable position for a range of reasons:

  • A change in personal circumstances; bereavement, divorce or separation, the breakdown of family relationships or supports
  • Issues with physical and mental health and wellbeing, including cognitive impairments, the diagnosis or onset of a serious or life-altering illness
  • A disability, which requires additional or alternative supports
  • Personal financial difficulties, including arrears and mounting debt
  • Marginalised groups, who may find it difficult to access financial services.
In our external engagement, and through our research, we have heard from customers, stakeholders, and members of the public that banks should demonstrate more support for customers in a vulnerable position. Our priorities have been focussed on initiatives aimed at raising financial awareness for such customers and undertaking more detailed research projects. This research identified specific groups of customers who may be in a vulnerable position and in need of particular supports from their banks.
We continue to liaise closely with Safeguarding Ireland, through our role on the National Safeguarding Advisory Committee and State Payments Group. We have also engaged with MABS, the Society of St. Vincent De Paul, the Open Doors Initiative, and the European Consumer Debt Network.

Additional support are available within our member banks for Customers in a Vulnerable Position

In September 2021, the IBCB facilitated a roundtable discussion between the Insolvency Service of Ireland (ISI) and member banks, to provide an informal opportunity to discuss areas for improvement and interaction between banks and the ISI, in support of customers in financial difficulty. The outcome of this discussion was agreement between participants in member banks and the ISI that member banks and the ISI would engage directly with each other with any feedback, in particular on the processes with Personal Insolvency Practitioners (PIPs), with a focus on improving process, communication and applying learnings to help customers who are in long-term arrears.

Throughout the COVID-19 pandemic, the IBCB highlighted the needs of vulnerable customers. Some, who experienced vulnerability prior to the pandemic faced an exacerbation of their circumstances and a significant number of bank customers have experienced vulnerability because of the impact of the virus on their health or financial circumstances. The IBCB highlighted steps taken by member banks and the banking industry to provide systemic payment breaks, followed by a range of solutions to customers experiencing difficulty in making loan repayments. We also highlighted positive steps taken by member banks to provide additional supports for customers in a vulnerable position, with specific times available for branch banking, dedicated phone lines, companion cards and other supports. In addition, we have promoted campaigns aimed at reducing financial abuse and fraud.

During 2020, we contributed to consultations related to aspects of supports for customers in a vulnerable position. In May 2020, we responded to the Law Reform Commission’s Issues Paper on ‘A Regulatory Framework for Adult Safeguarding’. The IBCB response focused on financial abuse which impacts on bank customers, bank staff, and institutions. The categories of financial abuse raised in the issues paper include thefts and scams, financial victimisation, coercion, signs of possible financial exploitation, and money management difficulties. These are issues which are also of concern to the banking industry, and all IBCB member banks have existing services in place to protect and support customers who may experience financial abuse.