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IBCB Industrywide Activity

Background and Context

Customer Account Switching in 2022/23

The announced departures in 2021 of KBC Bank Ireland and Ulster Bank from the Irish market represented an unprecedented level of change and presented banks and customers with major challenges. The departure of two banks required large numbers of customers to move their bank accounts to one of the three remaining banks or another financial services provider in the market over the last twelve months. The switching process, and the unprecedented scale of the movement of bank accounts involved, was the subject of extensive media coverage and public and political discussion, including some negative predictions about the potential outcome for customers and banks. Customers impacted by the departure of the two banks from the market, along with stakeholders and advocates were understandably very concerned about access to banking services arising from these changes. Particular concerns were raised for customers in a vulnerable position and in need of additional support.

In May 2022 the IBCB along with the Banking & Payments Federation Ireland (BPFI) announced a set of Guiding Principles agreed to by our mutual member banks for the management of this account migration.1 The principles were motivated by the necessity to protect customers and staff throughout the process of change and centred on commitments to ensure adequate resourcing, and on providing both groups with timely, clear, and specific information and all necessary support. As part of these principles, the IBCB committed to assess adherence to the principles through our ongoing éist Public Trust in Banking Surveys.

Most of these challenges have been met through a combination of extensive and coordinated work on behalf of the banks themselves and the significant efforts of their customers. All key stakeholders in the sector, from the BPFI, individual banks, the CBI, customer advocates, direct debit originators, and the IBCB worked effectively together to ensure there was clear communication with customers on the actions they needed to take. Banks allocated dedicated staff to the process and vulnerable customers were prioritised. Exiting banks, working with stakeholders, identified that some customers required more time to complete the process, and timelines were adjusted accordingly. The IBCB member banks reported regularly to the Board on the progress being made on the current account switching process, and responded in detail in relation to questioning on how the interests of customers were being protected throughout.

The scale of account migration was enormous, highlighted in CBI statistics, published on 19th May, covering the period up to 28th April 2023, which stated that “In total 1,200,810 current and deposit accounts were opened across the three remaining retail banks since the beginning of 2022.”2 

The departure of the two banks has inevitably been reflected in the findings of the IBCB’s 2023 éist Public Trust in Banking survey.3 The survey results highlight that the impact of two of these banks leaving the market has understandably significantly impacted perceptions of trust and as a result, the wider trust score for all IBCB member banks is slightly lower than the collective industry.  Survey respondents are clearly unhappy with the extent of the change in the banking market and in relation to the IBCB member banks, the remaining banks are trusted more than those departing. The average trust level across the two departing banks is –38, which is materially lower than that of the three banks whose collective score is –4.

Our survey highlights that notwithstanding the scale of the migration, and the threat it posed to public sentiment towards banks, 48% say they are generally satisfied with the bank they have joined and only 16% say the process has undermined their trust in banks. Of those who were obliged to switch banks, 39% found the process easier than expected with 37% saying they felt supported by the bank to which they were switching.

After a slow start and despite the scale of account transfers, we believe that our member banks have managed the process well over the last twelve months, in cooperation with customers and other stakeholders and through significant effort by front line staff.

Transparent and respectful communications

Stakeholders have highlighted to us that there is a need for the sector to communicate with all customers – both profitable and less so, (particularly for customers in arrears or who may be in a vulnerable position), with greater respect and transparency. Respectful and transparent customer communication has been identified as a key requirement in rebuilding trust in member banks. There should be less jargon in documentation but also transparency when things go wrong. Customers expect to communicate with someone knowledgeable, who takes ownership for issues and deals with them in a straightforward and honest manner.

This is an ongoing area of focus for the IBCB and our member banks to consider how to address this need. Member banks are working with the IBCB to specifically look at how they communicate with customers in letters, looking to enhance customer letters to make them more personal, to ensure they are written in plain English and to explain necessary technical terms. Our member banks are working through their plans internally to determine how they can implement these changes. These changes can be applied to new letters without many difficulties. It is more complex to update pre-existing letters or templates, as many of these are generated by a number of IT systems at a particular point in a customer’s journey. This requires updates to impacted IT systems, which will take some time to address. We will be monitoring progress in this regard on an ongoing basis and will continue to work with our member banks and stakeholders to identify other initiatives to improve communications with customers.

The IBCB is committed to using transparent and respectful communications. To support this the IBCB are members of the National Adult Literacy Agency (NALA) and in February 2022 the IBCB team undertook NALA’s Plain English training and have been incorporating the learnings into our communications since then.

The team also received training from Employers for Change to gain a better understanding on how to create an inclusive communications policy for people living with a disability.

Guiding Principles for Customer Support for Account Closure, Opening & Moving

In May 2022 the IBCB along with the Banking & Payments Federation Ireland (BPFI) announced a set of further Guiding Principles agreed to by our mutual member banks for the management of the unprecedented account migration prompted by the intended exit of Ulster Bank and KBC Bank Ireland from the market. The principles are motivated by the necessity to protect customers and staff throughout the process of change and centre on commitments to ensure adequate resourcing, and on providing both groups with timely, clear and specific information and all necessary support. Customers impacted by the departure of Ulster Bank and KBC from the Irish market are understandably concerned about access to banking services going forward. While there are real challenges for the industry in managing this unprecedented market change it is also recognised that the manner in which it is done will have an impact on overall trust in the sector.

Each of our member banks reports to the Board regularly on their individual adherence to the Principles and how they are managing the ongoing change, both for customers and staff. We will be assessing adherence to these Principles going forward, including through our ongoing éist trust & sentiment surveys, which are core to the IBCB’s research-based work programme, and are published regularly.

The IBCB participated in the advisory group in the NALA Financial Literacy Research project. This research report was launched by NALA in December 2022.

We also participate in a financial literacy group coordinated by NT MABS.

Consultations

Department of Finance Banking Review

The IBCB participated in the Department of Finance ‘Future of Banking’, review of retail banking and submitted a response to the consultation. Our submission focussed on those aspects of the consultation which are core to the purpose and activities of the IBCB and focussed on promoting positive behaviour and culture in banking for the benefit of bank customers, staff and wider society.

In November 2022 the IBCB welcomed the publication by the Department of Finance of its report on the Retail Banking Review Consultation and expresses its appreciation for the opportunity to engage with the consultation process. The IBCB looks forward to reviewing the report’s recommendations and to discussing their implementation in consultation with the Department and wider stakeholders.

Ireland’s Women in Finance Charter

The IBCB is proud to support Ireland’s Women in Finance Charter. The Charter underpins the financial services industry’s ambition to see increased participation of women at all levels, including junior, middle, and senior management, leadership and board roles within financial services organisations based in Ireland.  We know that more diverse and inclusive workforces lead to diversity of thought and better decision-making in organisations.  The IBCB’s 2021 Éist survey of bank culture highlights perspectives from bank staff on equal opportunities in the industry. Women make up a higher proportion of junior grades and a lower proportion of senior grades. This is reflective of the global financial services sector but fostering and developing the careers of women in the banking industry will help recruit and retain talented staff and will contribute to a more inclusive and diverse industry, benefiting organisations and wider business community and society as a whole.

For more information on the charter, click https://www.betterbalance.ie/partners/

United Nations Environment Programme Finance Initiative Principles for Responsible Banking

United Nations Principles for Responsible Banking

The IBCB is proud to endorse the United Nations Principles for Responsible Banking. These Principles provide a framework to ensure that the strategies and business practices of Banks align with UN Sustainable Development Goals and the Paris Climate Agreement. Signatory banks commit to embedding the Principles in their business and to carry out impact assessments, developing specific commitments, setting targets, and reporting on these targets.

We believe the UN Principles are an important commitment from the banking sector to promote an environment where ethical behaviour is at the heart of banking. The Principles are closely aligned to the purpose of the IBCB; to work with member banks to build trustworthiness in order to assist the industry in regaining public trust.

Central to the UN Principles is a focus on sustainable banking practices which consider the needs of society and customers, to engage proactively and responsibly with stakeholders, to ensure transparency, accountability, effective governance, and a culture of responsible banking. The six UN Principles for Responsible Banking are:

  • Alignment;
  • Impact and target setting;
  • Clients & customers;
  • Stakeholders;
  • Governance & culture;
  • Transparency & accountability

Further information on the UNEP Finance Initiative Principles for Responsible Banking is available at https://www.unepfi.org/

The IBCB responded to the Decision Support Service consultation on the Code of Practice for Finance Professionals for the Assisted Decision-Making Act (ADMA) and to the Oireachtas Joint Committee on Children, Equality, Disability, Integration and Youth on the General Scheme of the Assisted Decision-Making (Capacity) (Amendment) Bill 2021. We look forward to the launch of the ADMA and the Decision Support Service, which will enable some customers to manage their own finances or to avail of specific supports to help them manage finances.

The Guiding Principles for Change

During the course of 2021, material announcements were made in relation to the composition of the Irish retail banking market with significant changes to branch operating models and with Ulster Bank and KBC Bank Ireland announcing their intention to leave the market. The IBCB recognises that from time to time there will be commercial decisions taken by our member banks which may result in both negative (and positive) impacts on specific customer and/or staff cohorts. While it is not the role of the IBCB to focus on the commercial aspects of these decisions, we are of course concerned with how the changes are implemented and whether it is done in alignment with the core elements of positive behaviour and culture – fairness, transparency, and accountability. In response to these ongoing changes, in September 2021, the IBCB developed a series of Guiding Principles of Change (‘the Principles’) for our member banks to adhere to, as relevant, where there are significant changes in operating models and/or activities resulting in material impacts on bank customers, and/or staff, and/or the wider market.

The Principles are designed to facilitate material changes being carried out in accordance with the principles of good culture and are composed of five broad categories:

  • Behaviour & Culture;
  • Corporate Citizenship;
  • Communications;
  • Structured Listening and Consultation, and;
  • Supports.

Each of those areas cover the key pillars of cultural change and within each are commitments which each of our member banks have agreed to adhere to. The Guiding Principles will enable the IBCB to challenge, review and be informed and updated on member banks change programs and whether these are being managed in line with the IBCB’s overarching objectives of promoting fair and transparent outcomes for Customers and Staff, underpinned by ethics and accountability.

Consultations

The IBCB responded to the Central Bank of Ireland (CBI) consultation processes on the CBI’s Strategic Plan review and Stakeholder Engagement review.

Additionally, the IBCB responded to the Decision Support Service consultation on the Code of Practice for Finance Professionals for the Assisted Decision-Making Act (ADMA) and to the Oireachtas Joint Committee on Children, Equality, Disability, Integration and Youth on the General Scheme of the Assisted Decision-Making (Capacity) (Amendment) Bill 2021. We look forward to the launch of the ADMA and the Decision Support Service, which will enable some customers to manage their own finances or to avail of specific supports to help them manage finances.

In October 2021, the IBCB responded with a submission for the Pre-Legislative Scrutiny of the General Scheme of the Central Bank (Individual Accountability Framework) Bill 2021 to the Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach. Individual accountability is a cornerstone of positive behaviour and culture. The IBCB and each of our five member banks are strong advocates for the introduction of an effective accountability regime in Ireland, similar to that in successful operation in many other jurisdictions globally.

During 2020 we contributed to a number of consultations on aspects of financial literacy, including:

  • Supporting the Competition and Consumer Protection Commission (CCPC) in their response to the National Council for Curriculum and Assessment consultation on the Draft Primary Curriculum Framework, highlighting the importance of financial literacy as a life skill for young people;
  • Submitting a response to the SOLAS Adult Literacy, Numeracy and Digital Literacy Strategy, highlighting the importance of financial literacy for adults.

The IBCB commissioned independent research through Gibney Communications to better understand the views and banking needs of specific cohorts in society, to inform our next steps in contributing to delivering positive banking change for communities and societies in Ireland.

The research project aimed to gather the views of bank branch staff and customers based in rural communities, key stakeholders and advocacy groups representing those in rural/ farming communities, those living with disabilities, SMEs, those in vulnerable positions and marginalised groups, through qualitative interviews, focus groups and some limited desk research.