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IBCB Response to the Publication of the Department of Finance Retail Banking Review Public Consultation

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Written In-House

IBCB Response to the Publication of the

Department of Finance Retail Banking Review Public Consultation

29 November 2022: The Irish Banking Culture Board (IBCB) today welcomes 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.

CEO of the IBCB, Marion Kelly, today said: “Irish banking is continuing to evolve at pace with the imminent departure of two significant retail banking entities, Ulster Bank and KBC Bank Ireland. Their departure constitutes one of the most significant alterations to Irelands banking landscape in decades and it is critical that the principles of good behaviour and culture are adhered to throughout the process, in particular through ensuring sufficient support to those customers who need it when transitioning their banking arrangements. A robust and trusted banking sector is essential to the future prosperity of Ireland. Regardless of how the sector evolves, or how retail banking services are delivered, it is crucial that good culture, ethical behaviour and the interests of customers and staff remain central to the decision-making process in banks and the financial sector.”

Chairman of the IBCB, Mr Justice John Hedigan (Rtrd), said: “Restoring trust in banking remains crucial to the sector. No matter how the needs of customers are to be met now and into the future, trust and good behaviour need to be foremost in how banks make decisions and how they engage with customers and staff. This Retail Banking Review Public Consultation process to which the IBCB has made a substantial submission, is an important process in ensuring that the evolution of the sector remains rooted in meeting the needs of those it serves. The IBCB will continue to facilitate the cultural change needed to help restore the trust that is essential in society’s relationship with banks.”

The IBCB submission highlights the need to ensure that in the ongoing and necessary digitalisation of the banking sector that those who feel alienated or unable to engage with it, are not left behind. Retail banks need to find ways to promote the human, more trusted side of the sector, whilst continuing to deliver innovation.

The area of financial literacy, including digital literacy, is one which is frequently identified as a barrier for customers in managing their finances. While there is a range of financial literacy training available to consumers, we believe it would be helpful if an overarching national financial and digital literacy strategy was put in place. The EU ‘Financial competence framework for adults in the European Union’ provides a comprehensive framework for assessing financial competence and a national plan to implement this framework would provide a coordinated response to addressing the issue of financial literacy in Ireland.

On the issue of remuneration, the focus of the board is solely on bank staff and not on executive pay.

To ensure a level playing field in the market and enable the attraction and retention of the talent required to best serve customers, retail banking staff should be remunerated fairly when compared with peers in the wider industry We support the recommendations of the report that the current remuneration restrictions in relation to the award of flexible pay of up to €20,000, and benefits such as childcare/health insurance should be amended. The IBCB’s strong view is that the conditions on which these changes should be based are that all flexible pay be subject to appropriate behavioural performance assessment and the use of clawback provisions (as set out in the EBA guidelines) and the commencement of the Individual Accountability Framework (IAF) which is designed to hold individuals to account.

In this way, there is real potential for flexible pay to be used to reward, reinforce the right behaviours, and penalise inappropriate behaviours.

In conclusion, Marion Kelly said: “In looking to the future, the retail banking sector is now presented with an opportunity to draw a line under old behaviours and to embrace a positive cultural ethos that demonstrates to all that it is genuinely committed to placing positive customer outcomes at the centre of the decision-making process. The IBCB will continue to focus on cultural change in the sector, to help build on the progress already made and to hold our member banks to account as the inevitable evolution of the sector takes place.”


For more information:

Fiona Murphy, Edelman E: Fiona.Murphy@Edelman.com | T: + 353 87 819 4464

Notes to Editor:

About the Irish Banking Culture Board 

The Irish Banking Culture Board is an independent industry initiative established and funded by the five retail banks in Ireland (Allied Irish Banks, Bank of Ireland, KBC Bank Ireland, PTSB & Ulster Bank) with the purpose of working with their member banks to build trustworthiness in order to assist the industry in regaining public trust. The Board is independent with a non-banking majority, whose members are drawn from across Irish society. The role of the IBCB is to be an independent voice advocating for cultural change in the Irish banking industry. The IBCB is focused on culture and behavioural change in our member banks, in the knowledge that a changed culture will change outcomes.

The IBCB is not a lobbying or representative organisation. It does not act as a regulatory body nor duplicate the work of individual banks, the BPFI or the regulator.  


For more information www.irishbankingcultureboard.ie 


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