Customers in a Vulnerable Position

What we heard

This initiative sits within our Financial Awareness activities. 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 in the past year 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.

What we did

In light of the COVID-19 crisis, the IBCB has highlighted the needs of vulnerable customers.  Some, who experienced vulnerability prior to COVID-19 have 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 has highlighted those steps taken by member banks and the banking industry to provide systemic payment breaks initially, followed by a range of solutions to customers experiencing difficulty in making loan repayments.  We have 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.

Through our work with member banks in the area of bereavement, we became aware of the work of Embrace Farm, a charitable organisation, who provides support to farming families who experience loss or life-changing injuries.  The IBCB supported the publication of an important Embrace Farm supplement in the Irish Farmers Journal in June 2020. IBCB articles in the supplement focussed on raising awareness of the range of services and supports provided by IBCB member banks to farming customers in the event of a bereavement or life-changing injuries. The articles also covered the importance of preparing financial affairs for individuals, and the supports available for farm businesses in member banks. This supplement also included an opinion piece by Martin Stapleton, IBCB Board Member and Treasurer of the Irish Farmers’ Association (IFA) on the importance of banks treating all customers fairly and equitably, especially those who are in a vulnerable position.

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.

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.

Improving financial awareness for customers who are in a vulnerable position is an area of focus for the IBCB. As our plans develop, further details will be added to this page.