The ABA says it is working with ASIC and the ACCC to amend the Banking Code to incorporate the Financial Services Royal Commission recommendations for changes to Chapter 14 of the Code about vulnerable customers.
The paper discusses defining “vulnerable customers”. It notes that any definition of vulnerable customers should be sufficiently broad to ensure that it does not exclude any customer who should be included.
It observes that banks need to have in place effective and appropriate approaches to identifying, recognising and managing vulnerability to ensure delivery of good customer outcomes.
With respect to product and service design the consultation paper notes:
“One of the keys to addressing vulnerability and inclusion is to design inclusive products and services using robust customer feedback and monitoring of effectiveness. The seven Principles of Universal Design are recognised by banks as the foundation of the ABA’s Accessibility Principles for Banking and banks have committed to observing them in their strategy and approach to accessibility.
These principles are:
• Equitable use
• Flexibility in use
• Simple and intuitive use
• Perceptive information
• Tolerance for error
• Low physical effort
• Size and space for approach and use.”
The paper also discusses data collection, staff training, power of attorney arrangements, bank third-party authorisation forms, unsecured debt and collections, and scams.